1. Introduction
Code Q Software Solutions Co. Ltd. ("Company", "we", "our", or "us") is committed to protecting the privacy and security of personal data collected from our clients, end-users, and visitors. This Privacy Policy details our practices regarding the collection, use, disclosure, and safeguarding of information when you utilize our software development services, platforms, and integrations—specifically including our WhatsApp Business API solution services.
By accessing our services, integrating with our platform, or utilizing our WhatsApp Business API solutions, you agree to the collection and use of information in accordance with this Privacy Policy and Meta's technical and commercial guidelines.
2. Scope & Applicability
This policy applies to all personal data processed by Code Q Software Solutions Co. Ltd. in its capacity as both a Data Controller and a Data Processor, depending on the service provided. Specifically, it addresses:
- Enterprise client accounts utilizing Code Q solutions.
- End-users interacting with clients via Code Q’s WhatsApp Business API integration.
- Visitors to the Code Q corporate website and software portals.
3. Information We Collect
We collect information directly from users, automatically through system usage, and via third-party integrations such as Meta Platforms, Inc.
| Data Category | Types of Information Collected | Primary Purpose |
|---|---|---|
| Account Information | Name, business email address, phone number, company designation, billing address. | Account administration, service provision, identity verification. |
| WhatsApp Messaging Data | WhatsApp User ID (Phone Number), display names, message timestamps, delivery receipts, user opt-in records, message metadata. | Message delivery, routing, conversation history display, and API support. |
| Technical & Usage Data | IP addresses, browser types, API call logs, system performance metrics, error reporting logs. | Infrastructure monitoring, security auditing, service optimization. |
| Integration Credentials | Business Solution Provider (BSP) tokens, System User access tokens, Meta App IDs. | Authenticating and routing API communication between Meta and Code Q. |
4. WhatsApp Business API & Meta Policy Compliance
Code Q Software Solutions Co. Ltd. operates in full compliance with the WhatsApp Business Terms, WhatsApp Business Policy, and Meta Developer Policies.
4.1 Opt-in & Consent Management
Code Q provides technical tools for client organizations to obtain explicit user consent. End-users must explicitly opt-in before receiving non-transactional messages via WhatsApp. Clients utilizing our platform are strictly required to adhere to standard opt-in requirements and maintain documented evidence of consent.
4.2 Message Content & Limitations
- Prohibited Content: Code Q does not permit the use of its WhatsApp integration to process, transmit, or store content prohibited by Meta’s policies, including illegal products, fraudulent schemes, or unauthorized promotional broadcasts.
- Message Payload: Actual message body content (text, media files) is processed to fulfill transmission services and cached temporarily. Code Q does not inspect or utilize private end-user message payload data for secondary commercial purposes or advertising targeting.
4.3 Data Sharing with Meta
To fulfill communication requests, necessary routing identifiers and encrypted message payloads are transmitted securely through Meta's Graph API and WhatsApp Cloud API infrastructures.
5. How We Use Your Information
We process personal data strictly for legitimate operational and business purposes, including:
- Provisioning, operating, and maintaining our software platform and WhatsApp Business integration services.
- Facilitating message transmission, template management, and automated responses.
- Monitoring infrastructure stability, security vulnerabilities, and system throughput.
- Providing technical support and resolving service disruptions.
- Fulfilling legal obligations, compliance standards, and enforceability of our Service Agreements.
6. Data Storage, Retention, and Security
6.1 Data Security Measures
We implement rigorous technical and organizational measures to safeguard personal data against unauthorized access, loss, or alteration:
- Encryption: End-to-end transport layer security (TLS 1.2/1.3) for all API communications; REST-level data encryption for stored platform information using AES-256 standards.
- Access Controls: Strict role-based access control (RBAC) and mandatory multi-factor authentication (MFA) for administrative and developer environments.
- Auditing: Continuous security logging and threat detection protocols.
6.2 Retention Schedule
- Transactional Logs & Metadata: Retained for up to 90 days to resolve operational disputes and ensure proper billing audit trails, after which they are automatically purged or anonymized.
- Account Records: Maintained for the active duration of the business contract plus statutory retention periods required by applicable corporate laws.
7. Data Sharing & Third-Party Vendors
We do not sell, rent, or trade personal data or customer databases. Information may be shared under the following limited conditions:
- Sub-processors & Service Providers: Trusted cloud infrastructure vendors (e.g., AWS, Google Cloud), database hosts, and system monitoring tools bound by strict Data Processing Agreements (DPAs).
- Meta Platforms, Inc.: Necessary payload delivery data sent via official API channels.
- Legal Requirements: When compelled by law, subpoena, or legal process to protect the rights, safety, or legal integrity of Code Q Software Solutions Co. Ltd.
8. End-User Rights & Data Control
Depending on your jurisdiction, you may hold specific privacy rights regarding your personal information:
- Access & Portability: Request a copy of personal data held by Code Q.
- Correction: Request updates to incomplete or inaccurate account details.
- Erasure ("Right to be Forgotten"): Request deletion of data where retention is no longer legally required.
- Opt-out: Users interacting via WhatsApp can opt-out at any time by replying STOP or following automated prompt instructions.
To submit a privacy inquiry or exercise your data rights, contact us using the details below.
9. International Data Transfers
Code Q Software Solutions Co. Ltd. operates globally. Personal data may be transferred to and processed in countries outside your local jurisdiction. When transferring data internationally, we implement Standard Contractual Clauses (SCCs) or ensure recipient data protection standards align with applicable international privacy frameworks.
10. Updates to This Privacy Policy
We reserve the right to modify this Privacy Policy to reflect changing legal requirements, technological advances, or updates to Meta’s Developer Policies. Material changes will be communicated via platform notifications, official website posts, or direct email to registered client contacts prior to taking effect.
11. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please reach out to our Data Protection Officer:
Code Q Software Solutions Co. Ltd.
Data Protection &
Compliance Office
Kahramana Square, Baghdad, Baghdad
Governorate, 10011
Email:
[email protected]
Phone:
+964 773 655 9996