Privacy Policy

Last updated: September 15, 2026

1. Who we are

SMALAND COMPANIE S.A.S. (tax ID 901.918.761-6), registered at Cra. 115 A # 16-200, Cali, Valle del Cauca, Colombia, is responsible for the personal data described in this policy. Contact: info@smalandcompanie.com.

We provide software services to other companies. When we operate a client's messaging channels, that client is the data controller for their own users and we act as a data processor, following their instructions and this policy.

2. What data we process

• From people messaging our clients: phone number or social handle, profile name, the content of the conversation (text, photos, voice notes, files) and the details the person shares in order to be helped.
• Advertising: if the conversation started from an ad, the click identifier the platform attaches to the first message.
• From our clients: business contact and billing details, and the technical credentials needed to run the service.
• From this website: basic technical browsing data.

We do not ask for sensitive data. If someone shares it spontaneously in a conversation, it is treated with the same confidentiality and deleted on request.

3. Why we use it

• To handle the conversation and deliver the service our client contracted.
• To generate the automated assistant's replies.
• To measure the effectiveness of the client's advertising.
• To meet legal and contractual obligations.

We do not sell personal data and we do not use it for our own advertising.

4. Who we share it with

• The client who owns the channel, who handles the conversation.
• Meta Platforms (WhatsApp, Instagram and Facebook), as the operator of the messaging channels and ad measurement.
• Google, whose Gemini language model processes conversation text to draft the assistant's replies.
• Cloudflare, where the service runs and stores data.
• Authorities, where the law requires it.

Some of these providers are outside Colombia, so an international transfer of data may occur under the corresponding contractual safeguards.

5. How long we keep it

The assistant's working memory for an inactive conversation is erased automatically after 90 days. Conversation records are kept for the duration of the client contract and deleted when it ends, unless the law requires otherwise.

6. Your rights

Under Colombian Law 1581 of 2012 you may access, update, correct and delete your data, request proof of your authorization and revoke it. Write to info@smalandcompanie.com. We answer queries within 10 business days and complaints within 15 business days. To delete a conversation, see Data Deletion.

7. Security

We verify the signature of every webhook, keep secrets out of the code, isolate each client's data and give every token the least privilege it needs. No system is infallible, and we do not promise absolute security.

8. Changes

Any change to this policy will be published on this page with its update date.

This document describes our actual practices and is not legal advice.