Jenny By Growthful, Privacy Policy

Effective Date: 01.08.2026  ·  Last Updated: 01.09.2026

This Privacy Policy explains how Growthful Ventures Pte. Ltd. ("Growthful," "we," "us," or "our"), the operator of Jenny, a WhatsApp-native AI receptionist service ("Jenny" or the "Service"), collects, uses, discloses, and protects personal data in connection with your use of the Service.

This Policy is addressed to businesses that subscribe to Jenny (each, a "Client," "you," or "your") — for example, gyms, hair salons, and aesthetic clinics — and describes our practices as the data intermediary/processor handling data on your behalf, as well as our practices as a data controller for your own account information.

1. Who We Are

Growthful Ventures Pte. Ltd. is a company incorporated in Singapore. We can be reached at hello@heygrowthful.com for any privacy-related questions, requests, or concerns.

2. Scope of This Policy

Jenny operates on WhatsApp and communicates with your end customers on your behalf to handle inquiries, bookings, and appointment-related conversations. Two categories of personal data are relevant:

• Your Account Data — information you provide to us as a Client (e.g., business name, contact person, billing details) — Growthful acts as a data controller for this data.
• End Customer Data — information your customers share with Jenny via WhatsApp (e.g., name, phone number, appointment details) — Growthful acts as a data intermediary/processor on your behalf for this data, and you remain responsible as the data controller for your own customers under the Singapore Personal Data Protection Act 2012 ("PDPA").

3. What Data Jenny Collects

When your customers interact with Jenny via WhatsApp, we collect:

• Name
• Phone number (WhatsApp identifier)
• Appointment details (e.g., service requested, preferred date/time, booking status)
• Conversation history

We do not currently collect payment information, health/medical data, or other sensitive categories of personal data through Jenny.

4. How We Use the Data

We use End Customer Data solely to:

• Operate the WhatsApp conversation and respond to inquiries
• Schedule, confirm, reschedule, or cancel appointments on your behalf
• Escalate conversations to a human team member at your business when needed
• Improve the underlying AI system's performance for your account

We use Client Account Data to manage your subscription, provide support, and communicate with you about the Service.

5. Third Parties and Sub-processors

To provide the Service, Jenny relies on the following categories of third-party providers, which process message content and/or End Customer Data as part of delivering the Service:

• Meta / WhatsApp Business API — used to send and receive WhatsApp messages
• A large language model (AI) provider — used to generate Jenny's conversational responses
• Your booking/calendar system (e.g. Pike13, or another tool you already use) — Jenny integrates with the system you use to manage appointments; you remain responsible for that vendor's own data handling

We only share the minimum data necessary with these providers to operate the Service, and we require that they handle data in a manner consistent with applicable data protection obligations.

6. Where Data Is Stored

Data collected through Jenny is stored in Singapore. Application processing (running the WhatsApp conversation and workflow logic) takes place on infrastructure located in Indonesia. Personal data may therefore be transferred outside Singapore in the course of providing the Service; where this occurs, we take appropriate steps to ensure the recipient provides a standard of protection comparable to that required under the PDPA, consistent with the PDPA's Transfer Limitation Obligation (Section 26).

7. Data Retention

We retain chat and appointment data for 13 months from the date of the last interaction, after which it is deleted or anonymized, unless a longer retention period is required by law or requested by you for legitimate business purposes.

8. Your Responsibilities as a Client

As the data controller for your end customers, you are responsible for:

• Ensuring you have a lawful basis (e.g., consent or deemed consent) for your customers' data to be collected and processed via Jenny
• Providing your customers with appropriate notice that they are interacting with an AI-powered service
• Directing any data access, correction, or deletion requests from your customers to us at hello@heygrowthful.com so we can assist

9. Data Security

We implement reasonable technical and organizational measures to protect personal data processed through Jenny against unauthorized access, disclosure, alteration, or destruction.

10. Your Rights (PDPA)

Subject to applicable exceptions under the PDPA, individuals may request:

• Access to personal data we hold about them
• Correction of inaccurate personal data
• Withdrawal of consent for further collection, use, or disclosure of their data

Requests should be directed to hello@heygrowthful.com. As Growthful acts as a data intermediary for End Customer Data, we will support Clients in responding to such requests from their customers.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated to Clients via email or through the Service.

12. Contact Us

For any questions about this Privacy Policy or our data practices, please contact:

Growthful Ventures Pte. Ltd.
Email: hello@heygrowthful.com