Privacy policy

This Policy governs the processing of personal data carried out in connection with the use of Imperio (the "Platform"). By using the Platform, the Client declares that they know and accept this Policy, together with the Terms and Conditions in force.

1. Controller and roles of the parties

In the operation of the Platform, Hirely Partners acts as a technology provider. The Client, as owner of its business and of its end-user base, is responsible for the lawful origin of the data uploaded, for its legal basis for processing and for the information given to its own clients.

2. Categories of data processed

Depending on the modules enabled, we may process: registration and access data (users, roles, sessions), operational calendar and staff data, end-client data (identification, contact details, service history), transaction and register data, loyalty data (points, redemptions, tokens, wallet), messaging data (WhatsApp and templates), technical data (logs, IP, device, telemetry) and usage metadata for security and service continuity.

3. Purposes of processing

We process data to: (i) provide and maintain the contracted features; (ii) authenticate users and manage permissions; (iii) run automations and communications configured by the Client; (iv) enable reporting and operational analytics; (v) detect fraud, abuse or security incidents; (vi) comply with legal or regulatory obligations.

4. Legal basis

Processing is based on performance of the contractual relationship with the Client, the legitimate interest in operating and protecting the Platform, and/or compliance with legal obligations, as applicable. The Client declares that it has a sufficient legal basis to upload and process third-party data on the Platform.

5. Integrations and transfers to third parties

The Platform may integrate with external providers (for example, Meta/WhatsApp, payment gateways, Google Wallet, Apple Wallet, cloud providers and email). Using those integrations may involve data transfers under each third party's policies and terms, with the Client responsible for configuration, consent and applicable regulatory compliance.

6. Information security

Reasonable technical and organizational measures are applied to mitigate the risk of unauthorized access, loss, disclosure or alteration of data. However, no system is absolutely infallible, so total security or the complete absence of incidents cannot be guaranteed.

7. Retention period

Data is retained for the duration of the contractual relationship and for the additional time needed to meet operational, backup, audit, legal defence or regulatory requirements. Once the relationship ends, data may be kept blocked for reasonable legal or technical periods.

8. Data subject rights

Data subjects may request access to, rectification, updating or deletion of their data in accordance with applicable regulations. Where the data was uploaded by a Client of the Platform, the request must first be directed to that Client as the party responsible for its database.

9. Minors

The Platform is not directed at minors without the authorization of their legal representatives. The Client is responsible for verifying and meeting legal requirements when handling minors' data.

10. AI, messaging and generated content

In AI and automatic messaging modules, instructions, messages and metadata may be processed in order to run replies or flows. The Client is responsible for the content sent to end users, for its legality and for its commercial appropriateness.

11. No refunds, cancellation and complaints

In accordance with the Terms and Conditions, there are no refunds or reimbursements for Platform services. Any cancellation request must be notified with at least thirty (30) calendar days' notice to contacto@hirelypartners.com. To the maximum extent permitted by law, Hirely Partners does not take responsibility for claims arising from the Client's commercial operation towards third parties.

12. Changes to this policy

This Policy may be amended at any time for legal, operational or security reasons. The version published on this page is the one in force.

13. Contact

Contact email: contacto@hirelypartners.com