Data Processing & Security Addendum (DPSA)
Last updated: 16 October 2026 · Version 1.0
Download PDFThis Standard explains how BobOffice, LLC, operator of ChatSales ("ChatSales", "we"), protects the personal data that our customers process through the ChatSales platform, the security measures we apply, and the data protection laws our practices are designed to support. It applies to all ChatSales customers.
1. Scope
This Standard covers personal data in customer accounts on ChatSales: contacts, conversations, funnels, broadcasts, forms and AI knowledge sources, together with the data of customer users. It complements our Privacy Notice and Terms of Service.
2. Our role
For the contacts and conversations in a customer's account, the customer is the controller and ChatSales is the processor (or service provider / data intermediary / encargado / operador, depending on the law). We process that data only to provide the service and on the customer's instructions. We never sell or share customer data for advertising. ChatSales is the controller only for its own account, billing, security and product-usage data.
3. Data protection principles
We apply the internationally recognised principles: lawfulness and transparency; purpose limitation (only to provide the service); data minimisation; accuracy (customers can edit and delete data at any time); storage limitation (deletion when the service ends); integrity and confidentiality (Section 5); and accountability (documented measures and this Standard).
4. Data we process
Names, phone numbers, email addresses, profile names and pictures provided by messaging channels; message content (text, images, audio, video, documents); tags, notes, funnel stage, deal values and custom fields; form responses; advertising referral data (ad ID and title); and account and usage data of customer users. The service is not designed for special-category or sensitive data.
5. Security standard
Encryption: TLS 1.2 or higher in transit; AES-256 or equivalent at rest.
Access control: role-based access with least privilege, unique accounts, multi-factor authentication for administrative access, prompt revocation on role change.
Network and application: firewalls, network segmentation, DDoS protection and rate limiting; secure development, dependency patching, automated scanning and periodic vulnerability assessments.
Resilience: backups, monitoring and an incident response process with defined roles.
People: confidentiality obligations for all personnel with access to personal data; security policies reviewed at least annually.
5.1 Database and hosting on Amazon Web Services (AWS)
Customer data, including the database and stored messages and media, is hosted on Amazon Web Services. AWS operates its data centres and infrastructure under the following independently audited certifications and attestations (AWS's own, published at aws.amazon.com/compliance):
| Certification | What it covers |
|---|---|
| ISO/IEC 27001 | Information security management |
| ISO/IEC 27017 | Cloud security controls |
| ISO/IEC 27018 | Protection of personal data in the cloud |
| ISO/IEC 27701 | Privacy information management |
| SOC 1, SOC 2 Type II, SOC 3 | Independent audits of security, availability and confidentiality controls |
| PCI DSS Level 1 | Payment card data security |
| CSA STAR | Cloud Security Alliance assurance |
Under AWS's shared responsibility model, AWS secures the cloud infrastructure (data centres, hardware, network and virtualisation), and the platform secures what runs on it (access, encryption configuration, application and data). AWS data centres include physical access controls, 24/7 surveillance, and environmental and power protections.
6. Who sees what inside your account
Each person has their own user. Customers assign roles (Admin, Editor, Agent) and individual permissions. With "Access to all chats" turned off, an agent only sees the chats assigned to them. Customers also control who can see all contacts or export them, so their database stays protected if someone leaves the team.
7. Messaging channels and AI
WhatsApp API connections use Meta's official WhatsApp Business Platform; Meta's message fees are paid by the customer directly to Meta. AI-assisted replies run only where the customer enables them, using the customer's own knowledge sources; data sent to our AI model provider through its API is not used to train its models.
8. Security incidents
If a security incident affects a customer's personal data, we notify the customer without undue delay and within 72 hours of becoming aware, with the nature of the incident, data and people affected, likely consequences, measures taken and a contact point, and we support the customer's own notifications to authorities and individuals.
9. Rights of individuals
Customers can view, edit, export and delete contacts directly in the product, and we assist with requests for access, rectification, erasure, restriction, portability, objection and equivalent rights (including ARCO rights in Mexico). Requests we receive directly are forwarded to the customer.
10. International transfers
Data may be processed in the countries listed in Section 12. Where the law requires a transfer mechanism, we use recognised safeguards: the EU Standard Contractual Clauses (2021/914), the UK International Data Transfer Addendum, and the equivalent mechanisms of the other laws in Section 13.
11. Retention and deletion
Customers can export their data at any time. When the service ends, or on request, we delete the customer's personal data within 30 days, including copies held by sub-processors, except where the law requires us to keep it; backups are overwritten in the ordinary course.
12. Sub-processors
| Sub-processor | Service | Location |
|---|---|---|
| Amazon Web Services, Inc. | Database, hosting and storage of messages and media | Hong Kong (ap-east-1) + AWS regions |
| Google LLC (Google Cloud) | Cloud services | Configurable regions / regiones configurables |
| Meta Platforms, Inc. / Meta Platforms Ireland Ltd | WhatsApp Business Platform, Instagram, Messenger | US, Ireland / global |
| OpenAI, L.L.C. | AI model for AI-assisted replies (only when enabled) | US |
| Render Services, Inc. | Hosting of the AI assistant service | US |
| Cloudflare, Inc. | Website, edge security, DDoS protection | Global |
| Stripe, Inc. | Payment processing (billing data only) | US |
We give customers 30 days' notice before adding or replacing a sub-processor; customers may object on reasonable grounds.
13. Laws and frameworks this Standard supports
| Region | Law / framework | How we support it |
|---|---|---|
| European Union / EEA | General Data Protection Regulation (GDPR, EU 2016/679) | Processor terms (Art. 28), EU Standard Contractual Clauses 2021/914 for transfers |
| United Kingdom | UK GDPR and Data Protection Act 2018 | UK International Data Transfer Addendum |
| Switzerland | Federal Act on Data Protection (FADP / nLPD) | SCCs adapted for Swiss transfers |
| United States – California | California Consumer Privacy Act as amended by the CPRA (CCPA/CPRA) | Service-provider terms: no selling or sharing |
| United States – other states | Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA) and other state privacy laws | Processor terms |
| United States – federal | CAN-SPAM Act and TCPA (customer's messaging must have consent) | Opt-in and consent required for outbound messages |
| Canada | Personal Information Protection and Electronic Documents Act (PIPEDA) | Accountability and safeguards for service providers |
| Mexico | Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP) | Encargado obligations, ARCO rights |
| Brazil | Lei Geral de Proteção de Dados (LGPD) | Operador obligations, ANPD standard clauses for transfers |
| Argentina | Ley 25.326 de Protección de los Datos Personales | Processor safeguards |
| Colombia | Ley 1581 de 2012 (Habeas Data) | Encargado obligations |
| Chile | Ley 19.628 and Ley 21.719 (data protection reform) | Processor safeguards |
| Peru | Ley 29733 de Protección de Datos Personales | Encargado obligations |
| Singapore | Personal Data Protection Act 2012 (PDPA) | Data intermediary obligations, 3-day notification support |
| Malaysia | Personal Data Protection Act 2010 (PDPA) and 2024 amendments | Data processor obligations, breach notification support |
| Hong Kong | Personal Data (Privacy) Ordinance (PDPO, Cap. 486) | Data processor safeguards |
| Philippines | Data Privacy Act of 2012 (RA 10173) | Personal information processor obligations |
| Indonesia | Personal Data Protection Law (UU PDP No. 27/2022) | Processor obligations |
| Thailand | Personal Data Protection Act B.E. 2562 (PDPA) | Data processor obligations |
| Japan | Act on the Protection of Personal Information (APPI) | Entrustee safeguards |
| Australia | Privacy Act 1988 and Australian Privacy Principles (APPs) | APP 8 cross-border safeguards |
| United Arab Emirates | Federal Decree-Law No. 45 of 2021 (PDPL) | Processor obligations |
ChatSales does not hold its own certification under these laws; our practices and contracts are designed to support customers' compliance with them. AWS certifications are AWS's own.
14. Customer responsibilities
Customers are responsible for having a lawful basis and any required consent (opt-in) for the contacts they upload and the messages they send, for following WhatsApp and Meta policies, for configuring user permissions, and for their own privacy notice to their customers.
15. Contracts available on request
When a customer decides to proceed, we sign: a Data Processing Agreement (with the EU Standard Contractual Clauses and the jurisdiction-specific terms above), a Mutual Non-Disclosure Agreement, and a confidentiality letter addressed to the customer's company. We also complete security questionnaires. Request them at info@chatsales.app.
16. Contact
BobOffice, LLC (ChatSales) · privacy and security: info@chatsales.app · WhatsApp +1 302 314 2292 · trust.chatsales.app
This Standard describes our practices and may be updated; the current version is published at trust.chatsales.app. Where a signed agreement exists with a customer, that agreement prevails.