Privacy Policy

QuickReplyCY is a trading name of E.S.E Milimanou Digital Solutions Ltd, registered in Cyprus ("we", "us"). This policy explains how we collect and use personal data, and your rights under the General Data Protection Regulation (GDPR).

Who this policy covers

We handle personal data in two different roles:

• As a data controller - for visitors to our website, people who contact us, and our clients. This is data we collect for our own business.
• As a data processor - for our clients' customers. When we send messages (SMS, WhatsApp, email) to a client's customers on that client's behalf, the client remains the data controller and we process the data only on their instructions.

Most of this policy covers the first role. The section "When we act as a processor" covers the second.

Data we collect

When you visit our website:

• Technical data such as IP address, browser type, and pages visited
• Cookie data as described in the Cookies section

When you contact us or fill in a form:

• Name, business name, email address, and phone number
• Anything you include in your message

When you become a client:

• Contact and billing details
• Details about your business needed to set up your service
• Records of our communication with you

We do not knowingly collect data from anyone under 18, and our services are directed at businesses.

How we use your data

• To respond to enquiries and provide our services
• To set up, run, and support your systems
• To send invoices and manage payments
• To send you service-related messages
• To improve our website and services

Legal bases: performance of a contract (providing services you signed up for), legitimate interests (responding to enquiries, improving our services, limited marketing to business contacts), and legal obligations (tax and accounting records). Where we rely on consent, you can withdraw it at any time.

Marketing

If you have enquired about or used our services, we may occasionally contact you about relevant services. Every marketing message includes a way to opt out, and we stop immediately when you ask.

When we act as a processor

When our systems send messages to a client's customers:

• The client is the data controller of their customer data
• We process names, phone numbers, email addresses, and conversation history only to deliver the agreed service
• We act only on the client's documented instructions
• We do not use client customer data for our own purposes or share it with anyone except the service providers needed to deliver messages
• Opt-out requests are honored automatically
• When a client's subscription ends, we return or delete their customer data on request

If you are a customer of one of our clients and have questions about how your data is used, please contact that business directly - they control the data and we assist them.

Who we share data with

We use trusted service providers to run our business:

• HighLevel (LeadConnector) - CRM, website, and messaging platform
• Twilio and telecom carriers - SMS delivery
• Google - email, analytics, and business tools
• Meta Platforms - where messaging or advertising involves Meta services
• Stripe - payment processing

These providers process data under contracts that require them to protect it. We do not sell personal data to anyone.

International transfers

Some of our providers are based outside the European Economic Area, including in the United States. Where data is transferred outside the EEA, we rely on safeguards recognized under the GDPR, such as the EU-US Data Privacy Framework or Standard Contractual Clauses.

How long we keep data

• Enquiry data: up to 2 years after our last contact
• Client account and service data: for the duration of the service and up to 6 years afterwards where needed for legal, tax, or accounting purposes
• Client customer data processed on a client's behalf: for the duration of the client's subscription, then returned or deleted on request

We delete or anonymize data when it is no longer needed.

Your rights

Under the GDPR you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to processing
• Receive your data in a portable format
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We respond within one month.

You also have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus (dataprotection.gov.cy) or your local supervisory authority.

Cookies

Our website uses cookies that are necessary for it to function, and may use analytics cookies to understand how the site is used. You can control cookies through your browser settings. Where required, we ask for your consent before setting non-essential cookies.

Security

We take reasonable technical and organizational measures to protect personal data, including access controls and reputable service providers. No online service can guarantee absolute security, but we work to protect your data appropriately.

Updates

We may update this policy from time to time. The date of the latest version is shown above.

Contact

QuickReplyCY (E.S.E Milimanou Digital Solutions Ltd)
[email protected]