Privacy Policy

1. Introduction

Havari Ltd (“Havari”, “we”, “us”, or “our”) is committed to protecting the privacy of our clients and their end users. This Privacy Policy explains how we collect, use, share, and protect personal data when you use our business communication platform (including SMS, email, and WhatsApp services) or interact with us.

We are registered in England and Wales with company number 17161985. Our registered office is 4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB.

If you have any questions, please contact us at:

• 📧 support@havari.com
• 📞 0333 1888 388

2. Data Controller and Data Processor Roles

Clients (you) are the Data Controllers of the data you collect, upload, or process through our platform.

Havari is the Data Processor, processing personal data on your behalf in line with our Terms and this Policy.

For certain uses (e.g. for our own marketing or account management), Havari acts as the Data Controller.

3. Information We Collect

We may collect and process the following types of personal data:

a. Client Data (B2B Customers)

• Name, email, phone number, business address
• Company information and billing details
• Login credentials (encrypted)
• Usage and interaction data on our platform

b. End User Data (Message Recipients)

Data that you upload or manage through our service, such as:

• Name, phone number, email address, and opt-in status
• Messaging content, delivery reports, read receipts, and timestamps across SMS, email, and WhatsApp channels
• Email content, subject lines, attachments metadata, and thread history where email integration is enabled
• WhatsApp message content and conversation history where WhatsApp integration is enabled

You are responsible for ensuring all End User data is collected and used lawfully, with appropriate consent for each communication channel.

4. How We Use Your Information

We use personal data to:

• Provide and operate our business communication services (SMS, email, and WhatsApp)
• Manage your account and billing
• Communicate with you (including support and updates)
• Improve our platform and customer experience
• Meet legal and regulatory obligations

5. Legal Basis for Processing

We rely on the following lawful bases under the UK GDPR:

• Performance of a contract – to deliver our services to you
• Legal obligation – for compliance with tax or regulatory laws
• Consent – where required for electronic marketing (e.g. newsletters)
• Legitimate interests – such as improving our services and fraud prevention, where these do not override your rights

6. Data Sharing and Third Parties

We may share data with trusted third parties who assist in delivering our services, such as:

• SMS gateway and carrier providers (e.g. Telnyx)
• Email infrastructure providers, including Google (Gmail integration), Microsoft (Outlook integration), and AWS Simple Email Service (SES)
• WhatsApp Business Solution Providers and Meta Platforms Inc. — your use of WhatsApp is additionally subject to Meta's Privacy Policy and WhatsApp Business Terms
• Hosting and infrastructure services (e.g. AWS)
• Payment processors (e.g. Stripe)
• Professional advisors (e.g. accountants, legal counsel)

All such providers are contractually bound to protect your data and act only under our instructions, except where data must be shared with Meta or Google/Microsoft as a condition of using their messaging platforms.

6A. Email Integration Data

When you connect a Gmail or Outlook account to Havari, we access your email account solely to read, send, and manage emails on your behalf as directed by you within the Platform. We:

• Store email content, metadata, and thread history in our systems to power the shared inbox and CRM features;
• Do not use email content for advertising, profiling, or any purpose other than operating the Platform features you have enabled;
• Use Google API Services in accordance with the Google API Services User Data Policy, including the Limited Use requirements;
• You may revoke Havari's access to your email account at any time through your Google or Microsoft account settings.

6B. WhatsApp Data

When you use WhatsApp through the Platform, message content and metadata is processed via Meta's WhatsApp Business API. Meta operates as an independent data controller for certain elements of WhatsApp data. We process WhatsApp conversation data on your behalf to provide the Platform's inbox and CRM features. For full details of how Meta handles WhatsApp data, please refer to Meta's WhatsApp Privacy Policy.

7. International Transfers

If we transfer your personal data outside the UK (e.g. for SMS routing or cloud hosting), we ensure appropriate safeguards are in place, such as:

• UK adequacy decisions
• Standard Contractual Clauses (SCCs)

You can request a copy of applicable safeguards by contacting us.

8. Data Retention

We retain personal data only as long as necessary:

• Client account data: Retained for the duration of your account and up to 6 years after closure for legal or regulatory purposes.
• End User data (SMS, email, WhatsApp): Retained in accordance with your settings or specific instructions. Message content and thread history remain accessible within the Platform for as long as your account is active.
• Email content: Emails synced from connected Gmail or Outlook accounts are stored in our systems for Platform operation. If you disconnect an email account, previously synced data will be retained for up to 90 days before deletion unless you request earlier removal.
• WhatsApp conversation data: Retained for Platform operation for as long as your account is active.
• Backup data: Retained for a limited time under secure conditions.

9. Your Rights

Under the UK GDPR, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict or object to processing
• Data portability (where applicable)
• Withdraw consent at any time (for marketing)
• Lodge a complaint with the ICO: www.ico.org.uk

To exercise any of your rights, please contact us at support@havari.com.

10. Cookies and Tracking

Our website may use cookies and similar technologies to improve functionality and analyse usage. You can manage your cookie preferences through your browser settings or via our cookie banner. For full details, please refer to our Cookie Policy.

11. Security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, or misuse, including:

• Encryption of data in transit and at rest
• Strict access controls and user authentication
• Regular audits and secure backups

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any significant changes will be communicated via email or prominently on our website. Your continued use of the Platform after such changes indicates your acceptance of the updated Policy.

13. Contact

If you have any questions about these Policies, please contact us at: