This Privacy Policy explains how Ukwaju Systems ("we", "us", "our") collects, uses, shares and protects personal information when you use PromoterPal (the "Service"). PromoterPal is an AI assistant that helps nightlife promoters answer guest messages on WhatsApp and Instagram, share guest-list and table links, and keep track of their guests.
This policy covers two groups of people:
- Promoters: our customers, who connect their WhatsApp Business and/or Instagram accounts to PromoterPal.
- Guests: people who send messages to a promoter who uses PromoterPal.
1. Who we are
PromoterPal is operated by Ukwaju Systems, a company registered in Kenya.
Ukwaju Systems
P.O. Box XXXX-80100, Mombasa, Kenya
Email: privacy@ukwaju.systems
Website: https://ukwaju.systems
For promoter account data, we act as the data controller. For guest conversation data, we process information on behalf of the promoter who uses the Service. The promoter is responsible for their relationship with their guests.
2. Information we collect
2.1 From promoters
- Account and contact details: name, business name, email address, phone number and billing details.
- Connected account details: when you connect through Meta's signup flow, we receive your WhatsApp Business Account ID, phone number ID, business portfolio ID, Instagram professional account ID and username, and the access tokens needed to send and receive messages for you.
- Business content you provide: event calendars, venue details, guest-list rules, table and bottle information, links and documents you upload.
- Usage information: settings, activity logs and technical data such as IP address, browser type and timestamps when you use our web pages.
2.2 From guests (through a promoter's connected account)
- Profile information shared by WhatsApp or Instagram, such as your phone number, display name or username.
- Message content: text, photos, voice notes, locations, button replies and other content you send to the promoter, and the replies sent back to you, including replies the promoter types personally in the WhatsApp Business app or Instagram.
- Message history: if the promoter chooses to share it when connecting, up to the previous 6 months of one-to-one chats from the WhatsApp Business app, plus their WhatsApp contact list.
- Interaction details: which events or links you asked about, whether you signed up, your feedback ratings, and message delivery status.
We do not ask for and do not intend to collect sensitive information such as health, financial account or government ID details. Please do not send these in chat.
3. How we use information
- To run the Service: receive messages, generate and send replies, share the correct event, guest-list and table links, and send follow-up messages such as sign-up check-ins.
- To show promoters their conversations, guest activity and reports, such as daily and weekly summaries.
- To check the accuracy of replies against the promoter's event information.
- To provide support, keep the Service secure, prevent abuse, and fix problems.
- To bill promoters and manage subscriptions.
- To meet legal obligations and enforce our terms.
We do not sell personal information, use guest data for our own advertising, or use it to build profiles for any purpose other than providing the Service to the promoter.
4. Artificial intelligence
PromoterPal uses AI language models to understand guest messages and write replies. Message content and relevant event information are sent to our AI provider to generate each reply. Under our provider's business terms, this data is not used to train their models. Replies are generated automatically and may occasionally contain mistakes. Promoters can read every conversation and reply personally at any time.
5. Legal basis (where applicable)
Where data protection laws such as the Kenya Data Protection Act, 2019 or the EU/UK GDPR apply, we rely on: performance of a contract (providing the Service to promoters); legitimate interests (running, securing and improving the Service, and helping promoters respond to guests who contacted them first); consent (where the law requires it, for example for certain follow-up messages); and legal obligation (where we must keep or disclose information by law).
6. Who we share information with
We share information only as needed to run the Service, with:
- The promoter whose account a guest is messaging. They can see the full conversation.
- Meta Platforms (WhatsApp and Instagram), to send and receive messages.
- OpenAI, our AI provider, to generate replies.
- Supabase, our database provider, to store event information, conversations and settings.
- n8n, our automation platform, to process messages.
- Our web hosting provider, for our website and signup pages.
- Authorities or other parties when required by law, to protect rights and safety, or as part of a merger or sale of our business (with notice to promoters).
Each provider may only use the information to provide its service to us.
7. International transfers
Our providers may store and process information outside Kenya, including in the United States and the European Union. Where required, we rely on appropriate safeguards such as contractual protections offered by these providers.
8. How long we keep information
- Guest conversations and related records: kept while the promoter uses the Service, and deleted within 90 days after the promoter disconnects or closes their account, unless the promoter asks for earlier deletion.
- Promoter account and billing records: kept while the account is active, and billing records for as long as tax and accounting laws require.
- Access tokens: deleted when a promoter disconnects their WhatsApp or Instagram account.
9. Security
We use reasonable technical and organisational measures to protect information, including encrypted connections (HTTPS), access controls, and limiting access to staff who need it. No system is completely secure, but we work to protect your information and will notify affected users and authorities of a data breach where the law requires.
10. Your rights
Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal information, to object to or restrict certain processing, and to withdraw consent. Guests can also stop messages at any time by blocking the promoter's number or account, or by asking in the chat.
To make a request, email privacy@ukwaju.systems. Guests may also contact the promoter directly. We will respond within the time required by law. In Kenya, you may also complain to the Office of the Data Protection Commissioner (odpc.go.ke).
11. Deleting your data
To ask us to delete your data, follow the steps on our Data Deletion page or email privacy@ukwaju.systems with the phone number or Instagram username you used. Promoters can also disconnect PromoterPal at any time from the WhatsApp Business app (Settings → Account → Business Platform) or from Instagram's connected apps settings.
12. Children
The Service is intended for adults. Nightlife events are generally for guests aged 21 and over in the United States. We do not knowingly collect information from children. If you believe a child has provided information, contact us and we will delete it.
13. Changes to this policy
We may update this policy from time to time. We will change the "Last updated" date above, and for significant changes we will notify promoters by email or in the Service.
14. Contact us
Questions about this policy or your information:
Ukwaju Systems, P.O. Box XXXX-80100, Mombasa, Kenya
Email: privacy@ukwaju.systems