Privacy Policy — WhatsApp Business API

1. Data Controller

The data controller responsible for processing your personal data via WhatsApp is:

BROTHERS E.L.B. GROUP LTD ("E-Projects")
Company No. 516598968
8 Hatnufa Street, Jerusalem, Israel
Contact: avi@e-projects.fr

2. Scope of this Policy

This policy describes how we process personal data when you communicate with E-Projects Real Estate through the WhatsApp messaging service, using the WhatsApp Business API provided by Meta Platforms, Inc.

It applies only to WhatsApp conversations. Any other channel (email, phone, in-person) is governed by our general privacy policy.

3. Data We Collect

• Your WhatsApp phone number and display name
• Message content you send us and our replies (text, voice notes, images, documents you choose to share)
• Metadata automatically provided by WhatsApp/Meta: timestamps, delivery and read status, message type
• Information you voluntarily provide about your real-estate search (budget, desired area, property type, nationality, financing status, etc.)

4. Purposes of Processing

We use this data exclusively to:

• Respond to your real-estate inquiries
• Send you information about properties matching your search (apartments, projects, pricing) — only when you have explicitly initiated the conversation or requested such information
• Organize property viewings, video calls, and follow-ups
• Comply with our legal and accounting obligations

We do not send unsolicited marketing messages. You can opt out at any time by replying "STOP".

5. Legal Basis (GDPR)

For users located in the European Union, processing is based on:

• Art. 6(1)(b) GDPR — performance of pre-contractual measures (responding to your request for information about a property)
• Art. 6(1)(a) GDPR — your explicit consent, when you request to receive information about additional properties
• Art. 6(1)(f) GDPR — our legitimate interest in managing customer relations and preventing fraud
• Art. 6(1)(c) GDPR — compliance with legal obligations (record-keeping, anti-money-laundering where applicable)

6. WhatsApp / Meta as Processor

WhatsApp (Meta Platforms, Inc., USA) acts as a processor / sub-processor for the delivery of messages. Meta may process certain data for its own purposes (security, abuse prevention, service improvement) as described in Meta's privacy policy. We have no control over Meta's own processing of message content transmitted via WhatsApp infrastructure.

7. Data Retention

• Active conversation data: kept for the duration of our business relationship + 3 years
• Marketing-related messages: until you opt out or 3 years of inactivity, whichever comes first
• Accounting/contractual records: 10 years (Israeli and French legal obligations)

8. Your Rights

You have the right to access, rectify, delete, restrict, port your data, and to object to processing or withdraw consent. You may also lodge a complaint with your local data protection authority.

To exercise these rights: avi@e-projects.fr

9. International Transfers

Your data is processed from Israel (controller) and may transit through Meta's infrastructure located outside the European Economic Area (primarily the United States). Data hosting for our own systems (CRM, conversation storage) is located within the EU. Transfers to Israel benefit from the European Commission's adequacy decision of 31 January 2024. Transfers to the United States are protected by Meta's Standard Contractual Clauses (SCCs) and equivalent safeguards.

10. Security

We use industry-standard measures (encryption in transit via TLS, access controls, minimal-access principle) to protect your data. Our WhatsApp Business API access is restricted to authorized personnel only.

11. Changes to this Policy

We may update this policy. The "Last updated" date at the top reflects the most recent change. Material changes will be communicated via WhatsApp where appropriate.

13. Contact

For any privacy question: avi@e-projects.fr