Privacy policy

This policy explains what data Winkie CRM processes, why, who it is shared with, how long it is kept and how you can exercise your rights.

1. Who we are

Winkie CRM is a sales and customer service system for WhatsApp operated by Winkie Business Development ("Winkie", "we", "us"), located at 7901 4th St N, Ste 300, St. Petersburg, FL 33702, United States.

This policy applies to the website winkie.ca/crm, to the Winkie CRM system and to the WhatsApp conversations handled by the system on behalf of the businesses that use it.

2. Our role in each situation

• Client businesses and their users. For the account data of the business that subscribes to Winkie CRM and of its team members who use the system, Winkie is the data controller.
• End customers of those businesses. When someone talks on WhatsApp with a business that uses Winkie CRM, that business decides how the data is used (controller). Winkie processes the data on its behalf, as a processor, following the business's instructions and this policy.
• Website visitors. For people who visit winkie.ca/crm or fill in the demo form, Winkie is the data controller.

3. Data we process

3.1 WhatsApp conversations

Received through Meta's official WhatsApp Business Platform: phone number, WhatsApp profile name, message content, media shared in the conversation (such as photos and audio) and message delivery status. When a conversation starts from an ad, we also receive the ad and campaign identifiers provided by Meta.

3.2 Data recorded in the CRM

Information the client business or the artificial intelligence records during the conversation: name, email, city, language, products or services of interest, deal stage, orders, activities, notes and payment status.

We do not collect identity documents (such as national ID numbers, passports or dates of birth), payment card numbers or financial account numbers over WhatsApp, in line with Meta's policies.

3.3 System users

Name, email, phone, access role and usage logs (such as sign-in dates and actions taken in the system), for security and auditing.

3.4 Customer portal

When an end customer tracks an order in the portal, they may sign in with a Google account. In that case we receive the name, email address and profile picture, and we store only the account identifier, for the sole purpose of confirming that the person opening the portal owns the order.

3.5 Payments

Payment requests are sent as payment links from a third-party processor (such as Square). Winkie does not receive or store card data: we only receive the payment status and amount.

3.6 Website visitors

Data submitted in the demo form (name, company, WhatsApp number and information about the business) and technical browsing data such as IP address and browser type.

4. How we use the data

• To handle WhatsApp conversations on behalf of the client business and record deals in the CRM.
• To manage orders, payment requests and order tracking in the customer portal.
• To generate reports and metrics for the client business.
• When the client business enables the integration, to tell advertising platforms (Meta and Google) which contacts became qualified leads or made a purchase, so the business can measure and optimize its campaigns. Phone numbers and emails are sent only in hashed form, as these platforms require.
• To keep the system secure, prevent abuse and meet legal obligations.
• To respond to demo requests.

Data received through WhatsApp is used only to support conversations with that person and the client business's activities related to them. We do not sell personal data and we do not use it for our own advertising.

5. Use of artificial intelligence

The first conversation with new contacts may be handled by an artificial intelligence (AI SDR) configured with the client business's information and rules. To do this, conversation content is processed by language model providers contracted by Winkie, which do not use that content to train their models.

The AI does not negotiate prices, does not make commitments on behalf of the business and hands the conversation to a person on the team when needed. End customers can ask to talk to a person at any time.

6. Who we share data with

7. How long we keep data

When the contract with a client business ends, its data can be exported and is then deleted, except where the law requires us to keep it.

8. Security

Each business's data is isolated from every other business. Access is role-based, connections are encrypted and the system logs relevant actions for auditing. Phone numbers and messages do not appear in plain text in technical logs.

9. Your rights

You may request access to, correction, portability or deletion of your data, and withdraw any consent you have given. If you are an end customer of a business that uses Winkie CRM, you can contact that business directly or contact Winkie, and we will forward the request to them. See how to request deletion on the Data deletion page.

10. How to stop receiving messages

Reply "stop", "sair" or "parar" in the WhatsApp conversation, or ask the business that serves you by phone or email. The request is recorded and the business stops sending messages until you start a new conversation.

11. International transfers

Winkie operates from the United States, and our providers may process data in other countries. When this happens, we apply the safeguards required by applicable law, including Brazil's General Data Protection Law (LGPD) for data subjects in Brazil.

12. Minors

Winkie CRM is a business system and is not intended for anyone under 18.

13. Changes

We may update this policy. The date at the top shows the latest revision, and material changes are communicated to client businesses.

14. Contact

Privacy questions and requests: