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Personal Data Processing Agreement

This agreement supplements the VABI Terms and Conditions and applies to the archive features of the Pro plans (the group archive and the archive of followed conversations).

1. Parties and roles
The customer (the holder of the VABI account) is the controller within the meaning of Regulation (EU) 2016/679 (GDPR). Robomarketing SRL (J51/340/2019, CUI 40838015) is the processor within the meaning of Article 28 GDPR.
2. Subject matter, nature and purpose of the processing
Robomarketing SRL stores, displays, searches, exports and deletes the text of the messages in the groups and conversations the customer follows. The purpose is set by the customer. Robomarketing SRL does not use this data for its own purposes and does not use it to train any model.
3. Duration
The processing lasts as long as the customer uses the archive features, within the retention period chosen by the customer, and ends as described in section 7.
4. Categories of data and of data subjects

Data: the text of the messages and captions, the time of the messages, the WhatsApp identifiers of the authors (phone number or identifier), the display name, mentions and quoted messages. For photos and files, only their type, without the content.

Data subjects: the members of the followed groups, the people in the followed conversations and the representatives of the customer.

5. Instructions of the customer
Robomarketing SRL processes the data only on the documented instructions of the customer. The settings in the VABI account (what you follow, the retention period, export, deletion) are these instructions. If Robomarketing SRL considers that an instruction infringes the GDPR or other data protection provisions, it informs the customer immediately and may suspend carrying it out until the customer confirms it in writing or changes it.
6. Confidentiality and security

The people who have access to the data are bound by confidentiality. Robomarketing SRL applies technical and organisational measures appropriate to the risk, including:

  • in the application, the archive is visible only to the account holder; not even administrators who enter the account to provide support can read it;
  • direct technical access to the database is limited to the people who administer the platform and is used only for maintenance and incidents;
  • connections to the platform are encrypted;
  • the archive features do not write the text of the messages to technical logs;
  • data is deleted automatically when the retention period expires.

The data is hosted by Romarg, in Romania, and is not transferred outside the European Economic Area. Robomarketing SRL notifies you of any security breach affecting this data without undue delay, within 48 hours of becoming aware of it at the latest.

7. Deletion at the end

When you stop following, messages are deleted as they exceed the retention period, and whatever remains is deleted 30 days after you stopped, unless you delete it earlier. When the Pro plan is lost or the subscription ends, the archive is deleted within 30 days at most.

During this interval, the customer chooses: retrieve the data through export (CSV or JSON) or ask for immediate deletion. On request, Robomarketing SRL confirms the deletion in writing.

Backups of the platform are made automatically every day and kept for 3 days. Deleted data also disappears from them within 3 days at most.

8. Acceptance
The customer accepts this agreement when starting the first archive feature: through the confirmation in the activation wizard, for groups, and by starting to follow, for conversations.
9. Governing law
The law chosen in the VABI Terms and Conditions applies.

In force from 3 October 2026.