Privacy Policy
Last updated: 13 October 2026
Conciergr is a service provided by LONUT (UEN 53462899X), a sole proprietorship registered in Singapore ("LONUT", "we", "us"). We provide messaging automation and software services to business clients. This policy explains what personal data we handle, why, and your rights under Singapore's Personal Data Protection Act 2012 (PDPA).
Data we collect on our company website
Our company website, lonut.systems, does not use cookies, analytics trackers, or advertising pixels, except on its signup page described below. If you email us, we keep your email address and correspondence for as long as needed to handle your enquiry and maintain our business records.
Conciergr website, portal and signup
Conciergr's website, conciergr.com, works differently:
- Analytics. conciergr.com uses Google Analytics, which sets cookies (such as
_ga) to give us aggregate statistics about how the site is used. We do not use this data to identify individual visitors and we do not run advertising pixels there. - Portal sign-in. The Conciergr customer portal, the Team Inbox and signup offer Sign in with Google or a one-time code sent to your email address. With Google, we receive your name, email address and Google account identifier, and store no Google passwords or access tokens. With an email code, we send the code to the address you type and keep that address, a scrambled copy of the code and a scrambled copy of your IP address (used only to limit repeated requests) for about a day. Either way, we keep a session cookie on your device for up to 30 days so you stay signed in.
- WhatsApp connection. The signup pages (on both domains) load Facebook's SDK to run Meta's official WhatsApp signup flow; Meta's own data practices apply to that flow. An invite code you enter is kept in your browser's session storage only until signup completes.
Data we process on behalf of clients
Our core service is operating automated customer-messaging systems for business clients on the WhatsApp Business Platform. When we do so, we act as a data intermediary (processor) for the client, who remains responsible for the customer relationship. In that role we may process:
- Phone numbers and profile names of people who message our clients' WhatsApp business numbers;
- The content of those messages (text, and media such as photos, voice notes, videos and documents), used to generate a relevant reply on the client's behalf and to show the conversation to the client's own team, who can read and answer it in the Team Inbox;
- The replies the client's team sends to those people, from the Team Inbox or from the client's own WhatsApp Business app;
- Delivery and read metadata needed to operate the service reliably.
Message content may be processed by our AI language-model provider (currently OpenAI, under API terms that do not permit training on the data) to generate replies. We do not use client customer data for advertising, we do not sell it, and we do not use it to train models.
The client's team and the Team Inbox
A client can give the people on its team access to the Team Inbox, a web inbox where each person signs in individually to read the client's WhatsApp conversations and answer them from the client's number. For each person the client adds, we hold their first name, email address, role and, if the client gives one, a WhatsApp number on which they are alerted when a conversation needs a person. We record which person sent each reply from the Team Inbox and when, and how long the customer waited for it; a reply sent from the client's own WhatsApp Business app is recorded as the team's, never as a particular person's. The team can also give a customer a name and a note that only the team sees; these are never shown to the automated assistant. When a client's WhatsApp Business app shares its saved contacts with the WhatsApp Business Platform, or the client uploads its contact list, we keep each contact's saved name and phone number so the client's team sees conversations under the names it already uses. These names are shown only to the client's own team, are never shown to the automated assistant, are updated or removed when the client changes them in the app, and are deleted with the client's conversation data. A person the client removes from its team loses access at once.
Each reply a person on the client's team sends to a customer, from the Team Inbox or from the client's WhatsApp Business app, is scored automatically for quality: whether it answered what was asked, fitted that customer, was clear and brief, and left a next step, and whether it was only a holding reply. The scoring reads the recent conversation as it stands, on the same systems that host the conversation, and the conversation is not sent to any other provider for it. The scores, with reply times and the number of conversations each person closed, are shown only to the client's own people. They are not used for advertising, are not sold, and are never used to train AI models. The client is responsible for telling its team that their replies are recorded and scored.
Chat history imported at connection
When a client connects a WhatsApp number to our systems in coexistence mode, Meta provides a one-time copy of that number's recent conversation history (approximately the previous six months, both directions; the client chooses in the WhatsApp Business app whether to share it). We store that history on systems we operate, hosted by Cloudflare, and use it for two purposes, both on the client's behalf. The first is continuity: when a person who has written to the client before writes again, the client's automated assistant can see the earlier conversation and reply in context, in the same way and under the same terms as it handles messages received after connection. The second is a one-time setup analysis: contact details and identification numbers inside the messages (phone numbers, email addresses, postal addresses, NRIC and similar numbers) are masked by software running on systems we operate, and the text is then analysed by our AI language-model provider (currently OpenAI, under API terms that do not permit training on the data) to draft, for the client's review, a plain-language summary of the information the client's team commonly gives and a description of how the team writes. Names and the content of the conversations are not masked for this analysis; the drafts are written as general information about the business, not about any individual. Both drafts are sent only to the client, who checks them and decides whether to use them. Imported history is retained while the client's subscription is active and for 90 days after it ends, then deleted, or earlier at the client's request. It is not used for advertising, is not sold, and is never used to train AI models. Contact details the WhatsApp Business app synchronises to the WhatsApp Business Platform as part of coexistence are handled by Meta under WhatsApp's own privacy policy and are used by us only to operate the service.
Aggregated statistics
We may publish statistics about how the service is used, such as the share of enquiries that arrive outside business hours or how quickly replies are sent, calculated from message times and counts across several clients. Published statistics never include what any message says and never name or identify a client, a client's customer or any other person.
WhatsApp and Meta platform data
Our services are built on the WhatsApp Business Platform operated by Meta. Our access to and use of WhatsApp business data complies with the Meta Platform Terms and the WhatsApp Business Terms of Service. Messages are delivered through Meta's infrastructure and are also subject to WhatsApp's own privacy policy.
Retention
Conversation data processed for clients, including chat history imported at connection, is retained while the client's subscription is active so the service can maintain conversational context, or for a shorter period if the client directs. When a client's subscription ends, we retain their configuration, knowledge base and conversation data for 90 days in case they return, then delete them, keeping only anonymous counts that cannot identify anyone. Encrypted backups, held with a separate storage provider, and our hosting provider's recovery copies are kept for up to 30 days and then expire.
Photos, voice notes, videos and documents that customers send to a client, and files the client's team sends from the Team Inbox, are kept for 90 days from the day they arrive and then deleted automatically; after that the conversation keeps only a transcript or a short description of each one. They are deleted sooner when a person asks us to delete their data. The client's team list, the team's own names and notes for customers, and reply scores are kept and deleted with the client's conversation data.
Security
We protect personal data with reasonable security arrangements as the PDPA requires: data is held on access-controlled systems, transferred only over encrypted connections, with contact details and identification numbers masked before any external analysis other than generating a reply and scoring the client's team replies (both described above), and accessible only to the people who operate the service and, for a client's own conversations, to the people that client adds to its team.
Sharing and international transfers
We share data only with service providers necessary to operate our systems (e.g. Meta/WhatsApp for message delivery, Cloudflare for hosting and data storage, Backblaze for encrypted backups, and our AI language-model provider for reply generation), and where required by law. We do not sell personal data. Some of these providers process data outside Singapore, including in the United States; where they do, we transfer data under contractual terms that require a standard of protection comparable to the PDPA.
Your rights
Under the PDPA you may request access to or correction of personal data we hold about you, or withdraw consent to its processing, and you may ask us to delete it (see Deleting your data below). If your data was processed as part of a client's messaging service, we may refer an access or correction request to the relevant client, who controls that data; a deletion request we carry out ourselves.
Deleting your data
Anyone can ask us to delete the personal data we hold about them: a client, someone who signed in to the Conciergr portal, a member of a client's team, someone who emailed us, or someone who messaged one of our clients' WhatsApp numbers. Email [email protected] with "Delete my data" in the subject. If you messaged a business on WhatsApp, include the number you messaged from and the business's name; we may ask you to confirm the request from that number. We delete the data within 30 days and tell you when it is done. We keep only what the law requires us to keep, such as invoices, and anonymous counts that can no longer identify you, and we will tell you if anything was kept and why. If your data came to us through a client's WhatsApp service, we also tell that client. Encrypted backups and recovery copies expire on their own within 30 days after that.
Changes to this policy
We may update this policy from time to time; the date above shows the current version. Material changes affecting active clients will be notified by email or via the service.
Contact
For privacy matters, contact our data protection contact at [email protected]. If you are not satisfied with our response, you may complain to Singapore's Personal Data Protection Commission (pdpc.gov.sg).