Privacy Policy

How EngageOriga and Origa Network LLP handle, protect, and isolate your business and WhatsApp messaging data.

Last updated: October 202610 min read
Section 01

1. Overview & Scope

Welcome to EngageOriga (referred to as "Origa Automation", "we", "us", or "our"), operated by Origa Network LLP. We provide a multi-tenant software-as-a-service platform that empowers businesses to connect their WhatsApp Business accounts to Meta's official WhatsApp Business Platform (Cloud API), coordinate customer inquiries across shared team inboxes, compose and manage approved message templates, and run compliant broadcast campaigns.

This Privacy Policy explains how we collect, store, process, transfer, and protect your information when you visit our website, register for an account, connect your WhatsApp Business credentials via Meta's Embedded Signup flow, or interact with our software applications and APIs.

Core Privacy Guarantee

We never sell, rent, or monetize your contact lists, messages, or metadata to third-party advertisers. Your data remains strictly isolated in your dedicated workspace.

Section 02

2. Data Controller vs. Data Processor Roles

Under applicable data protection legislation—including the European Union General Data Protection Regulation (GDPR), the UK GDPR, and the Digital Personal Data Protection Act, 2023 (India DPDP Act)—the legal designation of data depends on the nature of the information:

EngageOriga as Data Controller

We act as a Data Controller for your account registration credentials, billing details, workspace member profiles, and direct business communications with us. We decide how this administrative data is stored and processed to maintain your subscription.

EngageOriga as Data Processor

You (the business customer) are the Data Controller for your end-customers' WhatsApp phone numbers, chat transcripts, media attachments, and custom attributes. We act exclusively as a Data Processor processing this data strictly on your instructions and in accordance with our Data Processing Terms.

Section 03

3. Information We Collect

We collect information in three primary categories to deliver the EngageOriga platform effectively:

A. Workspace & Authentication Information

  • Business identity: Company name, registered country, website URL, and billing address.
  • Team members: Full names, work email addresses, encrypted passwords, avatar images, and assigned role (Owner or Agent) with per-module permission grants.
  • Payment data: Transaction receipts and subscription tier status. Payment card numbers are processed directly by our PCI-DSS compliant payment gateways and are never stored on our servers.

B. Meta WhatsApp Cloud API Credentials & Metadata

  • Meta IDs: Meta Business Account ID (WABA ID), WhatsApp Phone Number ID, and Business Profile display information.
  • Access Tokens: System user tokens and OAuth access tokens granted via Meta's Embedded Signup flow. All tokens are encrypted at rest using AES-256 and are never exposed in front-end client bundles.
  • Webhook Signatures: HMAC-SHA256 signature verification keys used to validate incoming events from Meta Graph APIs.

C. Customer Messaging Data (Processed on Your Behalf)

  • End-user phone numbers: WhatsApp phone numbers in E.164 standard format and WhatsApp profile names.
  • Message content: Inbound and outbound message text, quick replies, call-to-action button clicks, and media references (images, videos, audio, documents).
  • Delivery receipts: Timestamps for messages sent, delivered, read, and failed, along with Meta error codes where applicable.
  • Templates: Text, headers, variables (e.g. {{1}}), and categories submitted to Meta for approval.
Section 04

4. Meta WhatsApp Business Platform (Cloud API) Integration

Unlike legacy tools or unauthorized third-party mods, EngageOriga connects solely to the official Meta WhatsApp Business Platform (Cloud API) hosted by Meta Platforms, Inc.

Our Meta Platform Commitments
  • No unofficial phone scraping, emulators, or web session hacks.
  • Full compliance with Meta Developer Policies and WhatsApp Terms.
  • All incoming webhooks verified with Meta's SHA-256 secret.
  • Immediate access token revocation upon number disconnection.

When a customer messages your WhatsApp Business number, Meta's servers route the encrypted event to our signed webhook endpoints. Once received, our servers decrypt and render the message within your workspace team inbox. When an agent replies, the message is dispatched to Meta's Cloud API over TLS 1.3 encrypted connections.

Section 05

5. How We Use Information & Legal Bases

We process personal data only when we have a legitimate legal basis under applicable law:

Purpose of ProcessingData ElementsLegal Basis
Shared inbox & live team messagingPhone numbers, message text, media, agent assignment notesPerformance of Contract
Template synchronization & approvalTemplate name, category, language, message variablesPerformance of Contract
Workspace session securityIP addresses, login timestamps, device/browser informationLegitimate Interests
Subscription billingSelected plan, seat count, company billing addressLegal Obligation / Contract
Section 06

6. Security Safeguards & Multi-Tenant Isolation

EngageOriga is architected for multi-tenancy. Every business workspace operates in its own isolated logical environment. There are no shared customer lists, credentials, or message records between distinct tenants.

Isolated by Design

Every SQL query and API route is strictly constrained by workspace ID at the database layer.

AES-256 Token Vault

WhatsApp Cloud API tokens and app secrets are encrypted at rest and never returned in UI responses.

Sanitized Logs

Server and operational telemetry logs are scrubbed to prevent message body or token leakage.

Section 07

7. Third-Party Sub-Processors

To deliver our cloud services, we engage verified third-party infrastructure providers who adhere to rigorous data protection standards:

  • Meta Platforms, Inc. (USA / Ireland): Provides the underlying WhatsApp Cloud API infrastructure, template moderation, and message dispatch.
  • Cloud Hosting & Database Partners: Managed cloud instances providing encrypted storage, Redis caching, and automated backups.
  • Transactional Email Service: Delivers workspace invitations, password resets, and system security alerts.
Section 08

8. Data Retention & Automatic Purging

We retain personal data only for as long as necessary to fulfill the operational purposes described herein, or as required by applicable tax, commercial, and regulatory laws:

  • Active Subscriptions: Workspace conversations, contact lists, and message templates remain stored as long as your workspace is active and in good standing.
  • Disconnected Numbers: When you disconnect a WhatsApp number, access tokens are immediately revoked, and we stop listening to incoming webhooks.
  • Workspace Deletion: If you request deletion of your workspace, all team inbox transcripts, contacts, and custom templates are verified and shredded within 30 days.
  • Statutory Compliance: Invoices, transaction records, and tax filings are retained for up to 7 years in accordance with Indian commercial and GST requirements.

For complete instructions on requesting immediate data removal, refer to our dedicated Data Deletion Instructions.

Section 09

9. Your Privacy Rights (GDPR, India DPDP, CCPA)

Depending on your location, you hold statutory rights regarding your personal information:

Right of Access & Portability:

Request a copy of your personal data and export your contact records in machine-readable JSON or CSV format.

Right to Rectification:

Correct inaccurate or incomplete profile data directly in your workspace settings.

Right to Erasure ("Right to be Forgotten"):

Request deletion of your personal records and WhatsApp conversation history.

Right to Restrict or Object:

Object to processing based on legitimate interests or revoke marketing preferences at any time.

To exercise these rights, submit a request to privacy@engageoriga.com. We respond to all verified inquiries within 30 calendar days.

Section 10

10. Cookies & Session Storage

We use strictly necessary cookies and browser local storage to maintain authenticated user sessions, remember UI sidebar states, and enforce CSRF security tokens. We do not use third-party behavioral tracking cookies for cross-site advertising.

Section 11

11. Contact & Data Protection Officer

If you have questions, feedback, or complaints regarding this Privacy Policy or our data protection safeguards, please contact our Data Protection Officer:

Origa Network LLP

Attn: Privacy & Data Protection Office

Product: EngageOriga (Origa Automation)

Email: privacy@engageoriga.com

General Legal: legal@engageoriga.com

First Floor, AAK Building, HMT Junction, Kalamassery, Kochi, Kerala 683104, India.

Transparency & Trust

Committed to user privacy and enterprise-grade security

EngageOriga is proud to be built natively on Meta's WhatsApp Business Platform Cloud API. We adhere strictly to Meta's developer guidelines and international privacy standards.