WATranslate Privacy Policy Last updated: 20 August 2026 TEST / DEVELOPMENT NOTICE WATranslate is currently a test and development service. The technical configuration, translation provider, data-retention settings, supported functionality and operational procedures described on this page are part of the current testing environment and may change before production use. This document describes how the current test version of WATranslate operates. 1. WATranslate PRIVACY POLICY 1. Purpose of WATranslate WATranslate is a communication-assistance service for WhatsApp Business. Its purpose is to help customer-service agents and WhatsApp users who speak different languages communicate with each other. The current test version supports: German Russian English Spanish Incoming messages may be automatically translated into the language used by the agent. Replies written by the agent may be translated back into the language of the WhatsApp user. Translation is used only to facilitate the relevant WhatsApp conversation and related customer communication. 2. Data We Process Depending on the conversation and technical operation of the service, WATranslate may temporarily process: • WhatsApp phone number or WhatsApp identifier • WhatsApp display name, where supplied by WhatsApp • Incoming WhatsApp message text • Outgoing message text • Machine-translated message text • Detected message language • Message timestamps • Sent, delivered, read or error status information • Technical webhook information required to receive and process WhatsApp messages • Technical information required for troubleshooting and operation of the service WATranslate is not designed for the intentional collection of payment-card details, passwords, government identification numbers, medical information or other unnecessary highly sensitive personal information. Users should avoid including unnecessary sensitive information in messages. 3. How Personal Data Is Used Personal data processed by WATranslate is used as necessary to: • Receive WhatsApp Business messages • Display the original message to an authorised agent • Detect the language of a message • Translate incoming messages • Allow an agent to prepare a reply • Translate the agent's reply into the user's language • Allow the agent to review and edit a translated reply • Send the approved reply through WhatsApp • Maintain recent conversation context • Process WhatsApp delivery and message-status information • Diagnose technical problems • Maintain security and prevent misuse of the service WATranslate is intended specifically to facilitate multilingual business communication. 4. Human Review Before Sending WATranslate does not automatically send an agent's translated reply. The agent is provided with the translated text before transmission and can review and edit the translation. A message is sent only after the agent explicitly chooses to send it. Machine translation may occasionally contain inaccuracies, incorrect wording or unintended meanings. The agent is therefore responsible for reviewing a translation before sending it. 5. Legal Basis Depending on the circumstances, processing may be based on one or more applicable legal bases. Where communication concerns an existing contract or steps requested before entering into a contract, processing may be necessary for those purposes. In other circumstances, processing may be based on legitimate interests, including: • Responding to enquiries • Providing customer support • Communicating with customers • Enabling multilingual communication • Operating and securing the communication service Where consent or another legal basis is required by applicable law, the appropriate legal basis must be used. 6. Data Retention on the WATranslate Server WATranslate is currently designed as a short-retention communication service. In the current test configuration, operational conversation information stored in the WATranslate database is intended to be retained for approximately 72 hours. This may include: • Incoming message text • Outgoing message text • Translated message text • WhatsApp identifiers • Display names • Message timestamps • Delivery and status information • Stored webhook information After the applicable retention period, this information is intended to be automatically removed from the WATranslate operational database. Contact records that no longer have retained messages may also be removed. The purpose of this short retention period is to provide enough recent conversation context for agents to communicate effectively while avoiding unnecessary long-term storage of WhatsApp conversations. Because WATranslate is currently a TEST / DEVELOPMENT project, the implementation and duration of this retention policy may change before production use. 7. Third-Party Processing and Retention The WATranslate server-retention period applies only to information stored and controlled directly by the WATranslate system. WATranslate currently relies on external services necessary to provide its functionality, including: • Meta / WhatsApp • Google Cloud Translation • Hosting and server infrastructure providers Information transmitted to these providers may be processed according to their respective terms, privacy arrangements, data-processing agreements and technical requirements. The WATranslate server's local retention schedule does not determine or override the independent processing or deletion procedures of these external providers. 8. Translation Provider – Google Cloud Translation During the current testing and development phase, WATranslate uses Google Cloud Translation to provide automatic language detection and machine translation. When translation is required, message text is transmitted securely from the WATranslate server to the Google Cloud Translation API. The current implementation supports translation involving: German Russian English Spanish Google Cloud Translation may also automatically detect the source language of a message. The translation process may therefore involve transmission of message content to Google Cloud for the purpose of providing the requested translation service. According to Google Cloud's documentation, Google does not use content submitted to Cloud Translation for purposes other than providing the service. Google Cloud's processing of Customer Data is governed by the applicable Google Cloud agreements and Cloud Data Processing Addendum. The WATranslate server's approximately 72-hour local retention period applies to the WATranslate operational database. It does not impose the same retention period on Google Cloud infrastructure. Google Cloud operates its own processing, security and deletion procedures under its applicable contractual and technical terms. WATranslate uses the official Google Cloud Translation API. WATranslate does not scrape or automate access to the public Google Translate website at translate.google.com. 9. WhatsApp and Meta WATranslate communicates with WhatsApp through Meta's WhatsApp Business Platform. Meta and WhatsApp therefore process information required to provide the WhatsApp messaging service. This may include: • WhatsApp identifiers • Phone numbers • Message content • Message timestamps • Delivery information • Technical messaging information Processing performed independently by Meta or WhatsApp is governed by Meta's and WhatsApp's applicable terms, privacy policies and data-processing arrangements. WATranslate's local data-retention settings do not control information independently processed by Meta or WhatsApp. 10. Data Sharing WATranslate does not sell personal data. Information may be disclosed or transmitted only where reasonably necessary to operate the service. Current categories of recipients may include: • Meta / WhatsApp • Google Cloud Translation • Hosting and server infrastructure providers • Technical service providers necessary to operate WATranslate • Public authorities where disclosure is legally required WATranslate does not currently use conversation information for behavioural advertising. 11. International Processing Some service providers used by WATranslate may process information in countries other than the country in which the WhatsApp user or agent is located. Where applicable data-protection law requires appropriate safeguards for international transfers, the relevant provider and service operator should maintain the legally required transfer arrangements. 12. Cookies and Session Data The WATranslate agent dashboard uses technically necessary authentication and session mechanisms. These are required to allow authorised agents to sign in and use the service securely. The current WATranslate test dashboard does not intentionally use advertising cookies or behavioural advertising trackers. 13. Security WATranslate uses technical and organisational measures intended to protect information processed through the service. The current measures include: • HTTPS for the public web interface • HTTPS for the Meta webhook endpoint • Authentication for the agent dashboard • Server-side storage of WhatsApp API credentials • Server-side storage of Google Cloud API credentials • Restricted access to administrative functionality • Meta webhook signature verification • Short-term operational data retention • Manual review before translated replies are sent API credentials and authentication tokens are not intended to be exposed to users through the public browser interface. No internet-based system can guarantee absolute security. 14. Data-Protection Rights Depending on applicable data-protection law and the circumstances of processing, individuals may have rights including: • Access to personal data • Rectification of inaccurate personal data • Erasure • Restriction of processing • Objection to processing • Data portability, where applicable • Withdrawal of consent where processing is based on consent • The right to lodge a complaint with the competent data-protection supervisory authority Because WATranslate uses short-term operational storage, information may already have been automatically deleted by the time a request is received. 15. Data Deletion Requests WATranslate is designed to automatically delete operational conversation information from its own database according to the current retention policy. A person who wishes to request earlier deletion of information still held by WATranslate may contact the business or agent with whom they communicated. To identify the relevant conversation, the requester may need to provide information such as: • The WhatsApp phone number used • Approximate date of communication • Approximate time of communication This identifying information should be used only as necessary to locate the relevant record. A deletion request made to WATranslate applies to information controlled by the WATranslate system. It does not automatically delete information independently controlled by Meta, WhatsApp, Google Cloud or another external service provider. 16. Controller / Service Operator Service: WATranslate Operator: AllDevLabs Website: https://alldevlabs.com/ Country: Germany WATranslate is currently operated as a TEST / DEVELOPMENT service. Before production deployment, the operator information should be completed with all identity, postal address and direct privacy-contact information required by applicable law. 17. Changes to This Privacy Policy This Privacy Policy may be updated when WATranslate changes, including changes to: • Translation providers • Hosting arrangements • Data-retention practices • Supported languages • WhatsApp integration • Security measures • Service functionality • Legal or regulatory requirements The "Last updated" date at the beginning of this document identifies the current version. WATranslate is an independent service using the WhatsApp Business Platform. WhatsApp and Meta are trademarks of their respective owners. Google and Google Cloud are trademarks of Google LLC. 2. WATRANSLATE DATA DELETION INSTRUCTIONS Last updated: 20 August 2026 TEST / DEVELOPMENT NOTICE These deletion procedures describe the current WATranslate test environment and may change before production deployment. Automatic Deletion WATranslate is currently designed to automatically delete operational conversation information from its own database after approximately 72 hours. Information subject to this local retention process may include: • Incoming WhatsApp message text • Outgoing message text • Machine translations • Detected languages • Message timestamps • Message-status information • WhatsApp identifiers associated with retained conversations • Stored webhook payloads used for message processing or troubleshooting • Contact records that no longer have retained conversation information Normal Automatic Deletion Under normal operation, users should not need to request deletion manually. Operational conversation information is intended to be removed from the WATranslate database automatically after the applicable retention period. Requesting Earlier Deletion If you believe WATranslate still holds information relating to your WhatsApp conversation and you would like it deleted before the automatic retention period expires, you may contact the business or agent with whom you were communicating. Please provide enough information to identify the relevant conversation. This may include: • The WhatsApp phone number used for the conversation • Approximate date of communication • Approximate time of communication, if known This information is required only to locate the relevant temporary record. Third-Party Services A deletion request made to WATranslate applies only to information controlled by the WATranslate server. WATranslate currently uses external services including: • Meta / WhatsApp • Google Cloud Translation • Hosting and infrastructure providers These providers may independently process information under their own applicable terms and data-processing arrangements. Deletion from the WATranslate database does not automatically cause deletion of information independently processed or controlled by those providers. Where necessary, requests relating to information controlled independently by another provider may need to be directed to that provider. Google Cloud Translation Message text requiring translation may be transmitted to Google Cloud Translation for language detection and machine translation. Google Cloud's handling and deletion of Customer Data is governed by the applicable Google Cloud agreements and Cloud Data Processing Addendum. Deleting a message from the WATranslate operational database does not itself define the deletion timetable within Google's infrastructure. Meta / WhatsApp WhatsApp messages are transmitted using Meta's WhatsApp Business Platform. Deletion from WATranslate does not necessarily delete messages or related information processed independently by WhatsApp or Meta. Users may have separate rights and controls available through WhatsApp or Meta. 3. WATRANSLATE DATA RETENTION POLICY Last updated: 20 August 2026 TEST / DEVELOPMENT NOTICE This Data Retention Policy describes the current test implementation of WATranslate. The retention period, technical implementation and third-party providers may change before production deployment. Purpose WATranslate is designed as a temporary communication and translation system rather than a permanent WhatsApp conversation archive. The system retains recent conversation information only for the period needed to provide agents with sufficient context to understand and respond to recent messages. Current Retention Period Operational conversation information stored on the WATranslate server is currently intended to be retained for no longer than approximately: 72 HOURS This may include: • Original WhatsApp messages • Translated messages • Agent replies • Detected languages • WhatsApp identifiers • Display names • Message timestamps • Delivery and status information • Webhook payloads associated with conversations Automatic Deletion A scheduled server process is intended to periodically remove information older than the applicable retention period. Expired messages and translations are removed from the operational database. When a contact no longer has retained messages, the associated temporary contact record may also be removed. Translation Provider The current TEST / DEVELOPMENT version of WATranslate uses: Google Cloud Translation Message text requiring language detection or translation may be transmitted to Google Cloud Translation for processing. The WATranslate server's approximately 72-hour retention period applies to information stored in the WATranslate operational database. It does not automatically control the processing or retention of information within Google Cloud infrastructure. Google Cloud's processing of Customer Data is governed by the applicable Google Cloud agreement and Cloud Data Processing Addendum. According to Google Cloud's Cloud Translation documentation, content submitted for translation is used for the purpose of providing the service. WhatsApp and Meta Messages are transmitted through Meta's WhatsApp Business Platform. Information independently processed by WhatsApp or Meta is subject to their own applicable retention, privacy and data-processing practices. WATranslate's local retention policy cannot determine Meta's or WhatsApp's independent retention periods. Hosting and Technical Infrastructure Operational information may also be processed on infrastructure used to host and operate WATranslate. Server logs, backups or infrastructure-level information may be subject to separate technical retention procedures operated by the relevant hosting provider. Before production use, these procedures should be reviewed and aligned with the final WATranslate retention policy. Purpose Limitation Information processed by WATranslate is intended specifically for: • Receiving WhatsApp communications • Detecting message language • Translating messages • Allowing agents to communicate with users who speak different languages • Delivering approved replies through WhatsApp • Maintaining short-term conversation context • Technical troubleshooting and security The current supported languages are: German Russian English Spanish Conversation information is not intended to be maintained by WATranslate as a permanent customer-message archive. Review Before Production Before WATranslate is placed into production, the operator should review and confirm: • Final data-retention period • Actual automatic-deletion implementation • Database deletion procedures • Server and hosting logs • Backup retention • Google Cloud configuration • Meta / WhatsApp processing arrangements • Data-processing agreements • International data-transfer requirements • Controller identity and contact details • Data-subject request procedures • Applicable GDPR and other legal requirements This document must then be updated to describe the final production configuration accurately.