Privacy Policy

Cloud Development Company Ltd ("we", "us", "our") operates the application Bossie, accessible at https://bossie.app.

We are committed to protecting personal data and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, store, and protect personal data when you use Bossie.

Bossie is a business communication platform that enables organisations to send operational and work-related WhatsApp messages to staff members who have explicitly agreed to receive such communications.

Bossie is not designed for unsolicited marketing communications.

For the purposes of data protection law:

• The organisation using Bossie to send messages is typically the Data Controller of staff data.
• Cloud Development Company Ltd acts as a Data Processor, processing personal data on behalf of that organisation.
• For account-level data relating to Bossie customers (such as account registration details), Cloud Development Company Ltd acts as Data Controller.

For any privacy queries, contact: hello@bossie.app

Depending on how Bossie is used, we may process the following personal data:

• Name
• Work email address
• Company name
• Role
• Login credentials
• Billing information (if applicable)

• Name
• Mobile phone number
• Internal identifiers (if used by the employer)
• Department or role (if included by customer)
• Messaging consent status

When messages are sent via the WhatsApp Business Platform:

• Message content
• Timestamps
• Delivery status
• Read status (where available)
• Template identifiers
• Interaction metadata

We do not access private WhatsApp conversations outside messages sent through the Service.

• IP address
• Browser type
• Device type
• Log data
• Access timestamps
• System diagnostics

Under UK GDPR, processing is carried out on the following legal bases:

• Performance of a contract
• Legitimate interests (operating and improving the Service)
• Legal obligations

Processing is based on:

• Consent provided to the employer to receive WhatsApp communications; and/or
• Legitimate interests in operational workplace communications

The employer (as Data Controller) is responsible for ensuring a valid lawful basis exists.

We use personal data to:

• Deliver WhatsApp messages via the Service
• Manage user accounts
• Provide support and maintenance
• Monitor system performance and security
• Comply with legal obligations
• Prevent fraud, misuse, or unlawful activity

We do not sell personal data.

We do not use staff message data for advertising.

Bossie integrates with the WhatsApp Business Platform, provided by Meta Platforms, Inc.

When messages are sent:

• Personal data (including phone numbers and message content) is transmitted to Meta for delivery.
• Meta acts as an independent data controller for its own processing activities.

Meta's privacy practices are governed by its own policy: https://www.facebook.com/privacy/policy/

We are not responsible for Meta's independent processing.

We may share data with:

• Meta (WhatsApp message delivery)
• Cloud hosting providers
• Infrastructure and security providers
• Professional advisers
• Legal or regulatory authorities where required

All subprocessors are subject to appropriate contractual and security obligations.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, such as:

• International Data Transfer Agreements (IDTAs)
• UK-approved Standard Contractual Clauses
• Equivalent safeguards required under law

We retain personal data only as long as necessary to:

• Provide the Service
• Comply with legal obligations
• Maintain legitimate business records

Message logs and metadata may be retained for operational, audit, and compliance purposes unless deletion is requested or required.

Customers may request deletion of data at any time.

We implement appropriate technical and organisational measures to protect personal data, including:

• Secure cloud infrastructure
• Access controls
• Encryption in transit
• Role-based access permissions
• Monitoring and logging

However, no internet-based service can guarantee absolute security.

Depending on your role:

You should contact your employer (the Data Controller) first regarding:

• Access requests
• Correction requests
• Deletion requests
• Objection to processing

You may also contact us directly at hello@bossie.app.

You have the right to:

• Access your personal data
• Request correction
• Request deletion
• Restrict processing
• Object to processing
• Lodge a complaint with the ICO

ICO website: https://ico.org.uk

Staff members may withdraw consent to receive WhatsApp messages:

• By contacting their employer; or
• By following opt-out instructions included in messages (where available).

Upon withdrawal, messaging should cease.

To request deletion of personal data, contact: hello@bossie.app

We may require verification of identity before processing requests.

Where we act as a Data Processor, we will forward deletion requests to the relevant Data Controller (the employer).

Bossie is intended for workplace use and is not directed at individuals under 18. We do not knowingly collect data from children.

Bossie may use essential cookies and similar technologies necessary for:

• Authentication
• Security
• Session management

We do not use tracking cookies for advertising purposes within the application.

We may update this Privacy Policy from time to time. Any changes will be posted at https://bossie.app/privacy with the updated date.

Continued use of the Service after changes are posted constitutes acceptance of the revised Policy.

Cloud Development Company Ltd

Website: https://bossie.app

Email: hello@bossie.app