Effective Date: `05/04/2025
`Open Mirror ("Open Mirror," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website `www.openmirror.co.za`, use our Facebook business page, use our application (the "App"), or engage with our services to create WhatsApp chatbots for businesses (collectively, the "Services").Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access or use our Services.
1. INFORMATION WE COLLECT
We may collect information about you in a variety of ways. The information we may collect includes:
a. Personal Data You Provide to Us (Primarily from our Clients):
Contact Information: When you (as a business Client or potential Client) inquire about or sign up for our Services, we may collect your name, your business name, email address, phone number, and other contact details.
Account Information: If you create an account with us, we collect your username, password, and other information needed to secure and provide access to your account.
Payment Information: If you purchase our Services, we (or our third-party payment processors) may collect payment information, such as credit card details or bank account information.
Communications: When you contact us for support, provide feedback, or otherwise communicate with us, we collect the information you provide in such communications.
Chatbot Configuration Data: Information you provide for us to build and configure your WhatsApp chatbot, which may include business information, product/service details, desired conversational flows, and integration credentials.
b. Data We Collect Automatically (From Website/App Visitors and Users):
Log and Usage Data: When you access our website or App, our servers may automatically record information, including your IP address, browser type, operating system, referring URLs, pages viewed, access times, and other usage statistics.
Cookies and Tracking Technologies: We may use cookies, web beacons, and similar tracking technologies to collect information about your interaction with our website or App, to enhance user experience, and for analytics. You can control the use of cookies at the individual browser level. For more information, see our "Cookies and Tracking Technologies" section below.
c. Information We Process on Behalf of Our Clients (End-User Data):
This section describes our role concerning the data of individuals ("End-Users") who interact with the WhatsApp chatbots we build for our Clients.
Client Responsibility: Our Clients are the "data controllers" of the personal data of their End-Users. This means our Clients determine the purposes and means of processing End-User data through the chatbots. Clients are responsible for having a lawful basis for collecting and processing End-User data, including providing adequate privacy notices and obtaining necessary consents from their End-Users, in compliance with WhatsApp policies and applicable data protection laws.
Open Mirror as Data Processor: When we provide Chatbot services to our Clients, we act as a "data processor" for the End-User data that is transmitted or processed through the Chatbots. This data may include End-User names, phone numbers, messages, and any other information shared by End-Users while interacting with the Client's Chatbot.
Our Processing: We process End-User data solely on behalf of and in accordance with the instructions of our Clients (as documented in our service agreements), for the purpose of providing, maintaining, and improving the Chatbot services. We do not use End-User data for our own purposes, except in aggregated and anonymized form for service improvement or as required by law.
Access: Our access to End-User data is limited to what is necessary to build, deploy, support, and maintain the functionality of the Chatbots for our Clients, or as required by law.
2. HOW WE USE YOUR INFORMATION
We use the information we collect (excluding End-User data processed on behalf of Clients, which is used as described in 1.c) for various purposes, including:
To provide, operate, and maintain our Services.To create and manage your Client account.To process your transactions and send you related information, including purchase confirmations and invoices.To respond to your comments, questions, and requests, and provide customer service and support.To send you technical notices, updates, security alerts, and support and administrative messages.To communicate with you about products, services, offers, promotions, and events offered by Open Mirror and others, and provide news and information we think will be of interest to you (subject to your communication preferences).To monitor and analyze trends, usage, and activities in connection with our Services to improve them.To personalize our Services.To detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Open Mirror and others.For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.For other purposes for which we obtain your consent.For End-User data we process on behalf of our Clients, we use it solely to provide and maintain the Chatbot services as instructed by our Client.
3. HOW WE SHARE YOUR INFORMATION
We may share information we collect as follows:
With Service Providers:
We may share information with third-party vendors, consultants, and other service providers who need access to such information to carry out work on our behalf (e.g., payment processors, hosting providers, analytics providers, communication services). These service providers are authorized to use your personal information only as necessary to provide these services to us.
With Our Clients (Regarding their End-User Data): We provide our Clients with access to the End-User data processed through the Chatbots we build for them.For Legal Reasons: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Open Mirror, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
With Your Consent: We may share your information with your consent or at your direction.
We do not sell personal information. End-User data processed on behalf of our Clients is shared only as directed by the Client, as necessary to provide the Services, or as required by law.
4. COOKIES AND TRACKING TECHNOLOGIES
We may use cookies, web beacons, tracking pixels, and other tracking technologies on our website and App to help customize the Services and improve your experience. When you access our website or App, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
5. DATA SECURITY
We use reasonable administrative, technical, and physical security measures to help protect your personal information and the End-User data we process on behalf of our Clients from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
6. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For End-User data we process on behalf of our Clients, we retain such data in accordance with the terms of our agreement with the Client or as instructed by the Client.
7. YOUR DATA PROTECTION RIGHTS
Depending on your location and applicable data protection laws, you may have certain rights regarding your personal information:
Access: The right to request access to the personal information we hold about you.
Rectification: The right to request correction of inaccurate personal information.Erasure (Deletion): The right to request deletion of your personal information, subject to certain exceptions.
Restriction of Processing: The right to request that we restrict the processing of your personal information.
Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format.
Objection: The right to object to the processing of your personal information in certain circumstances.
Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw your consent at any time.
To exercise any of these rights, please contact us using the contact details provided below. We will respond to your request in accordance with applicable data protection laws.
Note for End-Users: If you are an End-User of a Chatbot provided by one of our Clients and wish to exercise your data protection rights regarding data processed by that Chatbot, please contact the respective Client (the business that operates the Chatbot) directly. Open Mirror acts as a data processor and will assist our Clients in responding to such requests as applicable.
8. INTERNATIONAL DATA TRANSFERS
Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside `South Africa` and choose to provide information to us, please note that we transfer the data, including Personal Data, to `South Africa` and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
9. CHILDREN'S PRIVACY
Our Services are not directed to individuals under the age of 13 (or a higher age threshold as required by applicable law, e.g., 16 in some EU countries). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information as soon as possible. If you believe that a child has provided us with personal information, please contact us.
10. LINKS TO OTHER WEBSITES
Our Services may contain links to other websites or services that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. For material changes, we may provide more prominent notice (such as by email or a notice on our website).