Privacy Policy
Privacy Policy – “Belén Siempre Contigo” Application
Last updated: 30 December 2025
Data Controller
DIGITALBRAINS MARKETING LLC
910 W Pierce St #2132, Carlsbad, NM 88220, United States
Email: info@brains-dev.com
Website: https://brains-dev.com/
1) Scope
This Privacy Policy applies to the services operated by DIGITALBRAINS MARKETING LLC that process personal data through the WhatsApp Business Platform (Meta), including the “Belén Siempre Contigo” application (the “App”).
2) What the App does (clear use case)
The App is a conversation management system (CRM/dashboard) that enables our team to receive, organize, and reply to WhatsApp conversations initiated by users. It supports two-way messaging: receiving inbound messages and sending replies through our internal interface.
User-initiated messaging only: Users contact us voluntarily (e.g., by messaging our WhatsApp number or via a “Click to WhatsApp” entry point). We do not send unsolicited bulk messages.
3) Data we process
When a user contacts us via WhatsApp, we may process:
- WhatsApp identifiers: phone number; profile/display name and alias/handle (if available).
- Message content: the text the user sends and our replies.
- Media: images, audio, documents, or other files only if the user provides them.
- Messaging metadata: timestamps, technical message/conversation IDs, and delivery/read status (when available).
- Minimal technical logs required to operate and secure the service.
We do not intentionally request sensitive personal data (e.g., health, religion, political views). Users should avoid sending sensitive data via WhatsApp. If a user includes such data, it will be processed only to address the user’s request.
4) Purposes
We process personal data to:
- Provide and operate the App’s core functionality (two-way WhatsApp messaging).
- Manage and respond to user inquiries and requests.
- Maintain a minimal operational conversation history for continuity and quality control.
- Protect the service (security, abuse/fraud prevention, troubleshooting).
5) Legal basis
Processing is based on:
- User request / user action: the user voluntarily initiates contact and requests a response.
- Consent (where required by applicable law).
- Legitimate interests: operating, securing, and improving the reliability of our services and preventing abuse/fraud.
6) Sharing
To deliver WhatsApp communications, we use the WhatsApp Business Platform (Meta). Therefore, messages and required metadata are processed through Meta Platforms, Inc. / WhatsApp infrastructure.
We may also use essential service providers (hosting/security/infra) acting under our instructions with limited access.
We do not sell personal data.
7) Retention and deletion
We retain data only for the minimum time necessary to provide the service and meet operational/security needs, and we perform periodic deletion/purging of conversation records when no longer needed.
To request deletion, email info@brains-dev.com and include your WhatsApp number and the approximate date/time of the conversation.
8) Security
We implement reasonable technical and organizational safeguards, including access controls and administrative account protection, to prevent unauthorized access.
9) Your rights
You may request access, rectification, erasure (deletion), restriction, objection, and data portability (where applicable) by contacting info@brains-dev.com.
Please include: (i) your WhatsApp number, (ii) the right you wish to exercise, and (iii) information needed to identify your conversation/request.
10) Contact
For privacy questions: info@brains-dev.com