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META APP REVIEW & WHATSAPP CLOUD API COMPLIANT

PRIVACY POLICY

Official Privacy Compliance Documentation for VIRTU SOL IT ENABLED SERVICES PRIVATE LIMITED ("VirtuSol", "Aarika AI"). This policy outlines our data collection, processing, security, and deletion protocols in full compliance with Meta Platform Terms, WhatsApp Business API guidelines, and applicable data protection regulations.

EFFECTIVE DATE: September 23, 2026•VERSION: 5.0 (SOVEREIGN)•LEGAL ENTITY: VIRTU SOL IT ENABLED SERVICES PVT LTD

1. Legal Entity & Scope

This Privacy Policy applies to all websites, web applications, APIs, WhatsApp Cloud API integrations, and autonomous AI services operated by:

Corporate Name: VIRTU SOL IT ENABLED SERVICES PRIVATE LIMITED
Brand & Products: VirtuSol / Aarika AI / Sovereign AI Engine
Registered Address: PLOT NO. 9/2, SURVEY NO 64, ISIS BUILDING, 1ST FLOOR, HUDA TECHNO ENCLAVE, PHASE-2, HYDERABAD, TELANGANA 500081, INDIA
Contact Email: kevin@virtusol.com / privacy@virtusol.com

VirtuSol acts as a Data Processor when handling customer communications on behalf of our B2B clients, and as a Data Controller for direct communications submitted to VirtuSol.

2. Data We Collect (Meta & WhatsApp Webhooks)

To deliver real-time automated AI responses, appointment scheduling, and CRM synchronization via Meta's WhatsApp Cloud API and web services, we collect and process the following categories of data:

  • WhatsApp Identifiers & Profile Data: WhatsApp Phone Number (WAID), Profile Display Name, and associated phone country code.
  • Message Transcripts & Media: Text message bodies, voice note audio files, button interactive responses, and image/document attachments sent by users to configured WhatsApp business lines.
  • Appointment & Transaction Data: Booking parameters, preferred dates/times, service selections, and clinic/business intake questionnaire responses.
  • Technical Metadata & Webhook Signatures: HTTP headers, IP addresses, timestamp markers, and HMAC-SHA256 signature tokens transmitted during Meta Webhook events.

3. Purpose of Processing

We collect and process personal data exclusively for specified, legitimate operational purposes:

Automated AI Response
Executing real-time conversations via Aarika AI to answer customer inquiries.
Appointment Booking
Scheduling appointments and sending confirmation reminders on WhatsApp.
CRM Synchronization
Injecting qualified lead signals directly into the client's authorized CRM system.
Security & Integrity
Verifying Meta Webhook signatures (HMAC-SHA256) to prevent unauthorized spoofing.

4. Third-Party Data Sharing & Infrastructure

We strictly limit data sharing to essential infrastructure providers required to operate the service:

  • Meta Platforms, Inc. (WhatsApp Cloud API): Used as the official message transport and webhook delivery network under Meta’s Developer & Cloud API Terms.
  • Hetzner Online GmbH (Cloud VPS Hosting): Primary sovereign server infrastructure located in secure European data centers (Helsinki / Falkenstein).
STRICT NO-SELL GUARANTEE:VIRTU SOL IT ENABLED SERVICES PRIVATE LIMITED does NOT sell, rent, trade, or monetize personal data or WhatsApp chat transcripts to third-party data brokers, marketers, or advertisers under any circumstances.
META DEVELOPER REQUIREMENT: DATA DELETION INSTRUCTIONS

5. User Rights & Data Deletion Instructions

Pursuant to Meta Platform Rules, GDPR, and global data privacy standards, end-users and business clients have the right to request the complete deletion of their personal data, WhatsApp conversation transcripts, and associated records.

How to Request Immediate Data Deletion:

1
METHOD 1: Email Request (Recommended)Send an email to privacy@virtusol.com or kevin@virtusol.com with the subject line DATA DELETION REQUEST. Include your WhatsApp Phone Number (with country code).
2
METHOD 2: WhatsApp Keyword TriggerSend a WhatsApp message containing the text DELETE MY DATA or REMOVE MY DATA directly to the connected VirtuSol business number.
• Execution SLA: All valid deletion requests are processed and purged within 48 hours of receipt.
• Confirmation: A formal confirmation receipt will be issued via email or WhatsApp once records are removed from active databases and cache stores.

6. Data Security & Technical Measures

VirtuSol enforces industry-standard administrative, physical, and technical safeguards to protect data:

  • Encryption in Transit: Mandatory HTTPS SSL/TLS (TLS 1.3) protocol across all endpoint connections.
  • Meta Webhook HMAC Verification: Every incoming payload is validated against Meta's app secret using HMAC-SHA256 signatures before processing.
  • Tenant Isolation: Data for each business client is isolated within dedicated database schema spaces.
  • Access Restrictions: Access to production infrastructure is restricted to authorized engineers via SSH key authentication.

7. Data Retention Policy

We retain personal data only for as long as necessary to fulfill operational service agreements or legal requirements:

  • Transient Message Logs: Transcripts are stored for active session continuity and purged within 30 days unless extended retention is explicitly mandated by the business client.
  • CRM Records: Exported to the client’s designated CRM according to their account rules.

8. Governing Law & Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the State of Telangana, India, without regard to conflict of law principles. Any disputes shall be subject to the exclusive jurisdiction of the courts located in Hyderabad, Telangana, India.

9. Contact Information & Data Protection Officer

For privacy inquiries, regulatory notices, or data deletion requests, please contact our team:

Legal Entity: VIRTU SOL IT ENABLED SERVICES PRIVATE LIMITED
Attn: Data Protection Officer / Privacy Lead
Privacy Email: privacy@virtusol.com
Executive Email: kevin@virtusol.com
Registered Office Address: PLOT NO. 9/2, SURVEY NO 64, ISIS BUILDING, 1ST FLOOR, HUDA TECHNO ENCLAVE, PHASE-2, HYDERABAD, TELANGANA 500081, INDIA