Privacy Policy
Last updated: 2026-07-21
⚠️ This policy is currently being drafted and reviewed by legal counsel. It will be published here once approved. For questions, contact legal@shinygt360.com.
1Introduction
Shiny GT 360 (hereinafter referred to as “Platform,” “Website,” “Mobile Application,” “Shiny GT 360”) is a website and mobile-based WhatsApp Business API CRM platform owned and operated by Shiny Global Technologies (hereinafter referred to as “Shiny GT 360,” “we,” “us,” or “our”). This Privacy Policy (“Policy”) helps users accessing the Website/App (“User”/“You”/“Your”) and the Service therein understand the type of information we collect, the purpose for which it’s collected, how it’s used, who it’s shared with, and how it’s protected. We take protection of your information seriously. Please read this Policy carefully before accessing our Website/App, using our Services, or creating an Account. If you do not agree to this Policy, please do not access our Website/App, use our Services, or create an Account. [Insert applicable law reference here — e.g. India’s DPDPA 2023, UAE’s Federal Decree-Law No. 45 of 2021 on Personal Data Protection, EU GDPR — depending on where you’re legally registered and who you serve. The reference document used India-specific law; confirm before reusing that language.]
2Definitions
• Service: shinygt360.com website and the Shiny GT 360 mobile application, operated by [Shiny Global Technologies]. • Personal Data: Data about a living individual who can be identified from that data, alone or combined with other information. • Usage Data: Data collected automatically, generated by use of the Service or the Service infrastructure itself. • Cookies: Small files stored on your device. • Data Controller: The entity that determines the purposes and means of processing personal data. For this Policy, Shiny GT 360 is the Data Controller. • Data Processors (Service Providers): Third parties who process data on our behalf. • Data Subject (User): The individual using our Service.
3Information We Collect
Personal Data. This may include: • Email address • First and last name • Phone number associated with WhatsApp • Address, State, Province, ZIP/Postal code, City • Cookies and Usage Data • Social media login credentials • Any other identifiers considered sensitive/personal under applicable data protection law We may use your Personal Data to contact you by phone, SMS, email, or WhatsApp with newsletters, marketing, or promotional materials. You may opt out of any of these communications by following the unsubscribe link or instructions in any message we send. Usage Data. Information your browser or device sends automatically when you use the Service — IP address, browser type and version, pages visited, time and date of visit, time spent on pages, device identifiers, and diagnostic data. Behavioral Data. Information connected with your activity on the Website/App across devices, using your email or social login, plus the Services you search for and your communication preferences. Location Data. If you grant permission, we may collect and use location data to provide and improve Service features. You can disable this anytime in your device settings. Contact List & Files. Shiny GT 360 lets you upload your existing contact list (name, phone number, email, and other fields) to initiate WhatsApp conversations. We also process audio, video, PDF, and other rich media files you choose to share with your customers through the platform. Tracking & Cookies Data. See the standalone Cookies Policy below for full detail. Device Data. Operating system, hardware/software versions, battery status, signal availability, storage space, browser type, app names, device activity, unique identifiers, and (where permitted) Bluetooth/WiFi/cell tower proximity data, used to support Service delivery across your devices. Third-Party Information. If you link a third-party account (Facebook, Google, Instagram, etc.), we may receive information about your use of that service as part of the integration.
4How We Use Your Data
• To provide, maintain, and improve the Service • To notify you of changes to the Service • To provide customer support • To monitor Service usage and detect/prevent technical issues • To send you news, offers, and information about services similar to those you’ve used or inquired about, unless you’ve opted out
5Legal Basis for Processing
[Placeholder — select the applicable framework(s) based on your registered jurisdiction and customer base, and remove the others:] If you are in the European Economic Area (EEA), our legal basis for processing depends on the data and context, and may include: performance of a contract with you, your consent, our legitimate interests (where not overridden by your rights), payment processing needs, or legal compliance. If you are in the UAE, processing is conducted in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. [Confirm specific consent and legitimate-interest requirements with legal counsel — UAE PDPL has its own consent and cross-border transfer rules distinct from GDPR.]
6Data Retention
We retain your Personal Data only as long as necessary for the purposes in this Policy, or as required to comply with legal obligations, resolve disputes, and enforce our agreements. Usage Data is generally retained for a shorter period unless needed for security, functionality improvements, or legal compliance.
7Transfer of Data
Your data, including Personal Data, may be transferred to and processed in a country other than your own, where data protection laws may differ. [Insert your actual data hosting location(s) here — e.g., “we host data in [United States of America]” — this needs to be accurate, not a placeholder copied from another company’s servers.] By using the Service, you consent to this transfer. We take reasonable steps to ensure adequate security controls are in place for any such transfer.
8Disclosure of Data
We may disclose your Personal Data: • In connection with a merger, acquisition, or asset sale • When required by law or in response to valid requests by public authorities • To comply with a legal obligation, protect our rights or property, investigate wrongdoing, protect user or public safety, or defend against legal liability
9Security of Data
We use commercially reasonable means to protect your Personal Data, but no method of transmission or storage over the internet is 100% secure, and we cannot guarantee absolute security.
10Your Data Protection Rights
Depending on your jurisdiction, you may have the right to: • Access, update, or delete the Personal Data we hold about you • Rectify inaccurate or incomplete information • Object to our processing of your data • Restrict processing • Receive your data in a portable, machine-readable format • Withdraw consent at any time where we relied on it We may ask you to verify your identity before acting on these requests. Contact us at info@shinygt360.com to exercise any of these rights.
11Service Providers We Use
We may use third-party providers to operate, analyze, or improve the Service. These providers only access Personal Data to perform their assigned tasks and are contractually barred from using it for other purposes. [List your actual providers here — e.g. Google Analytics, Firebase, Mixpanel, Stripe, Meta/Facebook remarketing, whichever you genuinely use. Don’t leave the reference document’s provider list in — it names Shiny GT 360 vendors, not yours.]
12Payments
We do not store your payment card details directly. Payment processing is handled by third-party processors Stripe (s) , whose own privacy policies govern that data.
13Refund Policy Reference
See the standalone Refund Policy (part of your Pricing page FAQ) for details on our no-refund terms for partial billing periods.
14Children’s Privacy
Our Service is not directed at anyone under 18. We do not knowingly collect Personal Data from anyone under 18. If you believe a child has provided us with Personal Data, contact us at info@shinygt360.com and we will take steps to remove it.
15Changes to This Policy
We may update this Policy from time to time. We’ll notify you via email and/or a notice on the Service before changes take effect, and update the “Last updated” date above.
16Contact Us
Questions about this Policy: info@shinygt360.com
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