Platform Privacy Policy

1. Overview & Data Controller Identification

This Privacy Policy explains how Ziro Marketing Platform ("Ziro", "we", "us", or "our") collects, uses, processes, and protects personal information when retail organizations, store managers, cashiers, and consumers interact with our multi-tenant marketing infrastructure, omnichannel messaging pipelines, and cashier checkout verification desks.

In our multi-tenant software-as-a-service (SaaS) architecture, each subscribing Organization acts as the Data Controller for customer information uploaded or captured through digital receipts, POS integrations, and loyalty clubs. Ziro operates as the Data Processor on behalf of each Organization.

2. Information We Collect

We collect and process the following categories of information strictly to deliver service functionality:

• Account & Authentication Data: Names, work emails, Argon2id-hashed credentials, organization memberships, and role assignments (SUPER_ADMIN, ORG_ADMIN, STORE_MANAGER, CASHIER).
• Customer & Audience Directory: Mobile phone numbers (E.164 standard), customer names, opt-in consent timestamps, loyalty point balances, and RFM behavioural metrics.
• Store Checkout & Transaction Telemetry: Anonymized purchase values, item quantities, applied promo coupons, branch IDs, and cashier terminal timestamps.
• Messaging Logs & Delivery Receipts: Carrier message IDs, delivery receipt timestamps (DELIVERED, FAILED, UNDELIVERED), and error reason codes from SMS/WhatsApp gateways.
• System Audit & Access Logs: Client IP addresses, user agents, API key usage, and immutable security audit logs for compliance tracking.

3. Strict Multi-Tenant Data Isolation

We enforce multi-tenant isolation at the database, caching, and application layers. Every database entity is partitioned by immutable org_id (and branch_id for store-scoped data).

Under no circumstance is customer, coupon, or financial transaction data shared, mixed, or aggregated across distinct tenant organizations. No automated machine learning model is trained on cross-tenant proprietary customer lists without explicit opt-in consent.

4. Third-Party Sub-Processors & Carrier Networks

To deliver omnichannel messaging and process billing, Ziro transmits authorized dispatch payloads to certified infrastructure providers:

• Meta WhatsApp Cloud API: Encrypted message broadcast payloads and interactive customer conversation threads.
• Telecom Carriers (Dialog, Mobitel, Twilio): SMS notification dispatch and asynchronous delivery status receipts.
• Payment Gateways (Stripe, PayHere): Secure tokenized wallet recharge card transactions (PCI-DSS compliant).

5. Data Retention & Right to Erasure (GDPR Art. 17)

End-consumers have the right to request deletion of their profile, loyalty balance, or consent records. Tenant administrators can initiate one-click erasure of customer profiles through the Customer Directory. Upon deletion:

• Customer PII (phone number, name, email) is permanently purged or cryptographically pseudonymized.
• Past historical financial ledger transactions are retained in compliance with statutory fiscal retention mandates without identifying consumer details.

6. Data Protection Officer (DPO) & Contact

If you have any questions, subject access requests (SAR), or security disclosures regarding this policy, please contact our Data Protection Office: