ETW CRM Privacy Policy

Last updated: October 6, 2026

This policy explains what data ETW (a service of GREIG MOISES, Argentine tax ID (CUIT) 20-44329999-9, located at MEJICO 378, X5000 CORDOBA, CORDOBA, Argentina) processes, what it uses it for, who it shares it with, and how to ask for its deletion.

1. What ETW is and our role

ETW is a CRM that lets businesses serve their customers over WhatsApp and over their website's chat. The business connects its own WhatsApp Business account through Meta (WhatsApp Business Platform, using Meta's Embedded Signup) and, from ETW, sees and answers its conversations in an inbox shared with its team.

Each business can turn on an AI customer service assistant. That assistant only answers about the information the business itself provides (its products, opening hours, frequently asked questions and documents) and follows the rules the business sets up. It is not a general-purpose assistant. It can always hand the conversation over to a person on the team, and any team member can take over at any time.

Data about each business's end customers: the business is the data controller. ETW acts as a data processing service provider on behalf of the business (section 25 of Argentine Law 25,326): we process that data only to provide the service and following the business's instructions, we do not use it for any other purpose, and we do not share it with anyone other than the providers listed in section 4.
Data about the business's account and its users: the controller is GREIG MOISES.

2. What data we process

About the business using ETW: account data (name, email, team users and their permissions); the WhatsApp Business account data that Meta reports to us (account and number identifiers, phone number, display name, status, quality and messaging limits); its message templates; the information and documents it provides for the assistant; and the access permission the business grants us in Meta when connecting its number, which we store encrypted.
About the business's end customers: phone number, WhatsApp profile name, the messages exchanged with the business and the files, photos and voice notes sent, and any data the business adds to the contact's record.
If the person arrives from a Meta ad: we store which ad brought them (the ad's identifier, title and image, and the click identifier Meta sends) and, if the business sets it up, we send it to the business's own systems together with the sales and leads it reports to us.
If the business connects the number it already uses in the WhatsApp Business app (to keep using the app on its phone and ETW at the same time): we also import the contacts from the app's address book (name and number), up to 6 months of the app's chat history if the business agrees to share it when connecting, and the messages the business keeps sending from the phone app, so the conversation shows complete. This only happens if the business chooses to connect that way.
Technical data: operation and error logs (dates, internal identifiers, error codes). They do not store message content, end customers' phone numbers, or passwords or access keys, and they are kept for a limited time.

3. What we use it for

Receiving and sending WhatsApp messages on behalf of the business and showing them in its inbox.
Letting the business's customer service assistant reply based on the information and rules the business provides, and letting a team member take over the conversation.
Managing the business's message templates with Meta.
Notifying the business about changes to its number or account (for example, if Meta disconnects or restricts it, or if the permission expired) and keeping the service secure and running.

We do not sell data or use it for advertising. Data received through WhatsApp is not used to train artificial intelligence models, ours or anyone else's.

4. Who we share it with (providers)

Meta Platforms (WhatsApp Business Platform): to send and receive the business's WhatsApp messages. Meta also processes that data under its own terms with the business.
Anthropic (Claude model): processes the conversation text and the business's information to generate the customer service assistant's replies. It is only involved if the business has the assistant turned on.
OpenAI or Google (Gemini), only if enabled: used to search within the documents the business uploaded (they turn those documents and the assistant's searches into numeric data that lets us find the matching passage).
Our server provider (Hostinger, with the server in the United States), where the CRM, its database and the assistant engine run.

Under their commercial business terms, these AI providers do not use the data they receive through their API to train their models. Each provider processes the data only to provide its service to us.

International transfer (section 12 of Law 25,326): several of these providers process data outside Argentina, mainly in the United States (Meta, Anthropic and, if used, OpenAI or Google) and in the country where our server is located. This transfer is made to provide the service and under the contractual safeguards those providers offer.

Requests from authorities: if a public authority asks us for data, we check that the request is lawful, challenge it if it is not, provide only the minimum necessary and keep a record. Where the law allows it, we notify the affected business.

5. How long we keep it and what gets deleted

We keep data while the business has an active account and needs it for the service.

If the business presses "Disconnect" on a number: we stop receiving and sending messages for that account, ask Meta to stop sending us that account's messages and delete the stored access permission. Conversations and contacts remain in the business's account until it deletes them. The number keeps working in WhatsApp.
If the business presses "Delete this number's data": we delete that number's conversations, messages and files, the contacts that only talked through it, and the history imported from the app. If the WhatsApp Business account has no connected number left (this one included), we also delete its templates stored in ETW. This cannot be undone.
If the business closes its account or asks us for deletion: we delete its data and its end customers' data, except what the law requires us to keep.

6. Security

We use encrypted connections (HTTPS) across the service, store access permissions and keys encrypted, grant role-based access within each business (each business only sees its own data), limit server access to the technical team, and keep logs that do not store message content or credentials. Our providers commit in writing to protect the data. If a security incident affected data, we would notify the business as soon as possible.

7. Your rights and how to ask for deletion

You can ask for access to, correction, update or deletion of your personal data.

If you are an end customer of a business that uses ETW: the fastest way is to ask that business, which decides about that data. You can also write to us and we will pass it on or resolve it with the business.
If you are a business or a ETW user: write to us.

You can write to us from the contact page or at contacto@etwchatbot.com. We answer access requests within 10 calendar days (section 14 of Law 25,326) and correction, update or deletion requests within 5 business days (section 16). The steps are in Data deletion.

The data subject has the right to access their personal data free of charge at intervals of no less than six months, unless a legitimate interest is shown, under section 14, subsection 3, of Law 25,326.

The Agency for Access to Public Information (AAIP), as the supervisory authority of Law 25,326, has the power to handle complaints and claims filed by anyone whose rights are affected by a breach of the personal data protection rules in force.

8. Changes to this policy

If we change this policy, we publish the new version on this page with its date and, if the change is significant, we notify the businesses that use ETW.