Privacy Policy

Kula, operated by Fluora Inc., provides a software platform that helps businesses organize, manage, and respond to WhatsApp conversations and related business communications. This Privacy Policy explains how we collect, use, store, and protect personal data when you use our website, applications, and services (collectively, the "Services").

1. Roles and Responsibilities

When you connect your WhatsApp Business account to Kula, you are the data controller of any personal data contained in your messages and communications. Kula acts as a data processor, processing such data solely on your behalf and in accordance with your instructions to provide the Services.

We do not own the content of WhatsApp messages processed through Kula.

2. Information We Collect

We collect the following categories of information:

a. Account and Business Information

• Name, email address, and contact details
• Business name and business profile information
• WhatsApp Business Account identifiers
• Message templates associated with your WhatsApp Business account

b. Message Content and Metadata

When you connect a WhatsApp Business account, we may process and store:

• Message content sent or received through WhatsApp
• Message metadata (such as timestamps, sender and recipient identifiers, delivery status)

This information is processed solely to enable core functionality such as message display, categorization, drafting responses, analytics, and workflow support.

c. Usage and Technical Data

• IP address, device type, browser type
• Log files and usage metrics
• Interaction data related to use of the Services

d. Billing Information

If applicable, billing and payment information is processed by third-party payment providers. Kula does not store full payment card details.

3. How We Use Information

We use the information described above solely to:

• Provide, operate, and maintain the Services
• Enable businesses to view, organize, and respond to WhatsApp conversations
• Generate draft responses and productivity features at the direction of the user
• Provide customer support
• Improve reliability, security, and performance of the Services
• Comply with legal and regulatory obligations

We do not use WhatsApp message content for advertising, marketing, or training generalized AI models.

4. Message Retention and Deletion

a. Retention During Active Use

WhatsApp message content and metadata are retained only while a customer's WhatsApp Business account remains actively connected to Kula, and only for as long as necessary to provide the Services.

b. Deletion After Disconnection or Termination

Message data is deleted:

• When a customer disconnects their WhatsApp Business account from Kula
• When a customer terminates their Kula account
• Upon a valid deletion request from the customer

Deletion may occur immediately or within a reasonable period (typically up to 90 days) to allow for system backups, auditing, or legal compliance.

c. Legal Obligations

We may retain limited information if required to comply with applicable laws, resolve disputes, or enforce our agreements.

5. Data Sharing

We do not sell or rent personal data.

We may share data only:

• With service providers acting on our behalf (such as hosting and infrastructure providers), under strict confidentiality obligations
• With Meta Platforms, Inc. and WhatsApp, as necessary to deliver WhatsApp Business Platform functionality
• If required by law, regulation, or valid legal process

6. Security

We implement appropriate technical and organizational measures to protect data, including:

• Encryption in transit and at rest
• Access controls and authentication mechanisms
• Regular monitoring and security reviews

No system is completely secure, but we take reasonable steps to protect information from unauthorized access or disclosure.

7. International Data Transfers

Your data may be processed and stored in countries other than your own. Where required, we rely on appropriate safeguards to protect personal data in accordance with applicable data protection laws.

8. Your Rights

Depending on your location, you may have rights to:

• Access, correct, or delete personal data
• Restrict or object to certain processing
• Request data portability

Requests can be made by contacting us at the email address below.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Last updated" date.

10. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

Legal Company Name: FLUORA INC.
Address: 1875 Mission St; Ste 103 #440; San Francisco, CA 94103
Email: support@joinrio.app