Privacy Policy
FrontDesk+ is an AI assistant that helps small businesses in Hong Kong answer customer questions and manage bookings on messaging channels such as WhatsApp and Telegram. This policy explains what personal data we handle, why, who we share it with, and the rights you have. It is written to align with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and its six Data Protection Principles.
1. Who we are and our role
FrontDesk+ is operated from Hong Kong SAR. We handle personal data in two different roles:
- Business customers (our subscribers). For the account holders who sign up to FrontDesk+ — the business owner and staff users — we are the data user.
- End customers of a business. When someone messages a business that uses FrontDesk+, that business decides why and how their data is used, and is the data user. We act as its data processor, handling the data only to provide the service and on the business's instructions. If you are an end customer and want to exercise your rights, contacting the business directly is usually quickest; you may also contact us (section 12) and we will help route your request.
2. What we collect
From business customers
- Name, email address, phone number and login credentials (passwords are stored only as a one-way hash).
- Business details you enter: services and prices, opening hours, staff, calendar entries and bookings.
- Connection details for the channels you link (for example a WhatsApp phone number ID and access token, or a Telegram bot token). Access tokens are stored encrypted.
- Subscription and billing records, and usage records such as message and AI-usage counts.
From end customers who message a business
- Your phone number or messaging account ID, and the profile name shown on your account.
- The content of your messages and the assistant's replies.
- Booking details (service, date and time, notes) and any contact details you choose to give, such as an email address or address for a visit.
We collect only what the conversation and the booking need. We do not ask for identity-card numbers, payment-card numbers or health information, and we ask that you do not send them in chat. Images, voice notes and attachments are currently not processed.
3. How we use it
- To receive messages for a business, draft and send replies, and create, change or cancel bookings.
- To show the business its conversations, contacts and calendar, and to let the business review or take over a conversation.
- To send booking confirmations and calendar invitations on the business's behalf.
- To operate, secure, support and bill for the service, and to monitor for misuse.
- To meet legal obligations.
Replies are produced with artificial intelligence. The assistant answers using the business's own catalogue and calendar, and may refer a question to the business owner when it is not certain. We do not use end customers' personal data for our own marketing, we do not sell personal data, and we do not use it to train AI models.
4. Who we share it with
We share personal data only with service providers who help us run the service, and only as needed:
| Provider | Why |
|---|---|
| Meta Platforms (WhatsApp Business Platform) | Carries WhatsApp messages between customers and the business. |
| Telegram | Carries Telegram messages, for businesses that use Telegram. |
| Anthropic and Alibaba Cloud Model Studio | AI language models that read a message and draft the reply. |
| Alibaba Cloud | Hosting, database and storage. |
| The business's own email provider | Sends booking confirmations and invitations from the business's own email account. |
We may also disclose personal data where required by law, a court order or a regulator, or to protect rights and safety. Within a business, data is visible only to that business's authorised users; each business's data is kept separate from every other business's.
5. Data stored or processed outside Hong Kong
Our providers may store or process data in other places, including Singapore and other jurisdictions where they operate. Where personal data leaves Hong Kong we take reasonable steps, including contractual and technical measures, to ensure it receives protection comparable to the PDPO. Data sent to AI providers is limited to the content needed to answer the message.
6. How long we keep it
We keep personal data only for as long as it is needed for the purposes in section 3, in line with Data Protection Principle 2. Business account data and conversation records are kept while the account is active. When an account is closed, or when a business or an individual asks us to delete data (section 10), we delete or irreversibly anonymise it within a reasonable period, except where we must keep records to meet legal obligations or to resolve disputes. A business can also remove its own connected channels, contacts and owner numbers at any time from the FrontDesk+ portal.
7. Security
- Data is encrypted in transit (HTTPS/TLS).
- Channel access tokens and similar secrets are encrypted at rest; passwords are stored as one-way hashes.
- Each business's records are isolated at the database level so that one business cannot see another's.
- Access to systems is limited to authorised people who need it, and inbound webhooks from messaging platforms are verified by signature before being accepted.
- Service providers that handle data for us are required to protect it and to use it only for the services they provide.
No system is perfectly secure. If a data breach affects you, we will take prompt steps to contain it and will notify affected businesses and, where appropriate, individuals and the Privacy Commissioner.
8. PDPO-aligned data handling
How we handle personal data against each Data Protection Principle in Schedule 1 to the PDPO:
| Principle | What we do |
|---|---|
| DPP1 — Purpose and manner of collection | We collect only data that is necessary for, and directly related to, answering messages and managing bookings. Collection is by lawful and fair means, and this policy tells you what we collect and why. |
| DPP2 — Accuracy and retention | Businesses and individuals can correct inaccurate records. Data is not kept longer than needed (section 6). Where we use a data processor, we use contractual means to prevent data being kept longer than necessary. |
| DPP3 — Use of data | Data is used only for the purposes stated in section 3 or directly related ones. We do not use it for a new purpose without consent, and we do not use it for our own direct marketing. |
| DPP4 — Security | The measures in section 7 protect against unauthorised or accidental access, processing, erasure, loss or use. Service providers are bound to equivalent protection. |
| DPP5 — Openness | This policy states the kinds of personal data we hold and our practices. You can ask us about them at any time (section 12). |
| DPP6 — Access and correction | You may ask whether we hold data about you, ask for a copy, and ask for it to be corrected (section 9). |
This page describes our practices. It is not legal advice and does not replace the obligations of the businesses that use FrontDesk+ as data users.
9. Your rights: access and correction
Under the PDPO you may:
- ask whether we hold personal data about you and request a copy (a data access request);
- ask us to correct data that is inaccurate (a data correction request).
Email us at the address in section 12 with enough detail to identify you and the data concerned. We may need to verify your identity first. We aim to respond within 40 days, as the PDPO requires, and may charge a reasonable fee for the cost of supplying a copy. If we cannot comply, we will tell you why. If the data is held for a business that uses FrontDesk+, we will pass your request to that business or help you reach it.
10. Data deletion
To have your personal data deleted:
- Business customers: use the Remove option in the FrontDesk+ portal under Connections to delete a connected WhatsApp number, its access token and owner numbers, and to delete channels you no longer use. To close the account and delete its data, email us.
- End customers: email us with the phone number or messaging account you used. We will delete or anonymise the conversation and contact records linked to it, subject to anything we are legally required to keep.
- Meta/WhatsApp data: messages stored on WhatsApp's own systems are governed by Meta's policies; you can manage those in WhatsApp.
11. WhatsApp and Meta
FrontDesk+ connects to the WhatsApp Business Platform. When you message a business on WhatsApp, Meta also processes your data under its own terms and privacy policy. We receive the message text, your phone number and your WhatsApp profile name. We reply within the 24-hour customer service window that opens when you message the business. We do not use WhatsApp data for advertising and do not combine it with data from other sources.
12. Changes and contact
We may update this policy and will change the date above when we do; material changes will be notified to business customers. This policy is governed by the laws of Hong Kong SAR.
Privacy contact: hello@frontdeskplus.io (please put "Privacy" in the subject line).
If you are unhappy with how your data has been handled, you can also contact the Office of the Privacy Commissioner for Personal Data, Hong Kong: www.pcpd.org.hk.