Privacy Policy

ZAIMAH Technologies (“we”, “us”, “our”) operates funnl, an AI-powered WhatsApp CRM, booking, and multi-channel marketing platform for SME businesses across the UAE. This Privacy Policy explains how we collect, use, store, and protect personal data in compliance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL) and applicable international standards.

This policy applies to:

• End customers who interact with funnl-powered businesses via WhatsApp
• Business administrators who use the funnl dashboard
• Visitors to our platform and public booking pages

ZAIMAH Technologies
SHAMS Free Zone, Sharjah, United Arab Emirates
Email: support@zaimahtech.ae
Website: zaimahtech.ae

For data protection enquiries, contact us at support@zaimahtech.ae with the subject line “Data Privacy Request”.

3.1 End Customers (individuals booking or enquiring via WhatsApp):

• Name and WhatsApp phone number
• Appointment and booking details (service, date, time, staff preference)
• WhatsApp conversation history with AI assistant
• Star ratings and feedback provided after appointments
• Device language and approximate timezone

3.2 Business Administrators (funnl dashboard users):

• Name, email address, and phone number
• Business name, location, and sector
• Login credentials (passwords stored as one-way encrypted hashes)
• Usage data and activity logs within the dashboard

3.3 Automatically Collected Data:

• IP addresses and browser type (standard server logs)
• Page visit timestamps
• UTM campaign parameters (for tracking booking source)

We do not collect sensitive personal data as defined under UAE PDPL (health records, biometric data, financial credentials) unless explicitly required and consented to for a specific service.

Under UAE PDPL, we process personal data on the following lawful bases:

• Consent: when you message a funnl-powered business via WhatsApp, you consent to automated AI-assisted responses
• Contractual necessity: to fulfil booking confirmations, reminders, and appointment management
• Legitimate interests: to improve our AI models, detect fraud, and ensure platform security
• Legal obligation: to comply with UAE laws and regulations

We use personal data to:

• Process and confirm appointments and bookings
• Send WhatsApp booking confirmations, reminders, and follow-ups
• Operate our AI assistant (Fatimah) to handle customer enquiries
• Operate automated appointment reminder sequences via WhatsApp
• Provide the funnl dashboard to business administrators
• Power multi-channel marketing campaign execution on behalf of businesses
• Generate AI-assisted ad copy and creative content for campaigns
• Track campaign performance across Meta, Google, and WhatsApp channels
• Provide lead scoring and conversion analytics to business administrators
• Improve AI response quality through anonymised learning
• Send marketing messages only with explicit opt-in consent
• Comply with legal obligations and resolve disputes
• Detect and prevent fraud, abuse, and security incidents

We do not sell, rent, or trade personal data to third parties for their own marketing purposes.

funnl uses Meta's WhatsApp Business API to send and receive messages on behalf of our business clients. By messaging a funnl-powered business on WhatsApp, you acknowledge:

• Your messages are processed through Meta's infrastructure
• Meta's own Privacy Policy applies to all WhatsApp communications
• Message content is end-to-end encrypted in transit by WhatsApp
• We store message content on our secure servers to enable conversation continuity and AI improvement
• You can opt out of AI-assisted messaging at any time by replying STOP

We share personal data only in the following circumstances:

7.1 With our technology partners (data processors):

• Anthropic PBC — AI language model for conversation and copy generation
• Hetzner Cloud (Germany) — server infrastructure and data storage
• Meta Platforms Inc. — Facebook, Instagram advertising and WhatsApp Business API
• Google LLC — Google Ads and YouTube advertising platform
• Prisma / PostgreSQL — database management

All processors are bound by data processing agreements requiring PDPL-equivalent protections.

7.2 With the business you are booking with: Your name, phone number, and booking details are visible to the business you have contacted through funnl.

7.3 For legal compliance: We may disclose data if required by UAE law, court order, or government authority.

7.4 Business transfers: In the event of a merger or acquisition, personal data may be transferred to the successor entity under equivalent privacy protections.

• Customer booking and conversation data: 2 years from last interaction
• Business administrator account data: duration of active contract plus 90 days after termination
• Server and access logs: 90 days
• Anonymised, aggregated analytics data: indefinitely

After retention periods expire, data is securely deleted or irreversibly anonymised.

We implement technical and organisational measures including:

• TLS 1.2+ encryption for all data in transit (HTTPS)
• AES-256 encryption for sensitive data at rest
• Bcrypt hashing for all passwords
• Role-based access controls and least-privilege principles
• Regular security assessments and penetration testing
• Incident response procedures with 72-hour breach notification to the UAE Data Office as required under PDPL

As a data subject under UAE PDPL, you have the right to:

• Access: request a copy of personal data we hold about you
• Correction: request correction of inaccurate or incomplete data
• Deletion: request deletion of your personal data (right to erasure)
• Restriction: request restriction of processing in certain circumstances
• Portability: receive your data in a structured, machine-readable format
• Objection: object to processing based on legitimate interests
• Withdraw consent: at any time, without affecting prior processing

To exercise any of these rights, email support@zaimahtech.ae with subject “Data Rights Request”. We will respond within 30 days as required by PDPL.

To opt out of WhatsApp marketing messages, reply STOP at any time.

Our servers are hosted in Germany (Hetzner Cloud). By using funnl, you consent to the transfer of your personal data outside the UAE. We ensure adequate safeguards are in place through contractual clauses and security standards that meet UAE PDPL requirements for cross-border transfers.

Our public booking pages use minimal cookies for:

• Session management (essential, no consent required)
• UTM parameter tracking for booking source attribution

We do not use third-party advertising cookies or behavioural tracking.

funnl is not directed at children under the age of 13. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact support@zaimahtech.ae.

We may update this Privacy Policy from time to time. Material changes will be notified via email to business administrators and posted on this page with an updated date. Continued use of funnl after changes constitutes acceptance of the updated policy.

ZAIMAH Technologies
SHAMS Free Zone, Sharjah, UAE
Email: support@zaimahtech.ae

If you are dissatisfied with our response, you have the right to lodge a complaint with the UAE Data Office (uaedataoffice.gov.ae).