Privacy Policy

Last updated: September 30, 2026

This policy explains how SIGARNET S.A.S. ("SIGARNET", "we", "us") processes personal data in Sigar, our business management software, and in its integrations with other platforms.

Today Sigar integrates with Meta: WhatsApp, Messenger, Instagram, Facebook Pages, Lead Ads and ad metrics. We are preparing integrations with Google Business Profile and TikTok. Many Sigar features only work if the business that uses Sigar turns them on: for example, the artificial intelligence features (section 4), WhatsApp marketing campaigns (section 11) or sales reporting to Meta (section 6.3); when that is the case, we say so. Where something is not in operation yet, we mark it as In preparation. On Meta, Google and TikTok, the app through which Sigar connects is called "Sigar" (Integrations).

1. Who is responsible for your data

SIGARNET S.A.S. · Argentine tax ID (CUIT) 30-71898317-3 · Donado 1860 PB, C1430 Ciudad Autónoma de Buenos Aires, Argentina · info@sigar.net.

Data is stored in Sigar's databases, which SIGARNET manages, on Amazon Web Services servers (section 6.2).

• Data of each business's customers. The businesses that use Sigar ("client businesses") connect their own accounts and decide what they use the conversations, leads and other data of their customers for. Each client business is the controller of that data (in Argentine law, the responsable). SIGARNET acts as its processor (encargado del tratamiento, section 25 of Law 25,326), also called a service provider or technology provider: it processes the data only on behalf of that business, following its instructions and our Terms of Service, and it keeps the data of each business separate. Depending on what it agrees with each business, SIGARNET provides Sigar for the business's own staff to use or, in addition, handles the business's conversations on its behalf with SIGARNET staff; in both cases, it acts on behalf of the business and following its instructions.
• SIGARNET's own data. SIGARNET is the controller of the data of the people who use Sigar (the staff of each client business), of its own customers and business contacts, and of people who write directly to it.
• If you wrote to a business that uses Sigar, you can exercise your rights with that business or with us (section 10). Each business may also have its own privacy notice, which explains how it uses your data.

2. Data we process

2.1 Data of Sigar users

Name, email address, company and role; username and permissions; login, session and device-verification records; and the actions each user takes in Sigar (for example, who answered a message, who approved a post or who confirmed a marketing campaign).

• If the business uses team features in the inbox: each person's groups, the conversations assigned to them and when they were online.
• If the business uses the service metrics: how long each reply took and where it was sent from (the panel, the phone or another system) and, for replies from the panel, who replied.
• If a person turns on notifications on their phone: the data of that device that their browser provides so that notifications can be sent to it (an address and its keys, which we store encrypted, and the device type, for example "Android · Chrome") and a record of the notifications sent.

2.2 Data we receive from Meta

We only receive data from the assets that each client business connects (Facebook Pages, Instagram accounts, WhatsApp numbers, ad accounts and lead forms), and only with the permissions it grants. We do not ask for or store passwords of Meta accounts.

WhatsApp Business (Cloud API)

• About the person who talks to the business: their phone number, or the identifier WhatsApp provides when the person does not show their number; their profile name and username, if they have one; the content of the messages they send and receive (text, images, audio, video, documents, stickers, locations, contacts, reactions, button replies, orders placed from the business's catalog and answers to its WhatsApp forms); and the status of each message (sent, delivered, read or failed), with its billing category.
• If the person changes their WhatsApp number and WhatsApp notifies us, their record moves to the new number and we keep the previous one in it, so that the conversation stays in the same place, unless that number is already another contact of the business: in that case both records remain and the change is noted in the first one.
• If the person chooses in WhatsApp to stop receiving marketing messages from the business, or to receive them again, and WhatsApp notifies us, that choice (section 11).
• If the business uses the WhatsApp Business app on its phone together with Sigar, also the messages it sends from the phone and the notifications of messages that are deleted or edited (see "Deleted or edited messages" below).
• About the business account: phone numbers, display name, quality rating, messaging limits, Meta's notices about the account, the status of the connection with the phone app, message templates (which the business creates and deletes from Sigar or from Meta's WhatsApp Manager), and usage and cost reports.
• WhatsApp does not give us people's profile pictures.

Messenger (Facebook Pages)

• The person's page-scoped ID, name and profile picture (only of people who write to the page).
• Messages and their attachments, reactions to messages (when Meta reports them), and delivery and read status.
• When Meta sends them to us, also the messages that arrive while another app is handling the conversation (for example, another company's bot or the Meta Business Suite inbox). We do not notify the business's management system of those messages, so that no automated reply answers on top of the other app.
• At the request of the business, the history of earlier conversations that Meta provides through its API.

Instagram (professional account)

• The ID, username, name and profile picture of people who write to the account.
• Direct messages and their attachments, reactions to messages (when Meta reports them), story replies and story mentions; when Meta sends them to us, also those that arrive while another app is handling the conversation (as in Messenger).
• The notifications of messages that are unsent (see "Deleted or edited messages" below).
• At the request of the business, the history of earlier conversations that Meta provides through its API.
• We do not store the content of stories or the image or video of a shared post: only the link.

Comments on posts

• For new comments on the posts of the business's Facebook Page and Instagram account: the text, and the ID and name of the person who comments.
• If the business turns on comment moderation: what its staff do with each comment from Sigar (reply publicly or privately, hide, unhide, "like" or delete), who did it and when. That record does not keep the text of the comment.

Source of each inquiry

• When a person writes from an ad, a post, a link or a QR code, or from the button of a Facebook Page, Meta tells us where they came from: the type of source, and the ID and title of the ad or post. If this feature is turned on, Sigar stores that source with the inquiry, together with the time of the business's first reply.

Reactions and "likes" on Facebook posts

• For reactions ("Like", "Love" and the others) to the posts of the business's Facebook Page and to their comments: the type of reaction, which post or comment it is on, when it was made and whether it was removed.
• About the person who reacted, we only store a fingerprint of their ID: a code calculated with a secret key, which does not show the ID or the name. If that person commented on a post of the Page (and is therefore already a contact of the business in Sigar) or comments on one later, the reaction is linked to their record; if they only wrote to the Page on Messenger, it is not linked. A reaction never creates a contact.
• Instagram does not report who likes a post: we do not store reactions to Instagram posts.

Deleted or edited messages

• When the person unsends a message on Instagram, or deletes it on WhatsApp on a number that the business also uses with the WhatsApp Business phone app, Meta notifies us and in Sigar that message becomes "Message deleted": we delete its text and attachments, and we strike out its content in the technical copies of notifications. The same happens when the business deletes a message from the phone or from a Meta app.
• When the person edits a message on WhatsApp, on those same numbers, and WhatsApp sends us the new text, Sigar stores it over the original message, without the previous one, as WhatsApp does; the technical copy of the original message's notification is deleted automatically after 90 days. Today WhatsApp reports many edits without the new text: in that case the message stays as it was and an "Edited a message" notice is added to the conversation.
• For each deleted message we keep a record without its content (section 8).

Lead Ads

• The answers the person gives in the business's lead form (usually name, email address, phone number and the form's questions) and the date.
• The IDs of the form, ad, ad set and campaign; the platform (Facebook or Instagram); and whether the lead came without a paid ad.

Meta ads

• Name, status, objective, budget and dates of campaigns, ad sets and ads, and their daily results (spend, impressions, reach, clicks and other actions). These figures do not identify people. Sigar only reads them: it does not create or change ads.

Connection with Meta

• The IDs of the business portfolio and of the connected assets, the permissions granted, and the access tokens of that business.
• If the business connects from Sigar with "Connect with Meta": the ID of the Meta user who authorized the connection, who on its staff started it, how each attempt ended, and the picture of its Facebook Page and its Instagram account.
• If we set up an auxiliary Meta app for a business (for example, to receive only that business's WhatsApp notifications), that app may have a different name, and this policy applies in the same way.

2.3 Google Business Profile data In preparation

Today Sigar does not receive any data from Google. A client business will be able to connect its Google Business Profile in two ways: by adding our integration account as a manager of its profile, after authorizing us in writing, or, later on, by signing in with its own Google account. In both cases, Sigar accesses it with Google's permission to manage business profiles. Once it is connected, we will receive:

• the profile's reviews: text, rating, dates and the reviewer's name, or whether the review is anonymous. We do not store the reviewer's photo; for photos attached to a review, only how many there are and their link;
• the average rating and the number of reviews;
• location data: name, address, and Maps and review links;
• profile metrics (for example, views and actions), which do not identify people.

At the request of an authorized person of the business, Sigar will publish, edit or delete the business's replies to those reviews. Content received from Google is kept for no more than 30 days (section 8) and is used as described in section 13.

2.4 TikTok data In preparation

Today Sigar does not receive any data from TikTok. When a client business connects its TikTok accounts (TikTok API for Business), we will receive:

• the leads from its TikTok lead forms;
• the structure and metrics of its ads, which do not identify people;
• comments on its ads and on its own videos: text, and the ID and name of the person who comments;
• statistics of its account and its posts;
• the videos and photos that the business uploads to Sigar to publish on its account.

We do not download TikTok videos, images or thumbnails. If we later add TikTok direct messages, we will update this policy first.

2.5 Data that businesses enter in Sigar

The data that each business enters in its management system (ERP), such as customers, sales and other records of its activity; the link between a conversation and the customer's record in that system; and opt-outs from marketing messages. SIGARNET processes this data on behalf of the business.

Purchase documents. If the business uses the automatic reading of purchase documents (section 4.1): the file of each document it sends (a PDF or a photo of an invoice, a receipt, a credit note or a union contribution slip), through Sigar's API (for example, from an automation of the business) or from the panel; its original name; how it arrived and who sent it (for example, the phone number or email address of the staff member who sent it); and what the two readers read. A document may contain personal data of the supplier or the customer when they are individuals: name, tax ID (CUIT) and address.

Features that the business turns on. If the business uses them, Sigar also stores what its staff enter or decide in them:

• Team features in the inbox: who each conversation is assigned to, its status, its labels, quick replies, opening hours and the text of the automatic out-of-hours message.
• The business's knowledge for artificial intelligence (section 4.2): texts about the business, such as prices, opening hours or requirements, approved by a person. Sigar does not accept texts with phone numbers, ID numbers or email addresses.
• Sales: those that a person marks in a conversation, with the amount, the currency, the date, a note (which we store encrypted), who marked it and the ad the conversation came from, if it came from one.
• Appointments: the calendar, the day and time, the status (pending, confirmed, cancelled, attended or no-show), an internal note, the result of the confirmation and the reminder, and the history of changes, without texts from the customer.
• Inquiry pipeline: the stage of each inquiry, the estimated value, the next step (free text written by the staff), the reason it was lost and the history of who moved it and when.
• WhatsApp marketing campaigns (broadcasts): the template, who it was sent to and the status of each message, who confirmed it and, if consent was declared, who declared it (section 11).
• Posts: the texts, photos and videos that the staff prepare to publish on the business's Facebook Page and Instagram account, who prepared them and who approved them.
• Unified contact: suggestions that two contacts of the business may be the same person, the merges and splits that its staff decide, with who and when, and their internal notes, which we store encrypted. To look for matches, Sigar does not store the phone number, email address or management-system reference as such: it stores a fingerprint calculated with a secret key that is different for each business, and a partial hint so that the staff can recognize it (for example, the last four digits of the phone number).

2.6 Technical data

Access and error logs of our servers (they include IP addresses and the requested web addresses), and technical copies of the notifications (webhooks) that the platforms send us, which we keep for a short time to process them and to recover from failures. When a message is deleted, its content is also struck out of those copies.

2.7 This website

legal.sigar.net is a read-only website: it does not use cookies, analytics, advertising, forms or third-party resources. The hosting service may log technical data of each visit (such as the IP address, the requested page and the browser) to operate and for security.

3. What we use the data for

• Provide Sigar to each client business: a shared inbox to read and answer WhatsApp, Messenger and Instagram conversations, with the customer's name and picture and a link to their record in the business's management system.
• If the business entrusts it to SIGARNET, handle its conversations on its behalf: SIGARNET staff, each person with their own user, read and answer the messages following the business's instructions.
• Send the business's WhatsApp templates, without sending marketing templates to people who opted out, and show the status of each message.
• Show as "Message deleted" the messages that are deleted on the platform and, if the business has that feature turned on, delete a message from Sigar at the request of an authorized person (section 8).
• Receive the comments on the business's posts so that its staff can handle them.
• Record the reactions to the posts of the business's Facebook Page, to count them and to know which ones were left by people who are already its contacts.
• Show leads in Sigar and email them to the people the business designates.
• Show reports on campaigns and on WhatsApp usage and estimated spend.
• If the business uses the automatic reading of purchase documents, read the purchase documents it sends to pre-fill them in its management system, where a person authorized by the business reviews and approves them (section 4.1).
• Send email alerts about technical problems, for example, a connection that stopped working.
• If the business sets it up, notify its management system of new messages, statuses and leads, with signed notifications that carry only IDs.
• Provide support, keep the service secure, prevent abuse and comply with legal obligations.
• If the business turns on these features:
  • Team features: assign conversations to people or groups, label them, use quick replies and email the team when conversations are waiting for a reply (the email only says how many and since when, without customer data). If the business turns it on, Sigar sends an automatic message, with the text the business wrote, to people who write outside opening hours, except to people who opted out of marketing messages.
  • Artificial intelligence: suggest replies, summarize conversations, transcribe audio messages, answer on its own with what the business approved and suggest texts for posts (section 4.2).
  • Comment moderation: reply publicly or privately, hide, unhide, "like" (on Facebook only) and delete comments on the business's posts, always at the request of a person authorized by the business. Sigar can suggest which comments to hide based on word lists that the business chooses (for example, insults or possible health data), but it does not hide or delete anything on its own.
  • Publishing: publish on the business's Facebook Page and Instagram account what its staff prepare, only once an authorized person approves it, at the time they choose.
  • WhatsApp marketing campaigns: send marketing templates to groups of the business's contacts (section 11).
  • Appointments: schedule appointments from a conversation and, if the business turns it on, send the customer a confirmation and a reminder the day before with "Confirm" and "Cancel" buttons, which change the status of the appointment. The reminder is not sent to people who opted out of marketing messages.
  • Inquiry pipeline: organize inquiries by stage (for example, new, contacted, proposal, won or lost). Each new inquiry enters the first stage on its own; after that, a person moves it.
  • Sales: record the sales of a conversation, show how many sales each ad brought and at what cost and, if the business turns it on, tell Meta which sales came from its ads (section 6.3).
  • Source of each inquiry: show where each inquiry came from (an ad, a post, a link or a QR code), until when to reply on WhatsApp at no cost and how many inquiries each ad brought.
  • Service metrics: calculate how long it takes to reply, how many inquiries are left unanswered and at what times most of them arrive and, if the business asks for it, send it a monthly report by email with numbers only, without its customers' names, phone numbers or texts.
  • Unified contact: suggest to the business which contacts from its different channels may be the same person (see "What we do not do").
  • Phone notifications: notify each staff member who turned them on, on their phone, that a new inquiry arrived or that an inquiry has been waiting for a reply for more than 10 minutes. The notification only says the business, the channel and the type of notification: never the customer's name, phone number or message. They are not sent outside the business's opening hours (if it has not set them, between 9 p.m. and 8 a.m.).
  • Enhanced privacy for health data (section 5).
• In preparation Google: show reviews and metrics and publish the replies that a person of the business approves. TikTok: show leads, comments and statistics; reply to, hide, delete or "like" comments on the business's videos and ads, at the request of a person authorized by the business; and publish the content that a person authorized by the business approves. Artificial intelligence: see section 4.

What we do not do

• We do not sell, rent, license or trade personal data, and we do not buy data about people.
• We do not use one business's data for another business, and we do not combine data of different businesses.
• We do not use the data we receive from the platforms for advertising, or to build or enrich profiles of people for advertising or for our own purposes. Explicit exception: if the business turns on sales reporting to Meta, only to measure its own ads, we send Meta the amount, the currency and the date of the sales that came from those ads and an identifier that Meta already knows; never the name, phone number or email address (section 6.3). We only link a conversation to the customer's record in the business's management system when the business decides so. Marketing messages that a business sends to its own customers are covered by section 11.
• If the business turns on unified contact, Sigar suggests which contacts from its different channels may be the same person, only when the phone number, the email address or the reference in its management system match: never by name or photo, and never across different businesses. Nothing is ever merged automatically: a person of the business confirms or dismisses each suggestion, and can split what was merged. It is only meant to help the business serve its own customers better: it is not used for advertising.
• We do not use it to assess credit or creditworthiness, or to make decisions about anyone's housing, employment, insurance, education, government benefits or immigration status.
• We do not send or publish anything on behalf of a business unless a person authorized by that business decides so (from its staff or, if it entrusted us with handling its conversations, from SIGARNET), or an automated rule that the business turned on and configured beforehand does (for example, the automatic replies with artificial intelligence in section 4.2, the out-of-hours message or the appointment reminder).

We process each platform's data only as described in this policy and according to its rules: the Meta Platform Terms, the Meta Developer Policies, the WhatsApp Business Messaging Policy and the Lead Ads Terms; the Google API Services User Data Policy and the Google Business Profile API policies; and TikTok's terms for developers and advertisers. Data from a lead form is used only as allowed by the privacy notice that the business links in that form.

4. Artificial intelligence

Sigar uses artificial intelligence only in the features in this section, and each of them only works in the businesses that turn it on. The provider is OpenAI and, for the reading of purchase documents, also Amazon Textract, from Amazon Web Services (section 6.2). If a business does not turn any of them on, its messages, comments and other platform data are not sent to any artificial intelligence provider. Separately, the previous system of one client business uses its own artificial intelligence service (section 6.4).

4.1 Automatic reading of purchase documents

A business can enter its purchase documents (invoices, receipts, credit notes and union contribution slips) by sending the file, a PDF or a photo, through Sigar's API or from the panel. This is how it works:

• What is sent and to whom. Sigar sends each file to two services, which read it separately: Amazon Textract, from Amazon Web Services (region us-east-1, United States), which receives the image or, for a PDF with several pages, only the first one, and returns the data it finds (tax ID, date, number, CAE, type and amounts); and OpenAI, which receives the whole file and returns the document's data: about the supplier and the customer (tax ID, name or company name and address), dates, amounts and items. If the supplier or the customer is an individual, that is personal data.
• What for. Only to pre-fill the document in the business's management system. Sigar compares the two readings: it pre-fills what matches or what only one of them read, and leaves empty what does not match.
• Human approval. Nothing goes into the business's accounting on its own: a person authorized by the business, with permission over its purchase documents, looks at each document next to the two readings, completes or corrects what is needed and approves it, or discards it.
• What the providers keep. OpenAI processes the file in the United States and does not use it to train its models. We ask it not to store each request (the option to store it is turned off). What OpenAI and AWS keep on their own, and what they may use it for, is governed by their terms of service.
• Our own adapter. Textract uses an adapter in our AWS account, prepared with real purchase documents, to read Argentine documents better.
• Where it is kept. The file is stored in a private Amazon S3 bucket and the two readings in Sigar's database. They can only be seen through Sigar, with permission over the business's purchase documents. The retention periods are in section 8.

4.2 Copilot and automatic replies in the inbox

A business can turn these features on in its message inbox and when it prepares its posts. Today they cannot be turned on for the client business that carries out health-related activities (section 5).

• Copilot, at a person's request. A person authorized by the business can ask for "Suggest reply" (a draft based on the knowledge the business approved, which shows the sources it used and marks what is missing to be filled in instead of making it up), "Summarize" a conversation or "Transcribe" an audio message. The copilot does not send anything: the draft goes into the text box and the person reviews it, corrects it and decides whether to send it.
• Automatic replies. If the business turns them on (the copilot must also be on), artificial intelligence answers on its own the text messages that arrive through WhatsApp, Messenger and Instagram, using only the knowledge the business approved. Each business chooses how it introduces itself in its first reply in each conversation: if the business chooses so, it says that it is a virtual assistant (for example, "Hi, I'm the virtual assistant of…", which is the default text). If it cannot answer with that knowledge, or the question needs a person, it says that a person from the team will reply and stops answering in that conversation. It does not answer audio, images or comments, nor people who opted out of marketing messages; it does not answer if a person from the team replied in the last 12 hours or paused it in that conversation, nor when the platform no longer allows a reply (in general, 24 hours after the person's last message); and it sends at most 3 replies per hour in each conversation and 50 per day for each business. The business can set hours for it: outside them, it replies when the business opens. A person authorized by the business can pause it in any conversation.
• Texts for posts. When preparing a post, a person can ask for "Suggest text": artificial intelligence proposes a text, variants and hashtags based on the business's knowledge. The post is only published when an authorized person approves it.
• The business's knowledge. These are the texts that the business enters and approves (for example, prices, opening hours or requirements) and its quick replies. Sigar does not accept texts that contain phone numbers, ID numbers or email addresses.
• What is sent to OpenAI. To suggest or to answer: the latest messages of that conversation (up to 20, from the last 30 days; to summarize, up to 60), including audio messages already transcribed, the business's knowledge and, if there is one, the instruction the person wrote. Before sending them, Sigar replaces the customer's name with "Customer" and masks their username and any phone numbers, email addresses, national ID (DNI) numbers, tax IDs (CUIT) and card numbers. Masking is automatic and may miss data written in an unusual way (for example, in words). Deleted messages and messages flagged as possible health data are never sent (section 5). An audio message is transcribed only when a person of the business asks for it, and in that case the whole audio file is sent, unmasked, because a voice cannot be masked; an audio message flagged as possible health data is not transcribed.
• What OpenAI keeps. OpenAI processes these requests in the United States and does not use this data to train its models. We send each request with the option to store it turned off. According to OpenAI's terms for its API, it may keep it for up to 30 days to monitor abuse; whatever it keeps is governed by its terms.
• What we keep. The text of a transcribed audio message, encrypted, together with the message and for as long as the message exists. What artificial intelligence returned (drafts, summaries and suggested texts), encrypted, for 30 days. A record of each request and of each decision of the automatic replies, without the content (what was requested, by whom, when and at what cost), for 180 days. Automatic replies remain in the conversation like any other message.
• Spending cap. The cost of artificial intelligence is included in the service, with a monthly cap for each business; when it is reached, these features stop until the next month (Terms, section 8).
• Quality test. Before turning the copilot on for a business, and with its agreement, we may test it with up to 50 recent conversations of that business, masked in the same way and under the same rules, to see whether the drafts are useful. The report stays on our server, with restricted access, until we evaluate it, and then we delete it.
• Platform data. Data from Meta (WhatsApp, Messenger and Instagram) is used with artificial intelligence only for these features, which the business turned on and sees in Sigar, and never for other purposes. We do not use it to train artificial intelligence models.

4.3 Features in preparation

In preparation We are preparing more features that use artificial intelligence: reply suggestions for Google reviews and for comments, and an assistant that answers questionnaires and can transcribe audio and read images on its own. When a business turns any of them on, the rules in section 4.2 apply and, in addition:

• Human approval. Suggestions are drafts: a person authorized by the business reviews them, corrects them if needed and approves them before they are sent or published. Nothing is published automatically in reviews, comments or posts.
• Minimum data. Each feature receives only the data it needs, for example, the text of the review to be answered.
• Health. Answers to health questionnaires will be processed without artificial intelligence and will not reach its models, logs or summaries; the audio messages of those questionnaires will not be transcribed.
• No training. We do not use your data to train artificial intelligence models, and we only use providers that commit not to use it to train theirs.
• Improvements approved by a person. To improve a business's assistant, artificial intelligence will be able to review that business's past conversations, with names, ID numbers, addresses and phone numbers replaced and without the messages of the health questionnaires, and propose changes. Each change will be approved by a person before it is used.
• Platform data. Data from Google and TikTok will be used with artificial intelligence only for the feature the business asked for and that is shown in Sigar, and never for other purposes.
• Providers. If one of these features uses a provider other than those named in section 6.2, we will name it before turning the feature on, together with what data it receives and in which country it processes it.

5. Health data and other sensitive data

Some client businesses carry out health-related activities. Because of that, their conversations, their forms and the records they enter in their management system may include health data, which Law 25,326 treats as sensitive data (sections 2 and 7). Nobody is obliged to provide sensitive data: providing it is always optional.

• The business that receives that data is its controller and is responsible for obtaining the consent that the law requires.
• In Sigar, that data is used only to provide the service to that business. It is seen by the business's authorized staff. SIGARNET staff see it only for support or security purposes or, if the business entrusted SIGARNET with handling its conversations, to handle them.
• In Sigar, it is not used for advertising and it is not shared with other businesses. Today, for the client business that carries out health-related activities, the artificial intelligence features of the inbox (section 4.2), WhatsApp marketing campaigns, appointment scheduling and sales reporting to Meta cannot be turned on. The reading of purchase documents only receives the documents that the business sends (section 4.1). For the previous system of one client business, see section 6.4.
• In other businesses, if the copilot or the automatic replies are turned on, health data that a person writes in a message may reach OpenAI together with the conversation: the masking in section 4.2 removes the name and the numbers that identify the person, not the rest of the text. Only messages flagged as possible health data are left out (next point).
• Our recommendation: do not write health data or other sensitive data in a chat unless your question needs it. In businesses that use artificial intelligence without enhanced privacy, what you write may reach OpenAI (previous point).
• Enhanced privacy. If a business with health data turns it on, Sigar flags the messages that may contain health data using word lists reviewed by a person (for example, medicines, illnesses or treatments), and a staff member can flag or unflag a message manually. Flagged messages are shown masked: someone with permission reveals them with "View", and that is recorded. Who opens each conversation of that business is also recorded. That record does not keep the content of the messages and is deleted after 2 years. Flagged messages do not reach artificial intelligence, nor the business's management system unless it has that permission. The word lists can be wrong: they do not flag data written in a different way.
• The phone notifications described in section 3 never include the content of messages.
• Our Terms prohibit businesses from asking for health data or other sensitive data in Meta or TikTok lead forms, and from sending health information to TikTok.
• If you sent sensitive data by mistake, you can ask us to delete it (section 10).

6. Who we share data with

We do not sell or rent personal data. We only disclose it to:

6.1 The client business itself

Its authorized staff in Sigar (each person with their own user, only in their business and modules), the people it designates to receive leads by email, the recipients of its technical alerts and, if it sets it up, its management system. If the business connects its management system with other services it chooses to use (for example, invoicing, vehicle tracking or access control services), the necessary data is sent to those services on the business's instructions.

6.2 Providers that process data on our behalf

If we add a provider that receives personal data, we will name it here before we start using it. Client businesses and the platforms can ask us for the current list.

6.3 The platforms

Meta and, once they are active, Google and TikTok process the data that goes through their services according to their own policies. For WhatsApp, Meta processes messages as the business's processor for the Cloud API and keeps them for up to 30 days to provide that service. When a person authorized by the business replies, publishes, moderates a comment or creates a WhatsApp template from Sigar, that content is sent to the relevant platform. To publish a photo or a video, Meta downloads it from our private bucket through a link that expires after 60 minutes.

Sales reporting to Meta. If the business turns it on, when a staff member marks a sale in a conversation that came from a Meta ad (within the 7 days before the sale), Sigar reports it to Meta 15 minutes later, so that Meta can measure which of the business's ads bring sales. Only the amount, the currency, the date and the identifier that Meta already knows are sent: the ID of the ad click on WhatsApp, or the person's ID on the business's Facebook Page or Instagram account. The phone number, email address and name are never sent, not even in encrypted form. Sales that did not come from an ad are not sent. This is the only exception to our not using data for advertising (section 3), and it only serves to measure the business's own ads. Within those 15 minutes the sale can be undone; after that, it stays with Meta, which does not allow those events to be deleted.

6.4 Previous system of one client business

While it completes its move to Sigar's integrations, one client business still handles part of its conversations with a previous system. That system runs partly on SIGARNET's infrastructure (its database is on our Amazon Web Services servers) and uses external conversation automation, WhatsApp messaging, artificial intelligence and database services, with servers outside Argentina (section 6.2). Those conversations may include health data.

At the business's request, we moved to Sigar the Messenger and Instagram conversations that system stored: the messages and the profile name of the person who wrote, without their email or any other data, so the business's team can see them in the same inbox. In Sigar they are kept for the same periods as all other conversations.

The conversations that system has stored since 2017 are still stored and do not have a deletion period yet: we are defining it and will publish it here. That system will be shut down when the move is complete. If you wrote to that business and want to know more or ask for your data to be deleted, write to us (section 10).

6.5 Public authorities

Only when a law or a valid order requires it (section 15).

7. Transfer to the United States

We store and process data on Amazon Web Services servers in the United States (region us-east-1). This means that personal data collected in Argentina is transferred to that country. In addition, Meta and, once they are active, Google and TikTok process data in their own data centers, which may be outside Argentina; the services of the previous system (section 6.4) also process it outside Argentina. OpenAI, in the artificial intelligence features that each business turns on (section 4), processes it in the United States.

The United States is not among the countries that Argentina's data protection authority, the Agencia de Acceso a la Información Pública (AAIP), considers to provide an adequate level of protection. We inform you of this so that you know it before you give us your data. AWS is contractually bound to process the data only according to our instructions and to protect it with security measures.

8. How long we keep data

We keep data while it is needed to provide the service. These are the periods that apply today:

Copies that remain after a deletion. Deleted data may still exist for a limited time in backups, in server logs and records of failed tasks, and in the technical copies of notifications, until each of them expires. When a message is deleted, its content is also struck out of the technical copies of notifications. We do not use those copies to recover deleted data, except to restore the service after a failure; if that happens, we delete the data again.

Deleting a message from Sigar. If the business has this feature turned on, an authorized person can delete a message of a conversation from Sigar, for example, because it contains personal data that was not needed or because the customer asked for it. Its text and attachments are deleted, and its content is struck out of the technical copies of notifications; "Message deleted" remains, with who deleted it and when, together with a record without the content. It cannot be undone and it does not delete the message from WhatsApp, Messenger or Instagram (see the next paragraph).

What we cannot delete. Deleting data in Sigar does not delete it from WhatsApp, Messenger, Instagram, Google or TikTok: the message stays on the person's device and in the business's apps, and for WhatsApp it may remain for up to 30 days on Meta's servers. Nor does it delete sales already reported to Meta (section 6.3), or whatever OpenAI keeps on its own (section 4.2). To delete data from those platforms, use their own tools.

Legal obligations. We only keep data for longer when a law requires it, and in that case we keep only that data and the record of the obligation.

9. Security

These measures apply to Sigar: the management system, its panel and its integrations with the platforms in section 2. The previous system in section 6.4 is being replaced by these integrations.

• Connections with Sigar and with the platforms use HTTPS.
• We verify the signature of every notification Meta sends us, to make sure it comes from Meta.
• In the integrations, the businesses' access tokens are stored encrypted and checked every hour, and secrets are stored in an AWS secrets store. None of them is sent in web addresses or shown to users.
• Attachments and profile pictures are stored in a private Amazon S3 bucket, without public access. Files for posts are given to Meta through a link that expires after 60 minutes.
• We store encrypted the texts of transcribed audio messages, what artificial intelligence returns, the notes of sales and of unified contact, and the data of the devices that receive notifications. Phone notifications travel encrypted and contain no customer data.
• The features that send messages to customers, publish or report something to Meta (automatic replies, the out-of-hours message, appointment confirmations and reminders, marketing campaigns, posts and sales reporting) start turned off and are turned on for each business separately.
• Documents from the automatic reading of purchase documents are stored in a private Amazon S3 bucket and can only be seen through Sigar, with permission over the business's purchase documents.
• Each person signs in with their own user and, except for specific and controlled exceptions, with device verification, and only sees the businesses and modules they are allowed to. Sessions are logged and expire automatically.
• The data of each business is kept separate: Sigar does not show one business the data of another.
• Administrative access to the servers is limited to SIGARNET staff, with SSH keys and a firewall.
• SIGARNET staff with administrative access may see the data only to provide support, for security purposes or at the business's request. People at SIGARNET who access personal data are bound by the duty of confidentiality of section 10 of Law 25,326.

If we detect a security incident that affects personal data, we inform the affected client businesses and take the necessary measures and, when applicable, we also inform the affected people and the authority.

10. Your rights and how to exercise them

What you can ask for

• Access: to know whether we hold data about you, which data, where it came from, what it is used for and who it is disclosed to. It is free every six months (earlier, if you show a legitimate interest), and we answer within 10 calendar days.
• Rectification and update: to correct inaccurate or incomplete data, within 5 business days.
• Deletion: to delete your data, within 5 business days, unless a law requires us to keep it or deleting it would harm the rights of third parties. If we cannot delete something, we tell you what and why.
• Withdraw your consent at any time. This does not affect what was done before.
• To stop receiving marketing messages (section 11).

How to exercise them

• Write to info@sigar.net. No special form is needed.
• Tell us what you are asking for and how to find you: the business you talked to, the channel, and your phone number, profile name or username.
• We may ask you for some information to confirm that the request is yours. We will never ask for passwords.
• You can also make the request directly to the business. If we receive a request about the data of a client business, we pass it on to that business and resolve it together with it.
• Instructions to request deletion, including from Meta, Google and TikTok, are on the Data deletion page.

Giving us your data is voluntary. If you do not give it, or if it is inaccurate, the business may not be able to handle your request. If you live outside Argentina, the law of your country may give you other rights: write to us and we will help you.

If you believe we did not handle your request properly, you can file a complaint with the Agencia de Acceso a la Información Pública (see the footer of this page).

11. Marketing messages

Businesses that use Sigar may send marketing messages, for example, WhatsApp marketing templates. Having each person's consent to receive them is the responsibility of the business that sends them. Our Terms require it to send those messages only to people who agreed to receive them and to offer a way to opt out in each one.

You can opt out, or ask them to remove or block your data for advertising, at any time and by any means: by replying to the message, by telling the business or by writing to us. Sigar records the opt-outs that WhatsApp reports (when it notifies us that the person chose in WhatsApp to stop receiving marketing messages from the business, or when it rejects one for that reason) and those that the business marks, and it stops WhatsApp marketing templates addressed to people who opted out. If WhatsApp later notifies us that the person accepted them again, the opt-out that WhatsApp reported is lifted. If someone opts out by replying to a message or by other means, Sigar does not record it on its own (except in marketing campaigns, as explained below): the business must record and respect it.

WhatsApp marketing campaigns (broadcasts). If the business turns on this feature, it can send an approved WhatsApp marketing template to a group of people who wrote to it on that number. This is how it works:

• It is never sent to people who opted out, even if they opted out after the campaign was scheduled, and never twice to the same number in the same campaign. By default, it is not sent either to people who received another campaign in the last 7 days.
• By default, it is only sent to people whose consent the business recorded. If the business chooses to send it to people who wrote to it without that record, the person who confirms it declares that they agreed to receive marketing messages, and Sigar stores who declared it: that declaration is the business's responsibility.
• Each template must say how to opt out, with a button or with text; otherwise, Sigar does not allow it to be sent. The opt-out is recorded automatically if the person taps that button or if, within 7 days of a campaign, they reply with just a word such as "BAJA" or "STOP". Sigar does not send any automatic reply.
• Before it is sent, a staff member sees how many people it will reach and how much it will cost, sends a test to themselves and confirms it. Nothing is sent without that confirmation. Sigar stores who confirmed each campaign, who it was sent to and whether it was delivered, read or answered.
• It is sent gradually (20 per minute, from 9 a.m. to 9 p.m.) and Sigar stops it on its own if WhatsApp lowers the quality rating of the number, if many messages fail or if many people opt out.

12. When a business stops using Sigar

When a client business ends its relationship with us, or asks us to disconnect a platform or to delete its data:

1. We stop receiving its new data: we disconnect its accounts and the platform stops sending us data from that business.
2. We stop using its access tokens and delete them immediately.
3. Within 30 days we delete that business's data (contacts, conversations, attachments, profile pictures, leads, comments, reactions to posts, records of deleted messages, documents from the automatic reading of purchase documents, reports and the data of the features it turned on, such as transcriptions, knowledge, sales, appointments, marketing campaigns, posts, pipeline and unified contact), unless the business first asks us for a copy or a law requires us to keep part of it. In that case we keep only that part and the record of the obligation.
4. Backups expire as described in section 8.

If the business disconnects only one platform, this applies to that platform's data. If we stop offering Sigar or one of its integrations, we do the same with the data received from that platform.

If the business removes Sigar's access from the platform. The platform stops sending us its data. We check every hour that the connections with Meta are still active; if we detect that a business removed Sigar's access in Meta, we contact it to confirm that it is leaving. In preparation In TikTok, removing Sigar's access counts as a request to leave that platform: we delete the access tokens immediately and the TikTok data within 30 days. In Google Business Profile, Google content is deleted within 30 days at most and, if the business stops using Sigar, within 7 business days we remove our account from its profile so that it regains exclusive control.

13. Google data: Limited Use

Sigar's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

On Google, our app is called "Sigar".

Specifically, with the data we receive from Google:

• we only use it to provide or improve the features that the business sees and uses in Sigar: reading and answering reviews, and viewing the data and metrics of its locations;
• we do not transfer it to third parties, except when needed for those features and with the business's consent (for example, the text of a review to an artificial intelligence provider to suggest a reply, if the business turns that on), for security purposes, to comply with the law, or as part of a merger, acquisition or sale of assets of SIGARNET, after obtaining the business's explicit prior consent;
• nobody at SIGARNET reads it, except with the business's agreement (for example, when it asks us for support), for security purposes or to comply with the law;
• we do not sell it or use it for advertising, to assess credit or creditworthiness, or to build profiles;
• we keep it for no more than 30 days, securely, without aggregating or manipulating it.

To remove Sigar's access or request the deletion of Google data, see Data deletion.

14. Children

Sigar is a tool for businesses and is not directed to minors. If you believe a minor gave us data through a business that uses Sigar, write to us and we will resolve it together with that business.

15. Requests from public authorities

We only disclose personal data to a public authority when a law or a valid order requires us to. We review each request, challenge those that are not appropriate, disclose only what is strictly necessary and, unless the law prohibits it, inform the affected client business.

16. Changes to this policy

We may update this policy. We always publish the current version on this page, with its date. If a change is important, or changes how we use the data received from a platform, we inform the client businesses by email beforehand and, when the platform requires it, we ask for their authorization again. If you need an earlier version, ask us.

17. Contact

SIGARNET S.A.S. · Donado 1860 PB, C1430 Ciudad Autónoma de Buenos Aires, Argentina · info@sigar.net

This English version says the same as the Spanish version. If they differ, the Spanish version prevails.