Privacy Policy

Here Directive, a subsidiary of Lacto Food (FZE), (“Here Directive”, “we”, “us”, or “our”) is committed to protecting the privacy of individuals who visit our website and use the CHAT platform. This Privacy Policy explains what data we collect, how we use it, and your rights in relation to it. It applies to heredirective.com and all CHAT platform services.

This policy is governed by UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection. Where you or your customers are based in the European Union, GDPR principles also apply to the relevant processing activities.

1. Who We Are

Here Directive, a subsidiary of Lacto Food (FZE), is incorporated in the Sharjah Free Zone, United Arab Emirates. We operate the CHAT WhatsApp marketing platform, a white-label service built on the official WhatsApp Business API. Our registered website is heredirective.com.

2. Data We Collect

2.1 Website Visitors

When you visit our website, we may collect:

  • IP address and browser user agent (for spam detection and security).
  • Cookies for session management, login persistence, and display preferences.
  • Comment data if you submit comments on the site (retained indefinitely for moderation purposes).
  • Anonymised email hashes for Gravatar profile picture display where applicable.

2.2 CHAT Platform Users

When you register for and use the CHAT platform, we collect:

  • Account registration data: name, business name, email address, phone number, and billing information.
  • Usage data: platform activity, campaign data, message logs, automation flows, and feature usage.
  • Integration data: information exchanged between CHAT and your connected platforms (e.g., Shopify, HubSpot, WooCommerce).
  • Customer contact data: contact lists, opt-in records, and messaging history that you upload or generate through the platform.
  • Payment data: processed securely through Stripe; we do not store full card details.

3. How We Use Your Data

We use the data we collect to:

  • Provide, operate, and improve the CHAT platform and related services.
  • Process payments and manage your subscription.
  • Send transactional communications, including account updates, invoices, and service notifications.
  • Provide customer support and respond to enquiries.
  • Comply with legal obligations under UAE law and applicable international regulations.
  • Detect and prevent fraud, abuse, and security incidents.
  • Analyse platform usage to improve product performance and user experience.

We do not sell your personal data to third parties. We do not use your data for advertising purposes on behalf of third parties.

4. Cookies

We use cookies on our website and platform for the following purposes:

  • Session cookies: temporary cookies to maintain your login session, discarded when you close your browser.
  • Persistent cookies: login and display preference cookies lasting up to two years, where you select “Remember Me”.
  • Functional cookies: to remember your settings and improve your experience.
  • Analytics cookies: to understand how visitors use our site (anonymised data only).

You may opt out of non-essential cookies through your browser settings. Disabling cookies may affect the functionality of certain features.

5. Data Sharing and Third Parties

We share data with third parties only where necessary to deliver our services:

  • Meta Platforms, Inc.: CHAT operates on the official WhatsApp Business API. Messages sent through the platform are processed via Meta’s infrastructure and subject to Meta’s privacy policies.
  • Payment processors: Stripe processes all payment transactions. We do not store full card data.
  • Cloud infrastructure providers: We use third-party cloud hosting to operate the platform securely.
  • Integration partners: Where you connect third-party tools (e.g. Shopify, HubSpot), data is exchanged as required to enable those integrations.
  • Legal and regulatory authorities: We disclose data where required by applicable UAE law or valid legal process.

6. Your Responsibilities as a CHAT User

When using the CHAT platform to communicate with your customers, you are a data controller in your own right. You are responsible for:

  • Obtaining valid opt-in consent from all message recipients before sending any communications.
  • Maintaining accurate records of consent.
  • Ensure your privacy policy discloses your use of WhatsApp as a communication channel and any involvement of third-party platforms.
  • Complying with all applicable data protection and anti-spam laws in the jurisdictions where your customers are located.

7. Data Retention

We retain your account data for the duration of your subscription and for a reasonable period thereafter to comply with legal obligations. Upon termination, you have thirty (30) days to export your data. After this period, data may be permanently deleted.

Website comment data and associated metadata are retained indefinitely for moderation purposes. You may request deletion at any time, subject to any legal obligations to retain it.

8. International Data Transfers

As a global service, your data may be processed in countries outside the UAE. Where data is transferred internationally, we apply appropriate safeguards in line with UAE data protection law and, where applicable, GDPR transfer mechanisms. By using the Service, you consent to such transfers where necessary for service delivery.

9. Your Rights

You have the following rights in relation to your personal data:

  • Access: Request a copy of the personal data we hold about you.
  • Correction: Request correction of inaccurate or incomplete data.
  • Deletion: Request deletion of your personal data, subject to legal retention obligations.
  • Portability: Request an export of your data in a structured, machine-readable format.
  • Objection: Object to certain types of processing, including direct marketing.
  • Withdrawal of consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at privacy@heredirective.com. We will respond within thirty (30) days.

10. Embedded Content

Our website may include embedded content from third-party sources such as videos or articles. Embedded content behaves as if you had visited the originating website directly and may collect data, use cookies, and track interactions independently of Here Directive.

11. Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, or destruction. However, no method of transmission over the internet is completely secure. You are responsible for maintaining the security of your account credentials.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or a prominent notice on our website. Continued use of the Service after changes are posted constitutes acceptance of the updated policy.

13. Contact

For any privacy-related enquiries, requests, or complaints:

Here Directive
c/o Lacto Food (FZE)
P.O. Box 120790, SAIF Zone, Sharjah, UAE
privacy@heredirective.com
www.heredirective.com