Privacy Policy

Last updated: 12 October 2026

1. Overview

BRAND ("the Service") is operated by SmartClinic AI HK Limited ("the Company", "we", "us"). It lets businesses manage their WhatsApp, Facebook Messenger and Instagram messages in one place, with automated replies, broadcast messages, coupon codes, customer tags and reports.

This Privacy Policy explains how we collect, use, store and protect the personal data of businesses that use the Service and their staff, customers who contact those businesses through these channels, and people who send us an enquiry through this website.

For customers' personal data, the business using the Service is the Data User, and the Company acts as a Data Processor that handles the data only on that business's instructions. Businesses should give their customers a Personal Information Collection Statement in line with the Personal Data (Privacy) Ordinance.

2. Data We Collect

2.1 Customer data (processed for businesses)

When a customer chooses to message a business that uses the Service through WhatsApp, Facebook Messenger or Instagram, we process the following for that business:

  • The customer's WhatsApp phone number, or the Messenger or Instagram scoped ID provided by Meta
  • The customer's display name and Instagram username (provided by Meta)
  • Messages exchanged between the customer and the business, including text and attachment information
  • Message sent, delivered and read status
  • Tags, notes and coupon codes set by the business, and the customer's consent or opt-out status for promotional messages

2.2 Business and staff data

The business name, staff names and login emails, passwords stored as hashes, the names and IDs of connected WhatsApp numbers, Facebook Pages and Instagram professional accounts, and staff activity logs on the platform.

2.3 Website enquiries

When you submit the enquiry form on this website, we collect the name, company or brand, email, phone number, current setup, message volume, preferred channels and message you enter, and whether you agree to receive promotional information. To prevent abuse, we also record the time of submission and your IP address in an irreversibly encrypted form.

3. How We Use Data

3.1 Providing the Service

  • Showing customer messages in the business's inbox so its staff can read and reply to them
  • Automatically answering customer enquiries using information the business has approved, and passing other enquiries to the business's staff
  • Sending broadcast messages and coupon codes, on the business's instructions, to customers who have agreed to receive them; customers may opt out at any time
  • Providing the business with reports such as delivery, read and coupon-use figures

3.2 Facebook Messenger and Instagram data

  • We only access direct messages that customers send to the business's Facebook Page or Instagram professional account, and the business's replies.
  • We do not access posts, comments, friend lists or other profile data of the business or its customers, and we do not publish any content on the business's behalf.
  • This data is used only for the purposes above. It is never used for advertising or profiling, never sold or transferred to third parties, and never shared with other businesses.
  • A business can disconnect its Page or Instagram account at any time; we then stop receiving new messages for that account.

3.3 Website enquiries

We use enquiry details only to contact you about your enquiry and send a quote. We send product updates and offers only if you tick the box to agree, and you can opt out at any time by emailing us.

We also use system logs for security, abuse prevention and service maintenance.

4. Storage and Security

The Service's database is in Google Cloud Platform's Hong Kong region and protected by encrypted transmission (TLS). Each business's data is stored separately, and staff can only see data belonging to their own business. Access tokens used to connect WhatsApp, Facebook and Instagram are encrypted before storage.

Some processing, such as AI language processing and message delivery, may take place on servers outside Hong Kong. We apply reasonable technical safeguards, including encrypted transmission and access controls, to protect such data.

5. Retention

  • Service data is generally deleted within 90 days after a business stops using the Service, except where the law requires longer retention. A business may also request earlier deletion.
  • When a customer unsends a message, its content is erased from our systems.
  • Website enquiries are kept for up to 24 months after submission and then deleted automatically.

6. Service Providers

  • Meta Platforms, Inc.: WhatsApp Business Platform, Messenger Platform and Instagram messaging APIs, for sending and receiving messages
  • Google Cloud Platform: computing, database storage and AI language processing
  • Google Workspace: email, including internal notifications of website enquiries
  • Cloudflare, Inc.: hosting of this website and the business web interface

Each provider handles data under its own privacy policy.

7. Data Sharing

We never sell or rent personal data, and we never share data between businesses. Data may only be accessed or disclosed:

  • To comply with applicable law, court orders or lawful requests from government authorities
  • To protect the legitimate rights of the Company, businesses or others, for example to prevent abuse of the Service
  • On the instructions of the business, as the Data User

8. Your Rights

Under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486), you generally have the right to access and correct personal data we hold about you, to request deletion (subject to legal retention requirements), and to opt out of promotional messages at any time.

Facebook and Instagram users can remove the Service's access under "Apps and Websites" in Facebook settings. To delete stored data, see our Data Deletion instructions.

Customers may also contact the business that serves them, and we will help the business respond.

9. Changes to This Policy

We may update this policy to reflect changes in law, technology or our business. Material changes will be announced on this website, and the "Last updated" date above will change.

10. Contact Us

SmartClinic AI HK Limited
Email: info@smartclinicaihk.com