Privacy Policy for WhatsApp Auto-Chatbot Services
Vosme International Sdn Bhd
Company Registration No: 1086600-P
Address: 295, Jalan Bakri Jaya 13, Taman Bakri Jaya, 84200 Muar Johor
Date of Last Update: June 18, 2025
1. Introduction
Vosme International Sdn Bhd (“we,” “us,” “our,” or “Company”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your personal information when you interact with our WhatsApp auto-chatbot services.
This policy complies with:
- Malaysia’s Personal Data Protection Act 2010 (PDPA)
- Meta’s WhatsApp Business Platform policies
- Applicable international data protection standards
2. Data Controller Information
Data Controller:
Vosme International Sdn Bhd
295, Jalan Bakri Jaya 13, Taman Bakri Jaya, 84200 Muar Johor, Malaysia
Email: [email protected]
Phone: +60187607799
Data Protection Officer: Sean Tan
3. Information We Collect
3.1 Personal Data Collected
When you interact with our WhatsApp chatbot, we may collect:
- Contact Information: WhatsApp phone number, display name, profile picture
- Communication Data: Messages, media files, timestamps, delivery status
- Technical Data: Device information, IP address, WhatsApp session data
- Business Information: Company name, business details (if applicable)
- Interaction Data: Chat history, user preferences, response patterns
3.2 Automated Data Collection
Our chatbot automatically collects:
- Message metadata and timestamps
- User interaction patterns
- System performance metrics
- Error logs and debugging information
4. Legal Basis for Processing (PDPA Compliance)
Under Malaysia’s PDPA, we process your personal data based on:
- Consent: You have given explicit consent for specific processing activities
- Contract Performance: Processing necessary to fulfill our chatbot services
- Legitimate Interest: Improving service quality and customer support
- Legal Obligation: Compliance with applicable laws and regulations
5. How We Use Your Information
5.1 Primary Purposes
- Providing automated chatbot responses and services
- Customer support and inquiry handling
- Service improvement and optimization
- Business communication and notifications
5.2 Secondary Purposes
- Analytics and service performance monitoring
- Compliance with legal obligations
- Fraud prevention and security measures
- Marketing communications (with explicit consent)
6. Data Sharing and Disclosure
6.1 Third-Party Sharing
We may share your data with:
Meta Platforms (WhatsApp):
- Essential for chatbot functionality
- Subject to Meta’s privacy policies
- Limited to necessary operational data
Service Providers:
- Cloud hosting and storage providers
- Analytics and monitoring tools
- Technical support vendors
Legal Requirements:
- Government authorities when legally required
- Law enforcement agencies with valid requests
- Regulatory bodies for compliance purposes
6.2 International Transfers
Data may be transferred outside Malaysia to:
- Meta’s international servers
- Cloud service providers with adequate protection
- Service providers in countries with adequate data protection
Safeguards: We ensure appropriate safeguards through standard contractual clauses and adequacy decisions.
7. Data Retention
7.1 Retention Periods
- Chat Messages: Retained for 12 months from last interaction
- User Profiles: Retained while service is active plus 6 months
- Technical Logs: Retained for 3 months for troubleshooting
- Analytics Data: Aggregated data retained for 24 months
7.2 Deletion Criteria
Data is deleted when:
- Retention period expires
- User requests deletion
- Service termination
- Legal requirement for deletion
8. Your Rights Under PDPA
You have the right to:
8.1 Access Rights
- Request information about data processing
- Obtain copies of your personal data
- Know the source of your data
8.2 Correction Rights
- Correct inaccurate personal data
- Update incomplete information
- Amend outdated records
8.3 Withdrawal of Consent
- Withdraw consent for processing
- Opt-out of marketing communications
- Disable certain data collection features
8.4 Restriction Rights
- Limit processing in certain circumstances
- Object to automated decision-making
- Request data portability where applicable
To Exercise Your Rights: Contact our Data Protection Officer Sean Tan at [email protected] or +60187607799
9. Data Security Measures
9.1 Technical Safeguards
- End-to-end encryption for WhatsApp communications
- Secure data transmission protocols (HTTPS/TLS)
- Regular security audits and vulnerability assessments
- Access controls and authentication systems
9.2 Organizational Safeguards
- Staff training on data protection
- Data processing agreements with vendors
- Regular policy reviews and updates
- Incident response procedures
9.3 WhatsApp Security
We leverage WhatsApp’s built-in security features:
- Message encryption
- Secure authentication
- Platform security updates
10. Meta/WhatsApp Compliance
10.1 WhatsApp Business Policy Compliance
- Adherence to WhatsApp Business Platform terms
- Compliance with messaging policies
- Respect for user blocking and reporting mechanisms
- Proper use of WhatsApp Business API
10.2 Data Processing Agreement
We maintain appropriate agreements with Meta regarding:
- Data processing responsibilities
- Security requirements
- Incident notification procedures
- Cross-border data transfers
11. Cookies and Similar Technologies
Our chatbot service may use:
- Session identifiers for conversation continuity
- Analytics cookies for service improvement
- Performance monitoring tools
- User preference storage
Cookie Management: You can manage cookies through your device settings.
12. Children’s Privacy
- Our services are not intended for children under 18
- We do not knowingly collect data from minors
- Parental consent required for users under 18
- Immediate deletion of identified minor data
13. Data Breach Notification
In case of a data breach:
- PDPA Compliance: Notification to authorities within 72 hours
- User Notification: Direct notification if high risk to rights
- Documentation: Comprehensive breach records maintained
- Remedial Action: Immediate steps to contain and remedy
14. Cross-Border Data Transfers
14.1 Transfer Mechanisms
- Standard Contractual Clauses (SCCs)
- Adequacy decisions by relevant authorities
- Binding Corporate Rules where applicable
- Explicit consent for specific transfers
14.2 Countries of Transfer
Data may be transferred to:
- Singapore (WhatsApp servers)
- United States (Meta infrastructure)
- European Union (service providers)
- Other jurisdictions with adequate protection
15. Contact Information
15.1 General Inquiries
Vosme International Sdn Bhd
Email: [email protected]
Phone: +60187607799
Address: 295, Jalan Bakri Jaya 13, Taman Bakri Jaya, 84200 Muar Johor, Malaysia
15.2 Data Protection Officer
DPO Contact: Sean Tan
Email: [email protected]
Phone: +60187607799
Office Hours: Monday to Friday, 9:00 AM – 6:00 PM MYT
15.3 Complaints
For privacy complaints:
- Internal: Contact our DPO first
- External: Malaysian Personal Data Protection Commission
- WhatsApp-related: Meta’s privacy reporting channels
16. Policy Updates
- Regular reviews conducted annually
- Updates communicated via WhatsApp notifications
- Significant changes require renewed consent
- Version history maintained and available upon request
Notification Method: We will notify you of material changes through:
- WhatsApp message notifications
- Email communications (if provided)
- Website announcements
- In-app notifications
17. Governing Law
This Privacy Policy is governed by:
- Malaysian Personal Data Protection Act 2010
- Malaysian Communications and Multimedia Act 1998
- Applicable Malaysian federal and state laws
- International treaties where applicable
Jurisdiction: Malaysian courts have exclusive jurisdiction over privacy-related disputes.
18. Definitions
Personal Data: Any information relating to an identified or identifiable individual
Processing: Any operation performed on personal data
Data Controller: Entity determining purposes and means of processing
Data Processor: Entity processing data on behalf of the controller
PDPA: Malaysia’s Personal Data Protection Act 2010
Effective Date: June 18, 2025
Version: 1.0
Language: This policy is available in English and Bahasa Malaysia upon request
Acknowledgment: By using our WhatsApp chatbot services, you acknowledge that you have read, understood, and agree to this Privacy Policy.
This privacy policy is designed to be comprehensive and compliant with applicable laws. However, it should be reviewed by qualified legal counsel before implementation to ensure full compliance with current regulations and specific business requirements.