Privacy Policy
This Privacy Policy explains how DIGI CREATIVHEADS LLP (LLPIN ACL-0995), trading as CreativHeads Agency ("we", "us", "our") collects, uses, shares and protects personal data in connection with Relay (relay.creativheads.com), our software-as-a-service customer messaging platform. Relay lets businesses ("Clients") connect WhatsApp Business, Instagram, Facebook Pages/Messenger, email and website chat into a shared inbox with an optional AI assistant.
For message and contact data that Clients process through Relay, the Client is the data fiduciary/controller and we act as a data processor on the Client's behalf and instructions. For Client account and billing data, we are the data fiduciary.
1. Information we collect
- Account information: name, email, phone number, business name, billing and GST details, and login credentials of Clients and their team members.
- Connected channel data: when a Client connects WhatsApp Business, Instagram, a Facebook Page/Messenger, email or website chat, we receive data made available through those platforms, such as account/page IDs and names, access tokens, business phone numbers, and messages, comments and attachments exchanged between the Client and its customers, with sender names, profile identifiers, phone numbers and timestamps.
- Knowledge content: files, FAQs, website content, catalogues and bot instructions a Client adds to train its AI assistant.
- Website chat data: messages and basic technical data (such as IP address and pages visited) from visitors who use a Client's website chat.
- Usage and technical data: log data, device and browser information, and essential cookies.
- Payment information: invoices and wallet transactions. Card and bank details are handled by our payment providers; we do not store full card numbers.
2. How we use information
- To provide, operate and support Relay, including routing, displaying, sending and receiving messages in the Client's inbox;
- To generate AI-assisted replies, drafts, summaries, transcriptions and translations when the Client enables those features;
- To manage accounts, billing, invoices and prepaid wallet balances;
- To communicate with Clients about service, security and account matters;
- To keep Relay secure, prevent abuse and comply with legal obligations.
3. Meta Platform Data (WhatsApp, Instagram, Facebook, Messenger)
We access data from Meta's platforms ("Platform Data") only through the permissions the Client grants, and handle it as follows:
- We use Platform Data only to provide Relay to the Client that connected the account, and for related security, support and legal compliance.
- We do not sell, license or rent Platform Data.
- We do not use Platform Data for advertising, ad targeting, profiling or any purpose unrelated to the Client's use of Relay.
- We share Platform Data only with service providers that help us run Relay, under confidentiality and data protection obligations, or where required by law.
- We comply with the Meta Platform Terms, Developer Policies and WhatsApp Business policies, and delete Platform Data when no longer needed, when an account is disconnected, or on a valid deletion request.
Clients can revoke Relay's access at any time from Relay, Meta Business Settings, or Facebook/Instagram Settings > Apps and Websites.
4. AI processing
When a Client enables the AI assistant, relevant message content and the Client's knowledge content are sent to third-party AI model providers solely to generate replies, drafts, summaries, transcriptions or translations. We do not use Client message content or Platform Data to train AI models, and we use providers whose API terms do not allow submitted data to be used for training. AI output may be inaccurate; Clients remain responsible for messages sent from their accounts.
5. Sharing and service providers
We share personal data only as needed to run Relay, with: cloud hosting, database, storage and email infrastructure providers; the messaging platforms the Client connects (such as Meta); AI model providers (if enabled); payment processors and professional advisers; and authorities where required by law. We do not sell personal data and do not use it for advertising.
6. Data retention
Relay data is kept while the Client's account and channel connections are active, or for a shorter period the Client configures. After a channel is disconnected or an account is closed, related data is deleted within 30 days, except limited records (such as invoices) we must keep for legal, tax or accounting reasons.
7. Data deletion
Email hello@creativheads.com with the subject "Data Deletion Request", or disconnect the channel in Relay or Meta settings. We delete the relevant data within 30 days. Full steps: Data Deletion Instructions.
8. Security
We use reasonable technical and organisational safeguards, including encryption in transit, access controls, restricted access to access tokens, and logging. We will notify affected parties and authorities of personal data breaches as required by law.
9. Your rights (DPDP Act, 2023)
Subject to India's Digital Personal Data Protection Act, 2023 and its rules, you may request a summary of your personal data and its processing; request correction, completion, updating or erasure; withdraw consent; nominate another person to exercise your rights; and seek grievance redressal from us and then from the Data Protection Board of India. If you are a customer of a business that uses Relay, you may also contact that business directly; we will assist it in responding.
10. Cookies
Relay uses essential cookies and similar technologies for sign-in, security and functionality. The Relay website does not use advertising cookies.
11. Children
Relay is meant for businesses and is not directed at children under 18. We do not knowingly collect children's data directly.
12. International transfers
Our service providers may process data outside India. We take steps to ensure such transfers are protected and comply with applicable law.
13. Changes
We may update this policy. We will post the new version here with a new effective date and notify Clients of material changes by email or in Relay.
14. Contact and Grievance Officer
Grievance Officer: Souban Mandayappuram · Email: hello@creativheads.com · Phone: +91 79949 40202
DIGI CREATIVHEADS LLP (LLPIN ACL-0995), trading as CreativHeads Agency
Karnataka, India
GSTIN: 29AAXFD5446L1ZJ
Email: hello@creativheads.com
Phone: +91 79949 40202