Privacy Policy

October 15, 2026

This Privacy Policy describes our policies and procedures for collecting, using and disclosing your information when you use the Services, and tells you about your privacy rights and how the law protects you.

We use your personal data to provide and improve services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Explanation and Definition

1.1 Explanation

Capitalized words have the meanings defined by the following conditions. The following definitions shall have the same meaning whether appearing in the singular or the plural.

1.2 Definitions

For the purposes of this Privacy Policy:

• Affiliate Operator means an entity that controls, is controlled by, or is under common control with a party, where "control" means an entity that owns 50% or more of the shares, equity or other rights to vote for directors or other governing bodies ownership of securities.

• Application means an operator-provided software program that you download on any electronic device named Whats Web Plus

• Operator (referred to in this Agreement as "Operator," "us," "us," or "our") means Whats Web Plus.

• Country refers to: China

• Device means any device that can access the Services, such as a computer, cell phone or digital tablet.

• Personal data is any information relating to an identified or identifiable individual.

• Service means an Application.

• Service Provider means any natural or legal person who processes data on behalf of the Operator. Refers to third-party operators or individuals employed by the Operator to facilitate the Service, provide the Service on behalf of the Operator, perform services related to the Service, or assist the Operator in analyzing the use of the Service.

• Usage Data means data that is collected automatically, whether generated through use of the Service or from the Service infrastructure itself (for example, the duration of page visits).

• You mean the individual accessing or using the Services, or the operator or other legal entity (as applicable) accessing or using the Services on behalf of that individual.

• AI Service Provider means a third-party entity that provides artificial intelligence and machine learning services to process data on behalf of the Operator to enable AI-powered features.

• AI-Generated Content means any text, summary, translation, draft reply, customer detail extraction, or other output produced by artificial intelligence systems based on user data.

2. COLLECTION AND USE OF YOUR PERSONAL DATA

2.1 Types of data collected

2.1.1 Personal data

When using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address

• Location

• Usage data

• Additionally, when you use the AI-powered features, we may process the following data:

• Chat messages and conversation content that you save in the App

• Customer briefs, notes, and annotations you create or that are generated by AI

• Product library information including product names, descriptions, and pricing

• Customer details such as name, company, country, budget, and payment preferences

• AI prompts you input when using AI features

2.1.2 Usage data

Usage data is automatically collected when using the Services.

Usage Data may include your device's internet protocol address (e.g. IP address), browser type, browser version, pages of our Services you visit, time and date of your visit, time spent on those pages, unique device, etc. Information identifiers and other diagnostic data.

When you access the Services through or through your mobile device, we may automatically collect certain information, including but not limited to the type of mobile device you use, your mobile device unique ID, your mobile device's IP address, your mobile phone operation system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information sent by your browser when you visit our Services or access the Services through or through a mobile device.

We may also collect AI usage data, including which AI features you use, how often you use them, and whether AI-generated content was edited before being sent.

2.1.3 Saved Chats and Conversation Content

When you use the Saved Chats feature, you may choose to save conversation messages and related information for your own reference and productivity.

Depending on the features you use, the information may include saved messages, contact and business names, conversation labels, notes, reminders, customer details, and AI-generated content.

Saved Chats is designed to help you organize conversations, review saved information offline where supported, and manage follow-up activities.

Please save only conversations and information that you own or are authorized to use. Saved conversations may contain personal information relating to other individuals. You are responsible for ensuring that your use of such information complies with applicable laws and relevant platform terms.

2.2 Use of your personal data

The operator may use personal data for the following purposes:

• To provide and maintain our Services, including monitoring the use of our Services.

• Manage your account: Manage your registration as a user of the service. The personal data you provide may allow you to access different features of the service available as a registered user.

• For the performance of a contract: the formulation, compliance and commitment of a purchase contract for products, items or services you have purchased or any other contract you have with us through services.

• Contacting you: contacting you by email, phone call, text message or other equivalent form of electronic communication, such as push notifications from mobile applications regarding updates to features, products or contractual services (including security updates) or informational communications, Perform as necessary or reasonable.

• To provide you with news, special offers and general information about other goods, services and events from us that are similar to those you have purchased or inquired about, unless you have opted out of receiving such information.

• Manage your requests: participate in and manage your requests to us.

• For business transfers: We may use your information to evaluate or conduct a merger, divestiture, reorganization, reorganization, dissolution or otherwise sell or transfer some or all of our assets, whether as a going concern or as a bankruptcy, liquidation A portion, or similar program, in which the personal data we hold about users of our services is a transferred asset.

• For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotions and evaluating and improving our services, products, services, marketing and your experience.

• To provide AI-powered features: We use your saved chats, customer briefs, notes, and product library information to generate reply drafts, summarize conversations, translate messages, extract customer details, and identify potential deals.

• With AI Service Providers: To provide AI-powered features, we share necessary data with our designated third-party AI service providers as detailed in Section 2.4 below. We only share the minimum data necessary to fulfill the specific AI feature request. We will not share your data with AI service providers for purposes other than providing the AI features described in this Privacy Policy without your explicit consent.

We may share your personal information in the following situations:

• With service providers: We may share your personal information with service providers to monitor and analyze the use of our services in order to contact you.

• For business transfers: We may share or transfer your personal information in connection with any merger, sale of operator assets, financing or acquisition of all or part of our business to another operator or during negotiations.

• With affiliated operators: We may share your information with our affiliated operators, in which case we will require those affiliated operators to comply with this Privacy Policy. Affiliated operators include our parent operator and any other sub-operators, joint venture partners or other operators that we control or jointly control with us.

• With business partners: We may share your information with our business partners in order to offer you certain products, services or promotions.

• With other users: When you share personal information or otherwise interact with other users in public areas, such information may be viewed by all users and may be publicly posted externally.

• With your consent: We may disclose your personal information for any other purpose with your consent.

2.3 Retention of your personal data

The operator will only retain your personal data for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we need to retain your data to comply with applicable law), resolve disputes and enforce our legal agreements and policies.

The operator will also retain usage data for internal analysis. Usage data is generally retained for a shorter period of time unless the data is used to enhance security or improve the functionality of our services, or we are legally obligated to retain the data for a longer period of time.

Retention of Saved Chats and AI-Processed Data:

• Local storage: Saved chats, notes, labels, and AI-generated content are stored locally on your device, subject to the App's actual storage implementation. You may delete locally stored content using the deletion controls available in the App.

• Offline access: Locally stored saved information may remain accessible when the network is unavailable or the messaging service is disconnected, where supported by the App.

• Third-party AI processing: When you choose to use an AI feature, the relevant content necessary to fulfill your request may be transmitted to OpenAI. The retention of such data is subject to the applicable OpenAI API data retention policies described in Section 2.4.

• Deletion limitations: Deleting information from the App does not necessarily delete copies already transmitted to a third-party service provider or information retained for security, legal compliance, or other permitted purposes.

• Local data loss: Locally stored information may be lost if you delete the App, clear its local data, or otherwise remove it from your device. Unless the App provides a backup or synchronization feature, recovery of such information is not guaranteed.

2.4 Transferring your personal data

Your information, including personal data, will be processed at the operator's operating offices and wherever other parties involved in the processing are located. This means that this information may be transferred to and stored on computers located outside your state, province, country or other governmental jurisdiction which may have different data protection laws than your jurisdiction.

Your agreement to this Privacy Policy and subsequent submission of such information constitutes your consent to this transfer.

The operator will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Privacy Policy and will not transfer your personal data to organisations or countries unless adequate controls are in place, including security of your data and other personal information.

AI Data Processing and Third-Party AI Service Provider Disclosure:

• AI Service Provider:

We use OpenAI, L.L.C. (“OpenAI”), which operates the ChatGPT API (including GPT-5.5 models), as our designated third-party AI service provider to power the AI features of the App. OpenAI processes data as our data processor.

• What data is sent to OpenAI:

When you use AI features, the following data may be transmitted to OpenAI's API:

• Saved chat messages and conversation content

• Customer briefs and notes

• Product library information

• Any text you input when using AI features (e.g., AI prompts)

• Purpose of data sharing:

Data is sent to OpenAI solely for the purpose of generating AI outputs, including:

• Drafting reply suggestions

• Summarizing conversations

• Translating messages

• Extracting customer details

• Identifying potential deals

• How OpenAI handles your data:

Data sent to the OpenAI API is not used to train or improve OpenAI models unless we explicitly opt in. We have not opted in to data sharing for model training.

• OpenAI generates abuse monitoring logs for all API feature usage and retains them for up to 30 days, unless longer retention is required by law or is reasonably necessary to protect against harm.

• OpenAI personnel may review content only as necessary to enforce its Usage Policies and applicable law.

• For more details, see OpenAI's Privacy Policy at https://openai.com/privacy and Data Controls at https://platform.openai.com/docs/guides/your-data.

• Cross-border data transfer:

• OpenAI's servers are primarily located in the United States and may be located in other jurisdictions. When you use AI features, your data may be transferred to and processed in countries outside your country of residence, including the United States. We ensure that such transfers comply with applicable data protection laws and that your data receives an adequate level of protection in accordance with this Privacy Policy and our agreements with OpenAI.

2.5 Disclosure of your personal data

2.5.1 Commercial Transactions

Your personal data may be transferred if the operator is involved in a merger, acquisition or asset sale. We will give notice before your personal data is transferred and subject to different privacy policies.

2.5.2 Enforcement

In certain circumstances, the operator may be required to disclose your personal data if required by law or in response to a valid request from a public authority (such as a court or government agency).

2.5.3 Other legal requirements

The operator may disclose your personal data in good faith, believing that such action is necessary to:

• Compliance with legal obligations

• Protect and defend the rights or property of the operator

• Prevent or investigate possible misconduct in connection with the Services

• To protect the personal safety of service users or the public

• Prevent legal liability

2.6 Security of your personal data

The security of your personal data is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we endeavour to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

3. Children's Privacy

Our services are not directed to anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you know that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without parental consent, we will take steps to delete that information from our servers.

If we require consent as a legal basis for processing your information and your country requires parental consent, we may ask for your parental consent before collecting and using that information.

AI features and children: Our AI features are not designed for or directed to children under the age of 13. We do not knowingly send the personal data of children under 13 to third-party AI services. If you are a parent or guardian and believe that your child has used AI features and provided personal data, please contact us immediately so we can take appropriate action.

4. Links to other websites

Our Services may contain links to other websites not operated by us. If you click on a third party link, you will be directed to that third party's website. We strongly recommend that you review the privacy policy of each website you visit.

We have no control over, and are not responsible for, the content, privacy policies or practices of any third-party website or service.

5.Your Privacy Rights You have the following rights regarding your personal data:

5.1 Right of Access

You have the right to request access to the personal data we hold about you, including data that has been processed by our AI service.

5.2 Right to Rectification

You have the right to request correction of inaccurate personal data. You can edit AI-extracted customer details directly within the App.

5.3 Right to Deletion

You may delete saved chats, notes, labels, reminders, and AI-generated content directly within the App, where supported.

To request deletion of applicable data that has been transmitted to our third-party AI service provider, OpenAI, please contact us at dualwhatsappfeedback@outlook.com. We will review your request and forward applicable deletion requests to OpenAI where appropriate.

Please note that deletion from the App does not automatically guarantee the immediate deletion of all copies held by third-party service providers. Certain information may be retained where permitted or required by applicable law or for legitimate security purposes.

6. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will notify you by email and/or a prominent notice on our Services and update the "Last Updated" date at the top of this Privacy Policy prior to the change becoming effective.

You are advised to periodically review this Privacy Policy for any changes. Changes to this Privacy Policy will be effective as soon as they are posted on this page.

7. Contact us

If you have any questions about this Privacy Policy, you may contact us: dualwhatsappfeedback@outlook.com

Attachment 1 "Explanation of "Whats Web Plus" Permission Application and Usage"

1. In order to ensure the safe and stable operation of "Whats Web Plus", we will apply for or use the relevant permissions of the operating system according to the actual business scenario;

2. In order to protect your right to know, we display the relevant operating system permissions that the product may apply for and use through the following list, and you can manage the relevant permissions according to your actual needs;

3. According to product upgrades, the types and purposes of application and use rights will change according to product functions, and we will adjust the list according to these changes in a timely manner to ensure that you are informed of the application and use of rights in a timely manner;

4. Please be aware that for the functional and security needs of our business and products, we will consider using third-party SDKs based on actual business scenarios, and these third parties will also apply for or use relevant operating system permissions;

5. In the process of using the product, if you use the H5 interface or applet developed by a third party, the plug-in or applet developed by these third parties will apply for or use the relevant operating system permissions according to the actual business function needs.

List of iOS operating system app permissions

1.【Push Notifications Usage Description】

Permission function description: push message notification

Usage scenarios and purposes: to help you know whether the current application is the latest version

Consequences of refusing to provide: Unable to receive push notifications

2.【Network Extensions Usage Description】

Permission function description: network permissions

Usage scenarios and purposes: used to send and receive network data, access third-party links and other network requests

Consequences of refusing to provide: Unable to use the network

3.【Tracking Usage Description】

Permission function description: Use cross-program user tracking function

Usage scenarios and purposes: Obtain your device identifier for data statistics, measure and analyze service effects, ensure service security and improve your user experience

Consequences of refusal to provide: inability to better analyze service performance and improve your user experience

1. 【Camera Usage Description】

Permission function description: use the function of taking pictures

Scenarios and Purposes: To help you take pictures

Consequences of refusal: unable to take photos instantly

5.【Photo Library Usage Description】

Permission function description: read the content in the album

Usage scenarios and purposes: to help you send album pictures

Consequences of refusal: Unable to send album pictures

6.【Microphone Usage Description】

Permission function description: use the microphone function

Usage Scenario and Purpose: To record and send voice messages, and to record voice descriptions of customers (e.g., the "Describe customer" feature). These voice recordings are converted to text and processed by our AI service to generate customer profiles.

Consequences of refusing to provide: Unable to record via microphone

7.【Speech Recognition Usage Description】

Permission function description: use the speech-to-text function

Usage scenarios and purposes: the function of converting your speech into text and displaying it

Consequences of refusal: Speech-to-text functionality unavailable

8.【Files and Folders Usage Description】

Permission function description: access files and documents

Usage scenarios and purposes: To allow you to select and upload PDFs, catalogs, or quotation documents from your device to our AI service for parsing and knowledge base integration.

Consequences of refusing to provide: Unable to upload documents for AI parsing.

Attachment 2 ""Whats Web Plus" accesses the third-party SDK directory"

In order to ensure the realization of the relevant functions of "Whats Web Plus" and the safe and stable operation of the application, we will access the software development kit (SDK) provided by a third party to achieve related purposes according to the needs of actual business scenarios.

We will conduct strict security monitoring on the software tool development kits (SDKs) used by partners to obtain information to protect data security.

The relevant third-party SDKs we access to are listed in the catalog.

Please note that the third-party SDK may change the data processing type due to its version upgrade, policy adjustment, etc., please refer to the official description of its formula.

1. Umeng SDK

Purpose of use: to provide statistical analysis services and basic anti-cheating capabilities

Get information: device MAC address, unique device identifier (IMEI/OPENUDID/GUID), advertising identifier, SIM card IMSI information, network status, WiFi status, WiFi MAC address

Invoked device permissions: get network status, access WiFi status, allow applications to network

2. AdMob SDK

Purpose of use: push advertising information to users, anti-cheating

Get information: unique identifier, device type and settings, operating system, mobile network information (including carrier name) and app version numbers, IP addresses, crash reports

Called device permissions: get network status, access WiFi status