eglowsChat

Privacy Policy

Last updated: August 25, 2026

This policy describes how FLEITAS SOFTWARE SA (“EGLOWS”, “we”, “us”) processes personal data in eglowsChat, a platform that lets businesses handle conversations, reply with an automated assistant, and send notifications and campaigns through Meta’s WhatsApp Business Platform.

1. Who is responsible for processing

FLEITAS SOFTWARE SA, located at DURAZNO, URUGUAY, based in Uruguay, is responsible for the processing described in this policy. For any privacy enquiry, write to us at contacto@eglows.com.

When a business customer uses eglowsChat to communicate with its own customers, that business acts as the controller of its recipients’ data and EGLOWS acts as processor, handling the information solely according to its instructions.

2. What data we collect

  • Conversation data: phone number in international format, WhatsApp profile name, the content of messages sent and received (text, images, audio, video and documents) and their attachments.
  • Messaging metadata: message identifiers, date and time, delivery and read status, and error codes returned by Meta.
  • Automated assistant data: where the assistant is enabled on a conversation, the message content sent to it to generate a reply, the reply produced, and a record of when the assistant intervened and when the conversation was handed over to a person.
  • Campaign and consent data: membership of a sending list, the status of each send, and the record of opt-in or opt-out for marketing communications.
  • Business account data: WhatsApp Business Account (WABA) identifier, the associated phone number and its identifier, and the message templates created.
  • Platform access data: operator username and the technical logs needed to maintain the session and the security of the service.

We do not collect special categories of data, and we do not request financial information or third-party credentials over WhatsApp.

3. What we use the data for

  • Displaying conversations and their history to authorised operators.
  • Sending and receiving messages, including template notifications and reminders.
  • Generating automated support replies where the assistant is enabled on a conversation.
  • Running marketing campaigns to recipients who gave their consent, and honouring opt-outs.
  • Creating and managing message templates and the business account’s phone numbers.
  • Diagnosing delivery errors and keeping the service secure and available.
  • Meeting legal obligations and the WhatsApp Business Platform policies.

We do not use message content for advertising unrelated to the business that contacted you, we do not sell it, and we do not use it to train artificial intelligence models.

4. Automated assistant

eglowsChat offers an automated assistant that can reply to messages on behalf of the business. Its operation has explicit limits:

  • Scope limited to business support. The assistant only answers questions about the activity of the business using it: its products, services, opening hours, prices, appointments, orders, shipments and related procedures. It is not a general-purpose conversational assistant: it does not answer questions unrelated to the business, nor does it offer medical, legal, financial or any other advice outside that scope. When a request falls outside its scope, it says so and hands the conversation over to a person.
  • Enabled and disabled per conversation. The business decides, separately for each conversation, whether the assistant takes part. With the assistant disabled, every reply comes from a person.
  • A person is always available. You can ask to speak to a person at any time, and the business can take over the conversation whenever it deems it necessary.
  • No automated decisions with legal effects. The assistant informs and guides; it does not on its own make decisions that produce legal effects concerning you or similarly significantly affect you.
  • How the content is processed. To generate the reply, the message content may be processed by a language model provider acting as a sub-processor under contract, bound not to use that content to train its models or for any purpose of its own.

5. Marketing communications

Businesses may send marketing campaigns — promotions, news and offers — through templates previously approved by Meta. These communications are subject to additional rules:

  • Prior consent. They are sent only to recipients who agreed to receive them. Consent is specific to commercial communications and is separate from the fact of having contacted the business with an enquiry.
  • Opt out at any time. You can stop receiving campaigns by replying to the message with an opt-out request or writing to contacto@eglows.com. Opting out is free and you do not need to give a reason.
  • Opting out does not interrupt support. Unsubscribing from campaigns does not affect your ability to keep talking to the business, nor your service messages such as an order confirmation or an appointment reminder.
  • No profiling. We do not build advertising profiles and we do not combine your data with external sources to segment communications.

6. Legal basis

We process data on the basis of the performance of the contract with our business customers, the consent of the individual when starting a conversation or agreeing to receive marketing campaigns, our legitimate interest in keeping the service secure and operational, and compliance with legal obligations.

7. Who we share data with

  • Meta Platforms, Inc.: provider of the WhatsApp Business Platform. Sending and receiving messages necessarily passes through its infrastructure, subject to the WhatsApp Business terms.
  • Language model provider: only where the automated assistant is enabled on the conversation, and only with the content needed to generate the reply.
  • Infrastructure provider: the server hosting eglowsChat and its database.
  • Competent authorities: only where there is a legal obligation.

We do not sell or transfer personal data to third parties for commercial purposes.

8. International transfers

Meta’s services, the language model provider and our infrastructure provider may process data outside Uruguay. Where that happens, transfers rely on standard contractual clauses or other equivalent safeguards.

9. How long we keep the data

We keep conversations and their history for as long as the business customer keeps the service active, up to a maximum of 24 months from the last message, unless the law requires a different period. Attachments are retrieved from Meta on demand and are not stored permanently on our servers. The record of a marketing opt-out is kept for as long as needed to keep honouring it. Deletion requests are handled as described in the next section.

10. Data deletion and your rights

You may at any time request access, rectification, portability, restriction, objection or deletion of your personal data. The request is free and you do not need to give a reason:

  • Write to contacto@eglows.com stating the phone number concerned. Detailed instructions are on the user data deletion page.
  • We verify that the request comes from the person who owns the number before carrying it out, so that nobody can request the deletion of someone else’s history. We process it within 30 calendar days and confirm once it has been carried out.

Deletion covers every piece of data we hold about you: contact, conversations, messages, referenced attachments, interactions with the automated assistant, campaign list membership and delivery metadata. It does not cover the copy Meta keeps in its own infrastructure, nor records we are required to retain under an express legal obligation; in that case we tell you the reason and the retention period.

If you believe we have not handled your request properly, you may lodge a complaint with the data protection authority in your jurisdiction.

11. Security

Access to eglowsChat requires authentication and is served exclusively over HTTPS. Sessions are handled with signed, server-only cookies, and incoming events from Meta are cryptographically verified before being processed. Access to conversations is limited to authorised staff of the business customer.

12. Minors

eglowsChat is a professional tool and is not directed at anyone under 16. We do not knowingly collect data from minors.

13. Changes to this policy

If we change this policy, we publish the updated version at this same address and change the last-updated date. Material changes are also communicated to business customers.

14. Contact

FLEITAS SOFTWARE SA · contacto@eglows.com · DURAZNO, URUGUAY · Uruguay