Privacy Policy
1. Who this policy is for
This policy explains how Answr Global Limited ("Answr", "we") handles personal data when you interact with a WhatsApp concierge service that Answr operates on behalf of a clinic. For your enquiry and booking data, the clinic is the data controller and Answr is the data processor acting on the clinic's instructions. The clinic's own privacy notice governs how it uses your data after hand-off. This policy covers Answr's own processing and our website.
2. What we collect
- Identifiers: your WhatsApp phone number, name (if you give it).
- Conversation content: the messages you send, including any photos, voice notes or videos you choose to share, and details about the procedure you are enquiring about. Photos and health-related details are special-category data (health) under UK/EU GDPR.
- Booking & logistics: appointment dates, travel details, deposit/payment status. We do not collect or store your card or full payment details.
- Technical: message timestamps and delivery metadata from WhatsApp.
We do not access or hold clinical/medical records, and we do not provide medical advice. See our service boundary at hello@answrglobal.com on request.
3. Why we process it, and our lawful basis
| Purpose | Lawful basis |
|---|---|
| Respond to your enquiry, qualify, quote, book | Contract / legitimate interests; explicit consent for any health data (Art 9(2)(a)) |
| Process photos you send to prepare a quote | Explicit consent (Art 9(2)(a)) |
| Send you follow-up messages about your enquiry | Consent / legitimate interests |
| Keep records for the clinic | Clinic's controller basis; Answr processes on instruction |
You can withdraw consent at any time by replying STOP or messaging hello@answrglobal.com.
4. Automated processing & AI disclosure
Your messages are handled by an AI assistant (we tell you this at the start of the chat, per the EU AI Act). The AI drafts replies, prepares quote estimates and schedules bookings. It does not make a medical diagnosis. A human at the clinic reviews quotes and clinical matters. You can ask to speak to a human at any time.
5. Who we share it with (sub-processors)
We use these processors strictly to deliver the service:
- Meta Platforms — WhatsApp Business Cloud API (message delivery)
- 360dialog — WhatsApp Business Solution Provider
- Anthropic — language model (reply generation)
- Google — Gemini (photo/voice understanding)
- Groq — voice-note transcription
- Supabase — database hosting
We share your data with the clinic you enquired with. We do not sell your data.
6. International transfers
Your data may be transferred to the clinic in Türkiye. Such transfers rely on appropriate safeguards including Standard Contractual Clauses or equivalent mechanisms under UK GDPR and the Turkish KVKK framework.
7. Retention
We keep your enquiry data only as long as needed for the clinic to serve you and to meet legal obligations, then delete or anonymise it. Default Answr-side retention: 24 months from last contact, unless the clinic instructs a shorter or longer period. On clinic off-boarding, data is deleted or returned.
8. Your rights
Under UK/EU GDPR you have the right to: access, rectification, erasure, restriction, portability, objection, and the right to withdraw consent. To exercise these rights, contact the clinic (as data controller) or email hello@answrglobal.com and we will assist as processor. You can also complain to the ICO (ico.org.uk) or your local supervisory authority.
9. Security
We implement PII redaction in logs, encrypted transport (TLS), access controls, and authenticated infrastructure. For a security summary, contact hello@answrglobal.com.
10. Changes to this policy
We may update this policy; the effective date at the top of this page shows when it was last revised. Material changes will be communicated via our service channels.