Privacy Policy

This Privacy Policy applies to the CCH WhatsApp CRM application (the App) used by Cleanse Colon Hydrotherapy (CCH, we, us or our).

The responsible party for personal information processed through the App is:

• Legal entity: Trinity Health Group (Pty) Ltd t/a Cleanse CHT
• Physical address: 95 Bram Fischer Drive, Ferndale, 2194, South Africa
• Email: hello@cleancolon.co.za
• Information Officer/privacy contact: hello@cleancolon.co.za

Our website is www.cleancolon.co.za.

The App is an internal customer relationship management and communications tool. It helps us receive enquiries, manage prospective-client relationships, communicate through WhatsApp and email, and record the progress of enquiries. It is not intended to provide emergency, diagnostic or medical services.

This policy explains how we collect, use, disclose, store and protect personal information processed through the App, including information received through:

• Meta and Facebook lead forms;
• WhatsApp Business Platform;
• our websites and enquiry forms;
• email communications;
• telephone or direct communications with our team; and
• information entered into the App by authorised CCH personnel.

It should be read together with any additional privacy notice presented when information is collected.

Depending on how you interact with us, we may process:

• your name and surname;
• telephone and WhatsApp number;
• email address;
• preferred branch or location;
• the service or treatment about which you enquired;
• your enquiry, questions and communication preferences;
• messages exchanged with us through WhatsApp or email;
• the source of your enquiry, including a Meta lead-form identifier;
• campaign, advertisement and form information associated with an enquiry;
• dates, times and delivery statuses of communications;
• appointment-interest and sales-pipeline information;
• consent, unsubscribe and opt-out records;
• notes created by authorised staff following communications with you; and
• technical information required to secure, operate and troubleshoot the App.

The App is not intended to store detailed medical histories, clinical treatment notes or consent forms during its initial implementation. If you voluntarily send health-related information in a message, we will use it only as reasonably necessary to respond to your enquiry, determine the appropriate next step and provide our services, subject to applicable law and appropriate safeguards.

Please do not use WhatsApp or an online lead form for urgent medical matters.

We collect information:

• directly from you when you submit a lead form, contact us, send a message or provide information to our staff;
• from Meta when you submit a Facebook or Instagram lead form or communicate with our WhatsApp Business account;
• automatically when Meta sends message, delivery or webhook events to the App;
• from our authorised staff when they record an interaction or update an enquiry; and
• from service providers acting on our instructions.

Where information is collected through a Meta lead form, the form should identify CCH, the purpose of the collection and the communication choices available to you.

We process personal information to:

• receive and respond to enquiries;
• provide information requested by you;
• communicate with you by WhatsApp, telephone or email;
• assist you with selecting a branch or arranging an appointment;
• manage contacts, enquiries, follow-ups and staff assignments;
• send agreed or permitted follow-up communications;
• operate email and WhatsApp communication sequences;
• honour objections, unsubscribe requests and WhatsApp opt-outs;
• prevent duplicate records and communications;
• monitor whether communications were sent, delivered, read or failed;
• maintain accurate business and communication records;
• measure lead handling and campaign performance;
• secure, maintain, troubleshoot and improve the App;
• prevent fraud, abuse or unauthorised access; and
• comply with legal and regulatory obligations.

We do not sell personal information.

We process personal information only where a lawful justification applies, including your consent, steps taken at your request, the delivery of requested services, our legitimate business interests, or compliance with a legal obligation.

Marketing by electronic communication will be undertaken only where permitted by applicable law. Where consent is required, we will request and record it. Every marketing communication will identify the sender and provide a reasonable method to opt out.

You may object to direct marketing or withdraw your marketing consent at any time. We will maintain a suppression record where necessary to ensure that your preference continues to be respected.

Replying STOP to an applicable WhatsApp communication, using an email unsubscribe link, or contacting us at hello@cleancolon.co.za will stop the relevant marketing communications. An opt-out from WhatsApp does not necessarily unsubscribe you from email, and an email unsubscribe does not necessarily opt you out of WhatsApp, unless you ask us to stop all marketing communications.

We may still send non-marketing communications that are reasonably necessary to respond to a request, administer an appointment or service, or comply with law.

The App uses Meta services, which may include Facebook Lead Ads, the WhatsApp Business Platform and Meta webhooks.

When you submit a Meta lead form, Meta may provide us with the information you entered together with technical identifiers and advertising-context information, such as the lead, form, campaign, ad-set or advertisement identifier.

When you communicate with our WhatsApp Business account, Meta may transmit your number, profile information made available through WhatsApp, message content, message identifiers, timestamps and delivery-status information to the App.

Our processing of information received from Meta is governed by this policy, our agreements with Meta and applicable law. Meta separately processes information under its own terms and privacy policies. We do not control Meta's independent processing.

We use information received from Meta only for the purposes described in this policy and do not use it to build unrelated profiles or sell it to third parties.

The App may automatically send an initial response or follow-up message after you submit an enquiry. Automation may use information such as your first name, the source of the enquiry, whether you have replied, and the current status of your enquiry.

An inbound WhatsApp reply, opt-out, appointment booking, closure of the enquiry or other configured event may pause or stop automated follow-up. CCH staff remain responsible for material decisions about appointments and services. The App does not make clinical decisions about you.

We may disclose or make information available to service providers that help us operate the App and communicate with you, including:

• Meta Platforms and its affiliates, for Meta Lead Ads and WhatsApp Business Platform services;
• Base44, for application hosting, database and CRM functionality;
• Resend, for email delivery and related delivery events;
• infrastructure, security, monitoring and technical-support providers;
• professional advisers where reasonably necessary; and
• public authorities where disclosure is required or permitted by law.

Service providers may process information only for authorised purposes and subject to applicable contractual, confidentiality and security obligations.

We may also disclose information where necessary to protect rights, investigate misuse, comply with a lawful request, or establish, exercise or defend legal claims.

Some technology providers used by the App may process or store information outside South Africa. Where personal information is transferred internationally, we will take reasonably appropriate steps to ensure that the transfer is lawful and that the recipient is subject to an adequate level of protection, binding obligations, contractual safeguards or another lawful transfer mechanism.

We use reasonable administrative, organisational and technical safeguards designed to protect personal information against loss, unauthorised access, interference, alteration, disclosure or destruction. These measures include, where appropriate:

• authenticated and role-based access;
• restricted administrator permissions;
• server-side protection of access tokens and integration credentials;
• encrypted transmission;
• activity and audit records;
• webhook verification and duplicate-event controls;
• staff access controls and confidentiality obligations; and
• monitoring and response procedures for security incidents.

No method of transmission or storage is completely secure. If a security compromise involving personal information occurs, we will investigate and make notifications as required by applicable law.

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, to maintain required operational and consent records, resolve disputes, prevent unwanted communications, and comply with legal, accounting or regulatory obligations.

Retention periods may differ according to the nature of the record. When information is no longer authorised or required, we will delete, destroy, de-identify or securely archive it as appropriate. Limited suppression information may be retained after an opt-out so that we do not contact you again contrary to your preference.

Subject to applicable law, you may ask us to:

• confirm whether we hold personal information about you;
• provide access to your personal information;
• correct or update inaccurate or incomplete information;
• delete or destroy information that we are no longer authorised to retain;
• object to certain processing;
• withdraw consent where processing depends on consent;
• stop direct-marketing communications; or
• provide information about relevant recipients or categories of recipients.

To exercise these rights, email hello@cleancolon.co.za with the subject Privacy Request. We may need to verify your identity before acting on a request. Certain rights may be limited where retention or processing is required or permitted by law.

You may also lodge a complaint with South Africa's Information Regulator:

• Information Regulator (South Africa)
• Website: https://inforegulator.org.za/

You may request deletion of personal information obtained or processed through the CCH WhatsApp CRM App by:

• emailing hello@cleancolon.co.za;
• using the subject line Meta App Data Deletion Request; and
• providing the name, email address and WhatsApp number associated with your enquiry so that we can locate and verify the relevant records.

After verifying the request, we will delete or de-identify personal information that we are no longer authorised or required to retain. We may retain limited records where necessary to comply with law, establish or defend legal claims, prevent fraud, or preserve an opt-out request.

We will acknowledge the request and provide confirmation when it has been processed, subject to applicable legal requirements.

If Meta provides an automated user-data deletion callback for the App, requests received through that callback will be securely verified and processed in accordance with this section.

The App and CCH colon hydrotherapy services are intended for adults aged 18 years and older. We do not knowingly use the App to market these services to children. If we learn that a child's personal information has been collected inappropriately, we will take reasonable steps to delete or restrict it.

Messages or emails may contain links to our website, booking services or third-party platforms. Those services may have their own privacy practices. We encourage you to review the privacy notices presented by any third-party service you use.

We may update this policy when our practices, providers, App functionality or legal obligations change. The updated version will be published at the same public URL with a revised effective or last-updated date. Material changes may also be communicated through an appropriate channel.