Privacy Policy

1. Introduction

Thank you for using Cami. Your trust matters to us, and we are committed to protecting the privacy and security of your personal data.

This Policy applies to you if:

• you visit or browse our website or interfaces;
• you are a customer or end user who books services, buys products, communicates, or pays through Cami (we refer to you as a “Customer”);
• you are a business that uses Cami to run your operations, customers, bookings, or sales (we refer to you, or the business, as a “Merchant”).

This Privacy Policy explains how we collect, use, process, and disclose your personal data when you access or use the Cami platform, including our WhatsApp-based services, web interfaces, and any related tools (together, the “Platform” or “Services”).

In this Policy, “Cami,” “we,” “us,” or “our” refers to Cami Technologies Limited, a company registered in the Dubai International Financial Centre (DIFC), with its registered office at OT 09-35, Level 9, Central Park Offices, Dubai International Financial Centre, Dubai, United Arab Emirates. Cami Technologies Limited is the data controller responsible for your personal data under this Policy, except where stated otherwise (for example, in respect of payments or data controlled by a merchant).

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1.1 Who this Policy covers

Cami is a WhatsApp-first platform that helps businesses serve their customers. It connects two main types of users:

• Merchants – businesses that use Cami to manage their operations, customers, bookings, and sales.
• Customers – people who interact with a Merchant through Cami, including via WhatsApp, to book services, buy products, communicate, or make payments.

This Policy applies to both Merchants and Customers. Where a section applies only to one group, we say so.

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1.2 Merchant and Customer data (controller and processor roles)

For most data we collect to operate the Platform (account details, usage data, communications, payments), Cami acts as the data controller.

When a Merchant uploads, imports, or otherwise provides data about their own customers into Cami (for example, a customer contact list during onboarding), the Merchant is the controller of that data and Cami processes it on the Merchant’s behalf as a processor, in accordance with our agreement with that Merchant. Merchants are responsible for ensuring they have a lawful basis and any required consent to share that data with us. If you are a Customer and have questions about how a specific Merchant uses your data, please contact that Merchant directly.

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1.3 Applicability to payments

This Policy also applies to payment-related services made available through the Platform (the “Payment Services”). To process payments, we work with third-party payment providers, currently Stripe, NeoPay, and Network International (each, a “Payment Provider”), or such other providers as we may use from time to time.

When you make or receive a payment through the Platform, you may be providing your information, including payment information, directly to the relevant Payment Provider, who acts as a separate controller of that information for the purposes of processing the transaction. We do not see or store your full card or bank details; only our Payment Providers do. Please review each Payment Provider’s own privacy policy for details on how they handle your data.

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1.4 Definitions

Capitalized terms not defined in this Policy have the meaning given to them in our Terms of Service.

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2. Information We Collect

We collect information in three general ways: information you give us, information we collect automatically, and information we receive from third parties.

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2.1 Information you give us

Information necessary to use the Platform. We collect the following so we can provide the Services and meet our legal obligations. Without it, we may not be able to provide all features.

• Account information. When you sign up, we collect details such as your name, email address, and WhatsApp or mobile phone number.
• Merchant business information. If you are a Merchant, we collect information about your business, such as business name, address, contact details, services offered, pricing, staff or operating details, and other information needed to set up and run your account.
• Customer information. To enable bookings, purchases, and communication, we may collect information about Customers, such as contact details and service- or order-related notes provided by you or the Merchant.
• Communications. When you communicate with Cami, or use the Platform to communicate with a Merchant or Customer (including over WhatsApp), we collect the content of those communications and any information you choose to share.
• Payment information. To use the Payment Services, you provide certain financial information to the relevant Payment Provider in order to process payments. See Section 1.3.
• Information you choose to provide. You may volunteer additional information, such as when you complete a form, respond to a survey, or contact our support team.

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2.2 Information about the WhatsApp channel

Cami is WhatsApp-first. When you interact with the Platform through WhatsApp, message content, your WhatsApp phone number, and related metadata are processed so we can deliver the Services. These messages are also subject to WhatsApp’s and Meta’s own terms and privacy practices, which we do not control.

We deliver these messages using the WhatsApp Business Platform provided by Meta. When you message a Merchant through Cami on WhatsApp, your phone number, message content, and related metadata are processed by Meta to deliver the messages, in accordance with Meta’s and WhatsApp’s own terms and privacy policies, which we do not control. We use this information only to operate the Cami Services, such as enabling bookings, support, and communication between you and a Merchant. We encourage you to review WhatsApp’s and Meta’s privacy policies for details on how they handle your data.

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2.3 Information we collect automatically

When you use the Platform, we automatically collect certain information about how you use it. This supports the performance of our agreement with you and our legitimate interest in operating and improving the Services.

• Usage information. How you interact with the Platform, such as the features you use, bookings made, and actions taken.
• Log and device information. Information such as IP address, access dates and times, device and software details, unique identifiers, and crash data.
• Cookies and similar technologies. Where you use our web interfaces, we may use cookies and similar technologies to operate, secure, and improve the Platform and to understand usage. You can control non-essential cookies through your browser settings or any cookie controls we provide.

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2.4 Information from third parties

We may receive information about you from third parties and combine it with information we hold.

• From Merchants. Merchants may provide us with information about their customers, including contact and service or order information (see Section 1.2).
• From service providers. We may receive information from our Payment Providers, our WhatsApp provider, and other service providers, for example to confirm a payment, prevent fraud, or assess risk.

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2.5 Sensitive information and consultation forms

Depending on their business, Merchants may ask Customers, including through consultation, intake, or order forms made available on the Platform, to provide additional information. In some cases this may include sensitive or special category data under applicable law (for example, health-related details or other personal circumstances relevant to the service). The Merchant decides what to ask for and is the controller of that information. Cami processes it on the Merchant’s behalf to deliver the Services and does not use it for its own purposes. Merchants are responsible for collecting any consent required for sensitive information.

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2.6 Children’s data

The Platform is not directed to children under 18, and we do not knowingly collect personal data directly from them. If you believe we have collected information from a child, please contact us at support@getcami.io and we will take appropriate steps.

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3. How We Use Information

We use personal data to operate and improve the Platform, to keep it safe and trusted, and to communicate with you. Depending on the activity, we rely on one or more of the following legal bases: performance of our contract with you, our legitimate interests, compliance with legal obligations, or your consent.

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3.1 To provide and improve the Platform

• Enable you to access, set up, and use your account and the Services.
• Enable communication between Merchants and Customers, including over WhatsApp.
• Facilitate bookings, scheduling, and related operations for Merchants.
• Provide customer support and send service messages, updates, and security alerts.
• Operate, secure, improve, and develop the Platform, including through analytics and research.

Legal basis: performance of our contract with you | our legitimate interests in operating and improving the Services

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3.2 To keep the Platform safe and trusted

• Detect, prevent, and investigate fraud, abuse, spam, and security incidents.
• Verify information and conduct risk assessments, on our own or with third parties.
• Enforce our Terms of Service and other policies, and comply with our legal obligations.
• Resolve disputes and establish, exercise, or defend legal claims.

Legal basis: our legitimate interests in keeping the Platform secure | compliance with our legal obligations

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3.3 To communicate with you

With your consent where required, we may send you updates, offers, and other information about Cami that may be relevant to you. You can opt out of marketing communications at any time using the unsubscribe option in our messages or by changing your settings. Even if you opt out, we may still send you important service or transactional messages about your account.

Legal basis: consent | our legitimate interests in promoting the Services

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3.4 To process payments

We and our Payment Providers use payment-related information to enable and complete transactions, prevent fraud, and comply with applicable law, including anti-money-laundering requirements. See Sections 1.3 and 4.

Legal basis: performance of our contract with you | compliance with our legal obligations

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4. Sharing and Disclosure

We share personal data only as described in this Policy.

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4.1 Between Merchants and Customers

To enable bookings and communication, certain information is shared between a Merchant and the relevant Customer. For example, when a Customer books or contacts a Merchant, the Merchant receives the information needed to fulfil the request, and the Customer receives the information needed to interact with the Merchant.

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4.2 Payment Providers

We share payment-related information with our Payment Providers (Stripe, NeoPay, and Network International, or others we may use) as needed to process transactions and comply with applicable law. Each Payment Provider handles your data under its own privacy policy.

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4.3 Service providers

We use third-party service providers to help us operate the Platform, such as hosting, WhatsApp messaging, analytics, fraud prevention, and customer support. These providers may access personal data only to perform tasks on our behalf and are required to protect it and use it only as we instruct.

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4.4 Legal and safety

We may disclose personal data to courts, regulators, law enforcement, or other authorities, or to other third parties, where we reasonably believe it is required or permitted by law, or necessary to comply with a legal obligation, respond to a valid legal request, enforce our agreements, or protect the rights, property, or safety of Cami, our users, or the public.

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4.5 Corporate transactions

If Cami is involved in a merger, acquisition, reorganization, sale of assets, or similar transaction, your information may be transferred as part of that transaction. We will take reasonable steps to ensure your information remains protected.

4.6 Aggregated and anonymized data

We may share aggregated or anonymized information that does not identify you for analysis, research, and other business purposes.

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5. Analyzing Communications

We may review, scan, or analyze communications on the Platform for purposes such as fraud prevention, safety, regulatory compliance, support, and improving our Services. We use automated methods where possible, and limited manual review where necessary (for example, in fraud investigations or support). We do not sell these communications or use them to send you third-party marketing.

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6. International Data Transfers

Cami operates in the UAE and the wider GCC region and works with service providers that may be located in other countries. As a result, your personal data may be transferred to, stored in, or processed in countries other than your own, whose data protection laws may differ from those where you are located.

Where we transfer personal data outside the DIFC, we take steps to ensure an appropriate level of protection in line with applicable data protection law, including the DIFC Data Protection Law (DIFC Law No. 5 of 2020) and any other laws that apply to you. You can request more information about these safeguards by contacting us at support@getcami.io.

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7. Your Rights

Subject to applicable law, including the DIFC Data Protection Law, you may have the following rights in relation to your personal data:

• Access. Request a copy of the personal data we hold about you.
• Correction. Ask us to correct inaccurate or incomplete data.
• Erasure. Ask us to delete your personal data in certain circumstances.
• Restriction and objection. Ask us to restrict, or object to, certain processing, including processing based on legitimate interests and direct marketing.
• Portability. Request certain data in a structured, commonly used, machine-readable format.
• Withdraw consent. Where we rely on consent, withdraw it at any time, without affecting processing already carried out.
• Complaints. Lodge a complaint with us or, where applicable, with the relevant data protection authority (for DIFC, the Commissioner of Data Protection).

To exercise any of these rights, contact us at support@getcami.io. We may need to verify your identity before acting on your request. If your request concerns data that a Merchant controls (see Section 1.2), we may direct you to that Merchant.

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7.1 Data retention

We keep your personal data for as long as needed to provide the Services and to meet our legal, accounting, and reporting obligations, or to establish, exercise, or defend legal claims. When data is no longer needed, we delete or anonymize it. Some residual copies may remain in backups for a limited period.

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8. Security

We implement administrative, technical, and physical measures designed to protect your personal data against unauthorized access, loss, or alteration, such as encryption and access controls. No system is completely secure. If you believe your account has been compromised, please contact us immediately at support@getcami.io.

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9. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will post the updated Policy on the Platform and update the “Last Updated” date above, and where appropriate we will notify you in advance. Your continued use of the Platform after the changes take effect means you accept the updated Policy.

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10. Contact Us

If you have questions or complaints about this Policy or how we handle your data, please contact us:

Cami Technologies Limited

OT 09-35, Level 9, Central Park Offices, Dubai International Financial Centre, Dubai, United Arab Emirates

Email: support@getcami.io

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