Chatlyst - Privacy Policy

Last updated: 2026-01-16

1. Introduction

1.1. Effex Technologies Limited (trading as “Chatlyst”) is committed to protecting and respecting your privacy in accordance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”).

1.2. “Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, or (b) defined as “personal data” under the Ordinance.

1.3. This Privacy Policy describes how Chatlyst (referred to as “we”, “our”, “us”) collects, holds, processes, transfers, and uses your Personal Data.

1.4. This Privacy Policy covers Personal Data collected:

Online: When you use our web applications, mobile applications, API integrations, and website (collectively, the “Platform”).

Offline: Through telephone calls, in-person meetings, or events.

1.5. We operate a SaaS platform powered by Generative AI (GenAI) that facilitates omnichannel customer service. This platform connects our Clients (businesses) with their End-Customers through various communication channels (e.g., WhatsApp, Email, Webchat) using AI automation and human agent interfaces (the “Services”).

1.6. This Privacy Policy applies to the Personal Data of:

1.6.1. Visitors: Individuals who visit our website without logging in.

1.6.2. Clients: Businesses or entities subscribing to our SaaS.

1.6.3. Authorized Users: Employees or representatives of Clients who log in to the Platform (e.g., customer service agents, administrators).

1.6.4. End-Customers: Individuals who interact with our Clients via the Chatlyst Platform (e.g., chatting with a Chatlyst-powered AI bot).

1.7. BY ACCESSING OUR WEBSITE OR USING OUR SERVICES, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY.

2. Sources of Personal Data

2.1. We collect and process Personal Data from the following sources:

2.1.1. Provided directly by you: When you register for an account, subscribe to our newsletter, submit a support ticket, or voluntarily enter information into a chat interface.

2.1.2. Generated during usage: Metadata generated when you use the Services, such as IP addresses, login timestamps, and usage patterns of the AI features.

2.1.3. Integrated Channels: Data received from third-party communication channels linked to the Platform (e.g., messages forwarded from WhatsApp Business API, Facebook Messenger, or Email providers).

2.1.4. Third Parties: Information from business partners, sub-processors, or public sources used for identity verification or lead generation.

3. Types of Personal Data Collected

3.1. The Personal Data we collect includes, but is not limited to:

3.1.1. From Visitors:

IP address, browser type, device identifiers, and website usage data (via Cookies).

3.1.2. From Clients and Authorized Users:

Account Data: Name, business email, phone number, company name, job title.

Billing Data: Credit card details (processed via secure payment gateways), billing address, and transaction history.

Technical Data: Login credentials (encrypted), user preferences, and activity logs within the SaaS dashboard.

3.1.3. From End-Customers (interacting with the Platform):

Identity Data: Name, phone number, email address, or social media handle (depending on the channel used).

Conversation Data: Transcripts of chats, emails, and voice interactions processed by the Platform.

Uploaded Content: Files, images, or documents voluntarily uploaded during a support session.

Inferred Data: Sentiment analysis scores, intent classification, and summary data generated by our GenAI models based on the conversation history.

3.2. We only collect Personal Data reasonably necessary for the purposes stated in Section 4.

4. Uses of Personal Data

4.1. We process your Personal Data for the following purposes:

4.1.1. Service Provision and Maintenance:

To register and manage your account.

To process and route customer service messages across different channels (omnichannel routing).

To generate AI responses: We use conversation history to prompt Generative AI models to draft or send responses to End-Customers.

To facilitate payments and billing.

4.1.2. Platform Improvement and R&D:

To train and fine-tune our AI models (subject to data anonymization protocols where applicable) to improve response accuracy.

To analyze usage trends and system performance.

To debug technical issues and prevent service outages.

4.1.3. Communication:

To send administrative notifications (e.g., system updates, maintenance, security alerts).

To provide customer support and resolve disputes.

4.1.4. Security and Legal:

To detect and prevent fraud, spam, or abuse of the Platform.

To comply with legal obligations, including responding to regulatory requests.

4.1.5. Marketing:

To send promotional materials regarding Chatlyst updates and features (subject to your consent).

5. Personal Data Sharing and Disclosure

5.1. To provide our GenAI SaaS Services, we may share Personal Data with:

5.1.1. AI and LLM Providers: We transmit conversation text to third-party Large Language Model (LLM) providers (e.g., OpenAI, Microsoft Azure, Anthropic) to generate AI responses. Note: We implement strict data privacy agreements with these providers to ensure data is not used to train public models without consent.

5.1.2. Cloud Service Providers: For hosting, data storage, and computing power (e.g., AWS, Google Cloud).

5.1.3. Communication Channel Providers: Data must be transmitted to platforms like WhatsApp (Meta), Telegram, or Email providers to deliver messages to End-Customers.

5.1.4. Business Partners: Payment processors (e.g., Stripe), CRM integrators, and analytics providers.

5.1.5. Affiliates: Our parent company or subsidiaries for operational purposes.

5.1.6. Legal and Regulatory Bodies: If required by law, court order, or to protect the rights and safety of Chatlyst and its users.

5.2. We do not sell your Personal Data to third parties.

6. International Transfer of Personal Data

6.1. Chatlyst is a global SaaS platform. Your Personal Data may be transferred to, stored, or processed in countries outside of your location (including servers in the United States, Singapore, or Hong Kong).

6.2. When transferring data, we ensure that the recipient country or entity offers a standard of protection comparable to the protection under the Hong Kong Personal Data (Privacy) Ordinance, typically through contractual clauses or adequate data protection agreements.

7. Security of Personal Data

7.1. We employ industry-standard security measures, including:

Encryption: Data is encrypted in transit (TLS/SSL) and at rest.

Access Controls: Strict role-based access control (RBAC) for our employees.

Regular Audits: Security assessments of our infrastructure and AI models.

7.2. While we strive to protect your data, no method of transmission over the Internet is 100% secure. You acknowledge that you provide Personal Data at your own risk.

8. Retention of Personal Data

8.1. We retain Personal Data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law.

8.2. Client and Authorized User data is retained for the duration of the subscription. 8.3. Conversation logs and End-Customer data are retained according to the Client’s configuration settings or our default retention policy, after which they are deleted or anonymized.

9. Accessing, Correcting, and Erasing Data

9.1. Subject to the Ordinance, you have the right to:

9.1.1. Check if we hold your Personal Data and access a copy of it.

9.1.2. Request correction of inaccurate data.

9.1.3. Request deletion of your Personal Data (subject to legal or operational retention requirements).

9.1.4. Withdraw consent for marketing communications.

9.2. Clients (Data Controllers) are primarily responsible for managing End-Customer data rights. If you are an End-Customer, please contact the business you communicated with directly. If you are a Client, you may exercise these rights via the Platform settings or by contacting us.

10. Cookies

10.1. We use cookies and similar tracking technologies to track activity on our Platform and hold certain information (e.g., session status, language preference). 10.2. You can instruct your browser to refuse all cookies, but some portions of our Service may not function properly without them.

11. Disclaimer on Third-Party Links

11.1. Our Platform may contain links to third-party sites or integrations (e.g., a Client connecting their own CRM). We are not responsible for the privacy practices or content of these third parties.

12. Changes to this Privacy Policy

12.1. We may update this Privacy Policy from time to time to reflect changes in our technology (specifically GenAI capabilities) or legal obligations. 12.2. We will notify you of significant changes via email or a prominent notice on our Platform. Continued use of the Service after changes implies acceptance.

13. Contact Us

13.1. If you have any questions regarding this Privacy Policy or our use of GenAI, please contact our Data Protection Officer:

Email: privacy@chatlyst.io

Company: Effex Technologies Limited

14. Marketing

14.1. We may use your Personal Data to send newsletters, product updates, or event invitations. 14.2. You may opt-out of these communications at any time by clicking the “unsubscribe” link in the email or contacting us directly.

15. Language Versions

15.1. In case of any inconsistencies between the English version and any other language version of this Policy, the English version shall prevail.