Thinky Creates Privacy Policy — last updated 13 September 2026
Thinky Creates ("Thinky", "we", "us") is a business software platform operated by Thinky Trading and Marketing W.L.L., Doha, Qatar. This policy explains what personal data we process, why, and the rights you have. It covers our website (thinkycreates.com), the Thinky OS platform and its modules (including Thinky Connect, our customer-service and messaging module), and our Meta app "Thinky OS" (App ID 1390265819290138).
1. Who we are in relation to your data
Thinky OS is used by retail businesses ("Customers"). When a Customer uses Thinky OS to communicate with its own shoppers ("End Users") over WhatsApp, Facebook Messenger, Instagram or web chat, the Customer decides why and how that data is used; Thinky processes it on the Customer's instructions. In that relationship the Customer is the data controller and Thinky is the data processor. For data about our own website visitors and our Customers' staff accounts, Thinky is the controller.
2. Data we process
On behalf of Customers: End-User messages and attachments sent to a Customer's connected WhatsApp, Messenger or Instagram accounts; End-User names, phone numbers and profile details as provided by those platforms; order, delivery and purchase information the Customer connects from its own systems (for example an ERP or online store); campaign delivery status; opt-out (STOP) requests.
As controller: Customer staff account details (name, work email, role, login activity), billing contacts, support requests, website analytics in aggregate, and technical logs (IP address, browser, timestamps) needed for security.
3. Why we process it
To deliver the service: routing and displaying conversations, sending replies and approved template messages, keeping order and delivery information available to agents, running campaigns the Customer creates, and honouring opt-outs. To keep the service secure and reliable (authentication, audit logs, backups, abuse prevention). To bill and support Customers. To comply with law.
4. AI features
Thinky OS includes AI-assisted features such as suggested replies, automated answers to shopper questions, translation and voice-note transcription. To provide them, the relevant conversation text or audio is sent to a third-party AI model provider under a contract that prohibits the provider from using the content to train its models. Customers can turn AI features off per channel. AI outputs are suggestions; the Customer remains responsible for what is sent to End Users.
5. Meta platform data
Our Meta app "Thinky OS" (App ID 1390265819290138) lets Customers connect their own WhatsApp Business, Facebook Page and Instagram professional accounts. We receive the access tokens, account identifiers, messages and delivery events required to send and receive messages on the Customer's behalf. We use this data only to provide the messaging features the Customer has enabled, in accordance with Meta's Platform Terms and Developer Policies and the WhatsApp Business Terms. We do not sell it, use it for advertising, or share it with anyone other than the Customer and the sub-processors listed below.
6. Sub-processors
Hosting and backups: virtual servers and object storage operated by our hosting providers Hostinger International (virtual servers), Backblaze B2 (object storage for encrypted backups, EU Central region) and Google Drive (a second encrypted backup copy). Messaging: Meta Platforms (WhatsApp, Messenger, Instagram). AI: our AI model provider. Payments: we invoice Customers directly and do not process card payments through the Service. E-mail: Google (Gmail), for support correspondence; the Service does not send marketing e-mail on our own behalf. We keep this list current on request.
7. Retention
Conversation data is kept for as long as the Customer's subscription is active and, unless the Customer configures a shorter period, for 90 days after the subscription ends, after which it is deleted from live systems; encrypted backups are deleted within 60 days after that. For the first 30 days after the subscription ends the Customer's workspace is read-only, so its users can still sign in and export its data. Account and billing records are kept as required by Qatar law. Security logs are kept for 12 months.
8. Security
Data is encrypted in transit (TLS) and at rest for credentials and backups. Access is limited to authorised staff under role-based permissions with audit logging. Each Customer runs in an isolated instance with its own database.
9. International transfers
Data may be processed in the countries where our sub-processors operate. Where required, we use contractual safeguards.
10. Your rights
Depending on your location you may have rights to access, correct, delete, restrict or export your personal data, and to object to processing. End Users should contact the Customer (the business they messaged) first, because Thinky acts on that business's instructions; we will assist the Customer. Customers and their staff can contact us directly. See our Data Deletion page for how to request deletion.
11. Children
Thinky OS is a business tool and is not directed at children. We do not knowingly collect data from children under 13 (or the age required by local law).
12. Changes
We will post any changes on this page with a new "last updated" date.
13. Contact
Thinky Creates, Thinky Trading and Marketing W.L.L., Doha, Qatar — create@thinkycreates.com.