Privacy & Data Protection Policy

1. Overview & Service Scope

Premium Growth Engine ("we", "our", or "the platform"), operated by TORPSKÄRN LIMITED, is committed to protecting data privacy. The platform acts as an automated scheduling coordinator utilizing WhatsApp messaging access tokens to match client request slots with provider schedules, facilitating streamlined appointment communication.

2. Information Collection & WhatsApp Integration

To provide automated scheduling coordination services, the platform accesses and processes information through integrated Meta / WhatsApp API interfaces. This includes:

• WhatsApp Access Tokens: Utilizes secure authorization tokens to orchestrate automatic messaging updates on behalf of the registered tenant.
• Contact Information: Phone numbers of clients and service providers to facilitate match notifications.
• Scheduling Details: Requested booking slots, availability states, and service provider profiles.

3. Data Controller vs. Data Processor Roles (KDPA 2019)

Under the Kenya Data Protection Act 2019 (KDPA 2019):

• The merchant operating the salon, spa, or enterprise workspace acts as the Data Controller.
• TORPSKÄRN LIMITED acts as the Data Processor processing personal data on behalf of and strictly according to the instructions of the Data Controller.

4. Merchant SMS & WhatsApp Consent Warranties

Merchants warrant that all end-user phone numbers ingested into the system have granted explicit consent for transactional WhatsApp notifications and appointment reminders.

5. Data Deletion & Retention Criteria

We adhere to strict data retention policies. Customer and message log records are retained only as long as necessary to fulfill coordination activities or as required by law.

Tenants and end users can request a database purge or revoke permissions at any time. For step-by-step guidance on initiating a purge, please review our Data Deletion Instructions.