Your customers trust you. We take that seriously.

Who we are

Positive Contact is provided by Posicon Ltd (“we”, “us”), registered in the United Kingdom. Our registered address is 11 Old Mill Lane, Portishead, Bristol BS20 7BX.

If you have any question about this policy or your data, email us at privacy@positivecontact.app

Two kinds of people this policy covers

Positive Contact is a business-to-business product, so there are two different groups of people whose data we handle, and it’s worth being upfront about the difference:

• Businesses (“tenants”) who sign up for Positive Contact and their staff who use it day to day. We call these “you” throughout most of this policy.
• Contacts – the customers, and enquirers that a business talks to through Positive Contact. If you’ve received a WhatsApp message, email, or Facebook message from a business using Positive Contact, you’re a contact.

For contacts: the business you’re talking to is the one responsible for how they use your data day to day (things like how long they keep a conversation, or who on their team can see it). Positive Contact provides the platform and processes that data on their behalf. If you want to know what a specific business does with your data, ask them directly.

What we collect

When you sign up as a business

• Your name, email address, and phone number
• Your business name and address
• Your VAT registration status and number (if applicable)
• Payment details (handled directly by our payment processor, Stripe – we never see your full card number)

When your team uses Positive Contact

• Login details and basic profile information for each team member
• Usage information, like which features are used, so we can improve the product

Conversations with your contacts

This is the core of what Positive Contact stores. When one of your contacts messages you – or you message them – by email, WhatsApp, or Messenger, we store:

• The content of the message, and any attachments
• The contact’s name, email address, phone number, or messaging ID (whichever they used to reach you)
• Internal notes, tags, and to-dos your team adds to a conversation
• Metadata such as timestamps and which channel was used

We also generate short summaries of conversations and, where you ask for it, draft reply suggestions, to save your team time. These are generated automatically from the conversation content and are not reviewed by us.

Why we collect it

• To provide the application itself – receiving, storing, and letting your team reply to messages
• To bill you for your subscription
• To generate conversation summaries and reply drafts
• To keep the service secure and prevent abuse or spam
• To understand how Positive Contact is used, so we can improve it
• To contact you about your account, or important changes to the service

Our legal bases for these under UK/EU GDPR are: performance of our contract with you (providing the service you signed up for), our legitimate interests (security, product improvement), and, where relevant, your consent.

WhatsApp and Messenger

Positive Contact sends and receives WhatsApp and Facebook Messenger messages using Meta’s official Cloud API. This means Meta Platforms, Inc. processes message content and metadata as part of delivering these messages, in addition to Positive Contact. Meta’s own privacy policy governs how Meta itself handles that data:

• WhatsApp Privacy Policy: whatsapp.com/legal/privacy-policy
• Meta Privacy Policy: facebook.com/privacy/policy

A few things worth knowing specifically about how we use these platforms:

• Message content sent via WhatsApp or Messenger is transmitted through Meta’s infrastructure and is subject to Meta’s own data handling and retention practices, in addition to ours.
• We only send WhatsApp messages to a contact after they have messaged the business first, or after the business has sent an approved template message (as required by WhatsApp’s rules for businesses).
• We do not use WhatsApp or Messenger conversation content for advertising, and we do not sell contact data to third parties, on any channel.
• Each business using Positive Contact connects its own WhatsApp Business number or Facebook Page; Positive Contact acts as the technical provider that carries messages between that number/page and the shared inbox.
• If a contact blocks a business on WhatsApp or Messenger, or withdraws consent to be messaged, we stop delivering messages to them on that channel.

Who we share data with

We don’t sell your data, or your contacts’ data, to anyone. We do use a small number of specialist companies (“processors”) to run the service, each of whom is only allowed to use the data to provide their service to us:

We have data processing agreements in place with each of these providers, and we choose EU-based providers wherever practical. Where a provider is based outside the UK/EU (for example Meta, Anthropic, or Stripe), we rely on Standard Contractual Clauses or an equivalent recognised safeguard for the transfer.

We may also share data if required by law, to protect our legal rights, or if Positive Contact is ever involved in a merger or acquisition (in which case we’d tell you before any data changes hands).

How long we keep data

• Conversation history: kept indefinitely while your account is active, since Positive Contact is built around ongoing relationships with your contacts rather than one-off tickets that get closed and forgotten.
• Closed accounts: if you cancel your subscription, we keep your data for up to 60 days (in case you want to export it or come back), then permanently delete it.
• Payment records: kept as required by tax and accounting law, generally 6 years.

You can ask us to delete specific data sooner – see “Your rights” below.

Children’s data

Positive Contact is a business tool and is not directed at children. We don’t knowingly collect data directly from children. That said, some businesses using Positive Contact will naturally be in contact with parents about their children, or occasionally receive messages from a young person. Businesses using Positive Contact are responsible for making sure they have an appropriate basis (such as parental consent) for any conversations involving children, in line with their own obligations. If you believe a child has contacted us directly in a way that concerns you, email privacy@positivecontact.app and we’ll look into it.

Security

We store data with reputable, security-focused infrastructure providers, encrypt data in transit, and restrict access to your account to your own team. Attachments are stored privately and only accessible via time-limited links. No system is perfectly secure, but we take reasonable, industry-standard steps to protect your information and will tell you promptly if we ever become aware of a breach affecting your data.

Your rights

If you’re in the UK or EU, data protection law gives you the right to:

• Ask what data we hold about you, and get a copy of it
• Ask us to correct inaccurate data
• Ask us to delete your data (subject to things we’re legally required to keep, like payment records)
• Object to, or ask us to restrict, certain uses of your data
• Ask for your data in a portable format
• Withdraw consent at any time, where we rely on consent
• Complain to your local data protection authority – in the UK, that’s the Information Commissioner’s Office (ico.org.uk)

To exercise any of these, email privacy@positivecontact.app. If you’re a contact of a business using Positive Contact rather than the business itself, we’ll usually need to loop in that business, since they control the conversation – but we’ll help facilitate this.

Cookies and analytics

Our website and product use PostHog to understand how visitors and users interact with Positive Contact, so we can improve it. We don’t use tracking for advertising purposes.

Changes to this policy

We’ll update this policy as Positive Contact evolves. If we make significant changes, we’ll let account holders know by email before they take effect. The “last updated” date at the top always reflects the current version.

Contact us

Posicon Ltd
Email: privacy@positivecontact.app