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Privacy Policy

Last updated: 21 September 2026 · Version 2.0

Sahulatcart is a service of Nubrix Technologies (Pvt) Ltd, a company registered in Pakistan, providing an automated WhatsApp sales assistant to merchants. This policy explains what personal data we handle, why, who it is shared with, how long we keep it and how to have it deleted.

Contents

  1. Who this covers
  2. Our role: controller or processor
  3. Data we collect
  4. How we use it
  5. Automated processing and AI
  6. What we never do
  7. Who we share data with
  8. WhatsApp data residence
  9. Payments
  10. How long we keep data
  11. Security
  12. Your rights and choices
  13. Deleting your data
  14. International transfers
  15. Children
  16. Legal position in Pakistan
  17. Changes
  18. Contact

1. Who this covers

Merchants

Our customers — the shop owners who sign up, connect a WhatsApp number and use the admin portal.

Buyers

People who message a merchant on WhatsApp. We process your data on that merchant's behalf.

The merchant decides what their shop sells, what it charges, and how long they keep their records. Your relationship for an order is with them, not with us.

2. Our role: controller or processor

DataWho decides how it is usedOur role
Buyer conversations, orders, delivery details, payment screenshotsThe merchantProcessor — we act on the merchant's instructions only
Merchant account, billing, support and usage dataSahulatcartController
Website analytics and enquiry forms on sahulatcart.comSahulatcartController

Where we are a processor, requests about a specific shop's records are for that merchant to decide, and we will pass your request to them. Where we are a controller, you can come to us directly.

3. Data we collect

3.1 From buyers, via WhatsApp

DataWhy
WhatsApp phone number and profile nameTo identify the conversation and route replies
Message content — text, voice notes, imagesTo understand the request and reply
Voice note transcriptsSo a spoken message can be understood and answered
Delivery name, address, area and cityTo create and fulfil the order
Payment screenshots (bank transfer)So the merchant can verify payment manually
Order, negotiation and price historyTo maintain the conversation and the merchant's records
Opt-out statusTo stop messaging you when you ask us to

3.2 From merchants

Business name, owner name, email address, login credentials (stored hashed by our authentication provider — we never see your password), staff user accounts and roles, product catalogue, pricing and discount rules, knowledge-base content, and the bank account details you choose to show buyers.

3.3 Automatically

Technical logs needed to run and secure the service: IP address, timestamps, request paths, error traces, and message delivery status from WhatsApp. On our marketing website we use only what is necessary to serve the pages; we do not run advertising or cross-site tracking cookies.

4. How we use it

  • To operate the assistant: answer questions, negotiate within the merchant's limits, build orders, collect delivery details and record the chosen payment method.
  • To generate order slips and notify the merchant.
  • To let the merchant view, search and take over conversations from their admin portal.
  • To keep the service secure, prevent abuse, and diagnose faults.
  • To bill merchants and provide support.
  • To comply with legal obligations and with Meta's platform requirements.

5. Automated processing and AI

Replies are produced with help from an AI language model, which is used to interpret incoming messages, transcribe voice notes, read images, and phrase replies.

Prices are not decided by the AI. All pricing and discount limits are computed by deterministic code from the rules the merchant sets. Every reply that states a price is checked against that code's figure before sending; if they disagree the AI's wording is discarded in favour of a fixed template. The model cannot invent or exceed a discount.

Message content, voice notes and images are sent to our AI provider solely to produce that reply. We use a paid, commercial processing tier under which the provider does not use this content to train or improve its models and does not make it available for human review.

A buyer can ask to speak to a human at any point, and the merchant can take over the conversation. No decision with a legal or similarly significant effect is made about you by automated means.

6. What we never do

These commitments are binding on us and reflect the requirements of the WhatsApp Business Solution Terms:

  • We do not sell, rent or license personal data.
  • We do not use buyer data to track, build or augment profiles of individual WhatsApp users.
  • We do not use buyer data to create, develop, train or improve any machine learning or artificial intelligence model — ours or anyone else's.
  • We do not use buyer conversations to advertise to buyers, and we do not share data with advertising networks.
  • We do not share data between merchants. Each merchant's records are isolated at the database level.
  • We do not process buyer data for our own purposes — only to deliver the service the merchant asked for.

7. Who we share data with

We use the following sub-processors. We do not add a sub-processor that handles buyer data without updating this list.

ProviderWhat is sharedPurposeWhere
Meta Platforms / WhatsAppMessages and mediaSending and receiving WhatsApp messagesUSA, EU
Google (Gemini API)Message text, voice notes, product and payment imagesUnderstanding messages and drafting repliesUSA
SupabaseDatabase records, uploaded files, authenticationDatabase, file storage and merchant loginPer project region
RailwayApplication traffic and logsHosting the serviceUSA

We may also disclose data where we are legally required to — for example under a valid court order or a lawful request from a competent authority — or where necessary to establish, exercise or defend legal claims. If we are ever party to a merger or acquisition, data may transfer to the successor, who will remain bound by this policy.

8. WhatsApp data residence

Messages sent through the WhatsApp Business Platform are processed on Meta's Cloud API infrastructure and stored in Meta's data centres, currently located in North America and Europe. Meta acts as a processor for the merchant in respect of that content. Data localisation within Pakistan is not available for WhatsApp Business Platform messaging, and neither we nor the merchant can change where Meta processes it.

Sahulatcart is an independent technology provider. We are not affiliated with, endorsed by, or operated by WhatsApp LLC or Meta Platforms, Inc.

9. Payments

We never take custody of money and we are not a payment processor. Orders are Cash on Delivery, or a bank transfer made directly to the merchant's own account. Payment screenshots are stored in a private bucket so the merchant can verify them manually; we do not read, verify or act on them automatically beyond describing the image so the merchant can find it. We do not collect or process card numbers or banking credentials from buyers.

10. How long we keep data

DataRetention
Conversations and messagesWhile the merchant's account is active, unless they delete them sooner
Orders and order slipsWhile the account is active, or longer where the merchant must keep records for tax
Payment screenshots and inbound media12 months, then deleted unless attached to an unresolved dispute
Voice notesDeleted after transcription; the transcript follows the message retention above
Opt-out recordsKept indefinitely — we must remember not to message you
Technical and security logs90 days
Merchant account and billing recordsDuration of the account, plus the period required by tax law
After account closure30 days to allow export, then deleted or anonymised

Merchants control how long their own conversation and order records are kept within these limits and may delete them at any time.

11. Security

We maintain administrative, physical and technical safeguards appropriate to the sensitivity of the data, including:

  • Encryption in transit (HTTPS/TLS) for all traffic, and encryption at rest by our storage provider
  • Row-level database isolation so one merchant's queries cannot reach another's records
  • Role-based access control, so staff accounts cannot see cost prices or verify payments unless the merchant grants that role
  • Private storage buckets for payment screenshots and inbound media — these are not publicly accessible
  • Cryptographic verification of every inbound WhatsApp webhook before it is processed
  • Access credentials held in a secrets manager, not in source code, and rotated when exposed

No system is perfectly secure. If a breach affects your personal data and creates a real risk to you, we will notify the affected merchants without undue delay and support them in notifying buyers where that is appropriate.

12. Your rights and choices

You may ask us to:

  • Access the personal data we hold about you
  • Correct data that is wrong or incomplete
  • Delete your data — see Data Deletion
  • Export your data in a portable format
  • Stop messaging you

Buyers: to stop the assistant immediately, reply STOP on WhatsApp. That opts your number out of further messages from that merchant. You can also ask for a human at any time and the assistant will hand the conversation over.

Because we process buyer data on a merchant's behalf, a request about a specific shop's records will be passed to that merchant, who decides it. We will help them act on it. We respond to requests within 30 days.

13. Deleting your data

Full instructions, including what gets deleted and how long it takes, are on our dedicated Data Deletion page. In summary: buyers should contact the merchant they messaged, or us at sahulatcart2026@gmail.com; merchants can close their account from the admin portal or request deletion in writing.

14. International transfers

Our sub-processors operate outside Pakistan, principally in the United States and the European Union. Using this service necessarily involves transferring personal data to those countries. We rely on the contractual protections in our agreements with each provider, including their standard data processing terms, to protect that data.

15. Children

The service is intended for business use by adults and is not directed at children. We do not knowingly collect data from anyone under 18. If we learn that we have, we will delete it.

16. Legal position in Pakistan

At the date of this policy, Pakistan has no comprehensive enacted personal data protection statute; the Personal Data Protection Bill remains in draft before the legislature. We have written this policy to the principles that bill sets out — lawful basis, purpose limitation, data minimisation, retention limits, security and data subject rights — so that the service is ready when it comes into force. We also comply with the Prevention of Electronic Crimes Act 2016 and with Meta's platform requirements, which apply to us contractually regardless of local law.

17. Changes

We may update this policy. For material changes affecting merchants we will give notice by email or in the admin portal before they take effect. The revision date at the top shows when it last changed.

18. Contact

Nubrix Technologies (Pvt) Ltd
Lahore, Pakistan
+92 333 3051094
sahulatcart2026@gmail.com

Or use our contact page. We respond to data requests within 30 days.

Related pages: User Agreement · Data Deletion

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