Privacy Policy

1. Data controller

The controller of personal data collected on http://trtwhats.com and through the trtWhats platform is TRT Digital, a company incorporated under Moroccan law, Casablanca, Maroc, ICE 002143944000008, RC 420807. For any question about your data, write to [to be completed].

This policy is issued under Moroccan Law No. 09-08 on the protection of individuals with regard to the processing of personal data, its implementing decree and the decisions of the National Commission for the Control of Personal Data Protection (CNDP). Our processing operations have been notified to the CNDP under reference [to be completed].

2. Data we collect

Website visitors. Technical browsing data (IP address, device and browser type, pages viewed, timestamps) and, subject to your consent, the analytics and advertising data described in our Cookie Policy.

Prospects (forms and WhatsApp). Name, WhatsApp number, e-mail address where provided, business type, company size and country, the content of your enquiry, and marketing attribution data: UTM parameters, ad click identifiers (gclid, fbclid, ttclid) and the landing page. This data comes directly from you or from the campaign through which you found us.

Platform customers. Identification and contact details of users (name, e-mail, phone, role), billing data, business documents supplied to Meta for verification, and login and usage logs.

Data processed on behalf of our customers. In providing the service we process the WhatsApp numbers, names, message content, attachments, order and invoice statuses of our customers' contacts. For this data our customer is the controller and we act as processor, on its documented instructions. Each customer remains responsible for the lawfulness of collection (including obtaining WhatsApp opt-in) and for informing its own contacts.

We do not knowingly collect data relating to minors or sensitive data within the meaning of Law 09-08.

3. Purposes and legal bases

4. Retention periods

• Prospect data: three (3) years from the last contact, then deletion or anonymisation.
• Customer account data: for the term of the subscription, then three (3) years for evidentiary purposes.
• Data processed on behalf of customers: for the term of the contract, then deletion or return within ninety (90) days of the end of the service, unless the customer instructs otherwise or the law requires retention.
• Accounting records and invoices: ten (10) years under Moroccan commercial and tax legislation.
• Technical and security logs: twelve (12) months at most.
• Cookies: the periods stated in the Cookie Policy.

5. Hosting and sub-processors

Platform data is hosted on our servers located in the European Union with Hetzner Online GmbH (Union européenne). To deliver WhatsApp messages we use Meta Platforms' WhatsApp Cloud API; Meta acts as a processor for transmission and the data then passes through Meta's infrastructure under Meta's own terms and data processing commitments.

Strictly where necessary we also rely on providers in the following categories: hosting and infrastructure, transactional e-mail delivery, customer relationship management (CRM) tooling, analytics and advertising platforms (only with your consent), payment processing, and support tooling. Each is bound by a contract containing confidentiality and security obligations. An up-to-date list of sub-processors is available on request from [to be completed].

We do not sell or rent your data. We may disclose it to public authorities where the law requires.

6. International transfers

Hosting in the European Union and the use of Meta's services involve transferring data outside Morocco. Such transfers are carried out in accordance with the provisions of Law 09-08 on transfers abroad, to countries recognised as providing an adequate level of protection or under the authorisations and contractual safeguards required by the CNDP. For data processed on behalf of our customers, these safeguards are described in the data processing agreement (DPA) available on request.

7. Your rights

Under Law 09-08 you have the right to access your data, the right to have inaccurate or incomplete data rectified, the right to object on legitimate grounds to its processing, and the right to object, free of charge and without giving reasons, to the use of your data for direct marketing. You may withdraw your consent at any time without affecting the lawfulness of processing carried out beforehand.

To exercise your rights, send your request to [to be completed] or by post to TRT Digital, Casablanca, Maroc, enclosing proof of identity. We reply within thirty (30) days at most. If you are a contact of a business that uses trtWhats, please address your request to that business; we will assist it in responding.

You may also lodge a complaint with the CNDP (www.cndp.ma).

8. Visitors in the European Union

If you are located in the European Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR) may apply. In addition to the rights above, you then have the rights to erasure, to restriction of processing and to data portability, and the right to lodge a complaint with your supervisory authority. The legal bases listed in section 3 correspond to those set out in Article 6 GDPR.

9. Security

We apply appropriate technical and organisational measures: encryption in transit (TLS) and at rest, role-based access control and strong authentication, isolation of each customer's data, access logging, encrypted backups, regular security updates and staff awareness. In the event of a data breach likely to affect your rights, we will inform you and the CNDP as required by law.

10. Cookies

The use of cookies and trackers on our website, and how to manage your choices through the "Cookie settings" link in the footer, are described in our Cookie Policy.

11. Changes

We may update this policy to reflect legal developments or changes to our services. The date of the last update appears at the top of the page; material changes are brought to your attention by a notice on the website or by e-mail.

12. Contact

TRT Digital — Casablanca, Maroc — Data protection officer: [to be completed] — General contact: [to be completed] — WhatsApp: +212684496060.