SMS & WhatsApp Privacy Policy

1. Introduction

This SMS & WhatsApp Privacy Policy ("Policy") describes how Winkie — Operational Systems Engineering ("Winkie," "we," "our," or "us") collects, uses, and protects information related to text messaging (SMS/MMS) and WhatsApp Business communications sent or received through our messaging program (the "Program"). This Policy supplements our general Privacy Policy and applies in addition to it.

Our messaging is delivered through third-party communication platforms, including Twilio Inc. and the WhatsApp Business Platform (Meta Platforms, Inc.). By providing your phone number and consenting to receive messages from Winkie, you agree to the practices described in this Policy.

2. Program Description

The Program is operated by Winkie for the purpose of communicating with current clients, prospective clients, and individuals who have explicitly opted in to receive messages from us. Messages may include:

• Transactional notifications (appointment confirmations, onboarding updates, account/service alerts);
• Customer support replies and follow-ups;
• Promotional and marketing communications about Winkie products, services, and offers (only with prior opt-in);
• Operational updates related to ongoing engagements.

3. Consent & Opt-In

We only send messages to individuals who have provided prior express consent. Consent is collected through one of the following channels:

• A web form on winkie.ca with a non-pre-checked opt-in checkbox;
• A written agreement (contract, proposal, or service order) where you explicitly authorize messaging contact;
• A verbal or in-person request, confirmed by a follow-up double opt-in message.

The exact opt-in language presented to you is: "I agree to receive SMS and/or WhatsApp messages from Winkie regarding my account, services, and (if I check the marketing box) promotional offers. Message and data rates may apply. Message frequency varies. Reply STOP to cancel or HELP for help."

We retain a record of each opt-in, including timestamp, IP address (where applicable), the exact consent language shown, and the channel used.

4. Message Frequency & Costs

Message frequency varies based on your relationship with Winkie and the message type. Transactional messages are sent as needed. Marketing messages are limited to a maximum of 4 messages per month unless you have explicitly agreed to a higher frequency.

Message and data rates may apply. Winkie does not charge for the messages themselves, but your mobile carrier may charge you according to your plan.

5. Opt-Out (STOP) & Help (HELP)

You can opt out of the Program at any time, free of charge:

• Reply STOP, UNSUBSCRIBE, CANCEL, END, or QUIT to any SMS message from Winkie. You will receive a single confirmation message and will not receive further messages, except in response to your direct request.
• For WhatsApp, reply STOP or send a message stating you no longer wish to receive communications.
• You may also email admin@winkie.ca requesting removal from the Program.

For assistance, reply HELP to any message. You will receive contact information for Winkie customer care. You may also reach us at admin@winkie.ca or +1 (672) 727-8734.

6. Information We Collect Through the Program

• Phone number (mobile number you provide for messaging);
• Opt-in metadata (timestamp, IP address where applicable, opt-in source, and consent language presented);
• Message content you send to us in reply (subject to applicable platform retention);
• Delivery metadata from Twilio and WhatsApp (delivery status, error codes, timestamps);
• Carrier and device data as required to route messages.

7. How We Use Your Information

• To deliver requested transactional and marketing messages;
• To honor your opt-out and HELP requests;
• To maintain records required for legal and regulatory compliance (TCPA, CASL, CTIA guidelines, Meta WhatsApp Business policies);
• To troubleshoot delivery issues and improve message quality;
• To protect against fraud, abuse, and unauthorized use of the Program.

8. Information Sharing & Disclosure

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors that support the Program — such as messaging infrastructure providers (Twilio), the WhatsApp Business Platform (Meta), and customer-support tooling — is permitted strictly to operate the Program. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We may disclose information when required by law, subpoena, court order, or to protect the rights, property, or safety of Winkie, our users, or others.

9. WhatsApp Business Platform

WhatsApp messages are delivered through the WhatsApp Business Platform via Twilio. When you message us on WhatsApp, your communication is also subject to Meta's WhatsApp Privacy Policy and WhatsApp Business Messaging Policy.

Outside of the 24-hour customer-service window, Winkie will only contact you with pre-approved template messages that match the category you opted in to. We do not send content prohibited by Meta's Commerce Policy or Business Messaging Policy.

10. Data Retention

Opt-in and opt-out records are retained for as long as you remain in the Program and for a minimum of 4 years after your opt-out, as required by U.S. messaging regulations. Message content is retained only as long as necessary to operate the Program or comply with legal obligations.

11. Security

We apply administrative, technical, and physical safeguards to protect Program data, including access controls, encryption in transit, and use of reputable infrastructure providers. No method of transmission over mobile networks or the internet is 100% secure, and we cannot guarantee absolute security.

12. Your Rights

Depending on your jurisdiction (including the U.S. CCPA/CPRA, Canada PIPEDA, and Brazil LGPD), you may have the right to access, correct, delete, or restrict use of your personal information. To exercise these rights regarding messaging data, contact us at admin@winkie.ca.

13. Changes to This Policy

We may update this Policy from time to time. The "Effective Date" above will reflect the most recent update. Material changes will be communicated through the Program or our website. Continued participation after changes constitutes acceptance.

14. Contact Information

For questions regarding this SMS & WhatsApp Privacy Policy, contact: