Five Senses Pte Ltd WhatsApp Bot Privacy Policy

1. Introduction

Five Senses Pte Ltd (“Five Senses”, “we”, “us”, “our”), UEN 201910283W, with registered office at 1 Coleman Street, #03-21, The Adelphi, Singapore 179803, provides a conversational WhatsApp Business bot (“Bot”) via the Meta Business Platform. This policy explains how we collect, use, disclose, and store personal data in compliance with:

– WhatsApp and Meta Platform Policies,

– Singapore’s Personal Data Protection Act (PDPA), and

– Applicable international laws (e.g., GDPR where relevant).

2. Scope & Consent

By opting in to receive messages via WhatsApp, you expressly consent to our collection, use, and processing of your personal data described herein. You may withdraw consent at any time by texting “STOP” in WhatsApp or contacting us.

3. Information We Collect

– User-provided information: phone number, name, preferences, messages, and media you share within the Bot.

– Metadata: timestamps, message IDs, message frequency, and basic analytics.

– Technical data: device type, OS version, IP address (if retrieved via integration).

– We do not access your end-to-end encrypted message contents—these remain private between you and Meta.

4. Purpose of Use

We use your data to:

– Send messages and responses you request,

– Provide customer support,

– Share updates or promotions only if you opt in,

– Analyze usage to improve Bot functionality, and

– Satisfy legal obligations and prevent abuse.

5. Legal Basis & Data Minimization

Processing is based on your explicit opt-in. We collect only what’s necessary to serve you. Sensitive data is handled solely with your explicit consent and minimized wherever possible.

6. Data Retention

Data is stored only for as long as needed:

– Support conversations: up to 12 months (or as required by law),

– Marketing consent logs: one year after withdrawal,

– Metadata: six months.

After these periods, data is securely deleted or anonymized.

7. Data Sharing & Disclosure

We may share your personal data with:

– Meta – for Bot delivery and functionality; only non-content metadata is shared.

– Service providers – cloud infrastructure (SOC 2 certified), analytics vendors, messaging platforms, all under strict contractual obligations.

– Regulatory authorities – only if required by law (e.g., court orders, investigations).

No data is sold, leased, or used for targeted advertising beyond Bot operations.

8. Data Transfers

If personal data is transferred outside Singapore, we ensure foreign recipients uphold comparable PDPA or GDPR standards via binding contracts or other legal mechanisms.

9. Security Measures

We implement physical, technical, and organisational safeguards, including:

– Encryption in transit (TLS) and at rest,

– SOC 2-compliant infrastructure,

– Restricted, need-to-know access controls, and

– Regular security audits and penetration tests.

10. User Rights & Controls

You can:

– Access or request correction/deletion of your data,

– Withdraw consent or unsubscribe at any time,

– Object to or restrict processing,

– Lodge complaints with the PDPC, and

– Port your data in a structured, machine-readable format.

Submit requests via email or WhatsApp.

11. Children’s Privacy

Our Bot is not designed for users under 18. We don’t knowingly collect children’s data. If we become aware that a user is underage, we’ll delete their data promptly. Parental consent is required where legally necessary.

12. Opt-In & Opt-Out Procedures

– Opt-in: You must proactively message the Bot or confirm via a separate channel before we contact you.

– Opt-out: Reply “STOP” or contact us. After opt-out, all Bot messaging ceases except confirmation messages.

13. Updates to This Policy

We may revise this policy to reflect changes in laws, Bot operations, or Meta requirements. Updates will be posted here with an updated “Last Updated” date. We’ll notify you via WhatsApp or email of material changes.

14. Contact & Complaints

For privacy inquiries, access requests, or complaints, please contact our Data Protection Officer (DPO):

Mailing Address: 1 Coleman Street, #03-21, The Adelphi, Singapore 179803

Attn: DPO

We aim to resolve complaints within 30 business days.