Privacy Policy

1. Introduction

This Privacy Policy explains how NeeNam Solutions Pvt Ltd (“NeeNam”, “we”, “us”, or “our”), the owner and operator of the MSGMEE product, collects, uses, discloses, and protects personal data when you use our websites, tenant portals, administrator portals, APIs, and related multi-channel messaging services — including WhatsApp, email, SMS, and other channels we enable (together, the “Services”).

By accessing or using the Services, you acknowledge this Policy. If you do not agree, do not use the Services. Capitalised terms not defined here have the meaning given in our Terms & Conditions.

2. Roles, channels, Meta, and partners

MSGMEE provides multi-channel messaging infrastructure. Depending on configuration, the Services may interoperate with:

• Meta Platforms, Inc. and its affiliates (“Meta”), including the WhatsApp Business Platform / Cloud API and related Meta Business tools
• Channel partners, including WhatsApp Business Solution Providers (“BSP”) and other partners for onboarding, template submission, and message delivery where configured
• Email and SMS providers (and other channel or gateway partners) used to transmit mail, SMS, or additional messaging channels enabled for a tenant

Use of WhatsApp is also subject to Meta’s and WhatsApp’s own terms and privacy policies (including the WhatsApp Business Terms and WhatsApp Business Messaging Policy). Our partners’ services are subject to their own terms and privacy notices. Email, SMS, and other channel partners likewise have their own terms and privacy notices. We encourage you to review those documents. MSGMEE does not control Meta’s or our partners’ independent processing.

3. Categories of personal data we process

Depending on how you interact with MSGMEE, we may process:

3.1 Account & organisation data

• Name, work email, organisation / tenant name and slug
• Role, authentication credentials (password hashes / tokens), and access logs
• Billing contacts, credit balances, rate cards, and invoices
• Application registration details (client IDs, contact emails, scopes)

3.2 Channel & account configuration data

• WhatsApp Business Account (WABA) identifiers and linked phone numbers
• Business display name, category, and onboarding / verification status
• Business contact details submitted during Meta or partner onboarding
• Email sending domains, addresses, and mail configuration metadata
• SMS sender IDs, routes, and related telecom configuration metadata
• Template names, content, languages, variables/examples, and approval status

3.3 Messaging data (all channels)

• Recipient identifiers — phone numbers (E.164), email addresses, and other channel addresses you instruct us to use
• Outbound message content, subjects, template parameters, and attachments you instruct us to send
• Delivery, read, bounce, failure, and other channel status events (webhooks)
• Message identifiers, channel type, timestamps, categories, and credit consumption records

3.4 Technical & security data

• IP addresses, device / browser metadata, request IDs, and API usage telemetry
• Error logs, fraud/abuse signals, and security event data

We do not require special categories of personal data (e.g. health, biometric, or precise location) to operate the platform. Customers must not submit such data unless they have a lawful basis and have configured appropriate safeguards, and applicable channel policies (including Meta/WhatsApp where relevant) permit it.

4. How we collect data

• Directly from you — registration, portal use, support requests, and contractual onboarding.
• From customer systems — via APIs, OAuth client-credentials flows, and webhooks you configure.
• From channel partners — Meta, WhatsApp partners, and email/SMS or other providers may return onboarding status, template review outcomes, delivery, bounce, and related events.
• Automatically — server logs, authentication events, and website analytics strictly necessary for security and performance (see Cookies).

5. How we use personal data

We use personal data to:

• Provide, operate, maintain, and improve the Services
• Authenticate users and applications; enforce scopes and tenancy isolation
• Onboard and operate channels (WhatsApp, email, SMS, and others); submit and sync templates; send messages as instructed by customers
• Calculate credits / fees, prevent abuse, and manage accounts
• Deliver webhook notifications to customer endpoints you configure
• Comply with law, respond to lawful requests, and enforce our Terms
• Protect the security and integrity of MSGMEE, channel partners, customers, and end users
• Communicate service notices, incident updates, and material policy changes

We do not sell personal data.

6. Legal bases (where applicable)

If you are in a jurisdiction that requires a “legal basis” (for example under the EU GDPR / UK GDPR), we rely on one or more of the following:

• Contract — to provide the Services you or your organisation requested
• Legitimate interests — platform security, fraud prevention, product improvement, and business operations, balanced against your rights
• Legal obligation — tax, accounting, and regulatory requirements
• Consent — where required (for example certain marketing, or where customers must obtain end-user opt-in for WhatsApp, SMS, email, or other messaging)

For end-user messaging on any channel, customers are responsible for obtaining and documenting any required opt-in / consent under WhatsApp Business policies, telecom and anti-spam rules, email marketing laws, and other applicable law before instructing MSGMEE to send messages.

7. Sharing, processors, and subprocessors

We may share personal data with:

• Meta / WhatsApp — to the extent necessary to create or manage WhatsApp Business assets, submit templates for review, and send or receive messaging events on the WhatsApp channel
• Channel partners — including BSPs and messaging partners for onboarding, template workflows, delivery, and related channel operations
• Email, SMS, and other channel providers — to transmit messages and receive delivery / bounce / status events for those channels
• Infrastructure providers — hosting, databases, monitoring, and security vendors under appropriate contracts
• Professional advisors — legal, audit, and compliance advisers under confidentiality obligations
• Authorities — when required by law or to protect rights, safety, and security
• Corporate transactions — in connection with a merger, acquisition, or asset sale, subject to continued protection of personal data

Customers’ integrator applications may receive message status and related payloads via webhooks or APIs that the customer configures. Customers are responsible for securing those endpoints and for their own privacy notices to end users.

8. Channel-specific privacy practices

8.1 All channels

• MSGMEE processes messaging data to fulfil customer instructions and channel requirements. Message content and recipient data may be visible to the relevant channel partner as part of delivery and policy enforcement.
• Customers must honour user opt-outs, unsubscribe, stop / block, and DND mechanisms applicable to each channel, and must not message users without a valid opt-in or other lawful basis where required.
• MSGMEE may suspend or restrict messaging that appears to violate partner policies or applicable law, and may retain limited records for abuse investigation.

8.2 WhatsApp (Meta / partners)

• Template content and sample values submitted for Meta review must comply with WhatsApp Business Messaging Policy and must not include prohibited or sensitive content.
• Message content may be processed by Meta/WhatsApp and our partners for delivery and policy enforcement.

8.3 Email & SMS

• Email may involve processing of email addresses, subjects, bodies, headers, and bounce/complaint events via mail providers.
• SMS may involve processing of phone numbers, message bodies, sender IDs, and delivery reports via SMS gateways or telecom partners.
• Customers are responsible for complying with applicable anti-spam, TRAI/DND (or equivalent), CAN-SPAM, and similar rules in each jurisdiction.

9. International data transfers

Personal data may be processed in India and in other countries where we, Meta, our partners, email/SMS providers, or our infrastructure providers operate. Where required, we use appropriate safeguards (such as contractual clauses or equivalent measures) for cross-border transfers. Channel partners may transfer data according to their own transfer mechanisms.

10. Retention

We retain personal data only as long as needed for the purposes described in this Policy, including:

• Account and billing records for the life of the customer relationship plus a reasonable period for disputes, audits, and legal retention
• Message and delivery logs for operational troubleshooting, credit accounting, abuse prevention, and compliance
• Security logs for a limited period consistent with industry practice

When data is no longer required, we delete or anonymise it, unless longer retention is required by law. Customers may request deletion subject to technical constraints of channel partners and legal holds.

11. Security

We implement administrative, technical, and organisational measures designed to protect personal data, including access controls, encrypted transport (TLS), hashed secrets where applicable, tenancy isolation in APIs, and monitoring. No method of transmission or storage is completely secure; customers must protect their credentials, tokens, and webhook endpoints.

12. Your rights

Subject to applicable law, you may have rights to access, correct, delete, restrict, or object to certain processing, and to data portability. You may also withdraw consent where processing is consent-based.

End users of messages (WhatsApp, email, SMS, or other): please contact the business that messaged you first; MSGMEE typically processes that data as their service provider. We will assist customers with verifiable requests as required by contract and law.

To exercise rights related to MSGMEE accounts, email don.caleb@neenam.com. We may need to verify your identity. You may lodge a complaint with a supervisory authority where available.

13. Children

The Services are intended for businesses and adult organisational users. MSGMEE is not directed to children under 16 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal data from children. If you believe a child has provided personal data, contact us and we will take appropriate steps.

14. Cookies and similar technologies

Our marketing website may use strictly necessary cookies for security and basic functionality. Portals may use session / authentication cookies required to keep you signed in. We do not use third-party advertising cookies on the public MSGMEE site described here. If we introduce analytics cookies, we will update this Policy and provide choices where required.

15. Changes to this Policy

We may update this Privacy Policy from time to time. We will post the revised version with an updated “Last updated” date and, for material changes, provide additional notice (for example by email or in-product notice) where appropriate. Continued use of the Services after the effective date constitutes acceptance of the updated Policy, except where applicable law requires otherwise.

16. Contact

For privacy questions, requests, or complaints:

• Company: NeeNam Solutions Pvt Ltd
• Email: don.caleb@neenam.com
• Product: MSGMEE