Privacy Policy

This Privacy Policy describes how Francisco Javier Jaramillo LLC, doing business as Gain With Media ("Company," "we," "us," or "our"), collects, uses, and discloses information about you when you access or use gainwithmedia.com and any services we provide, including the HABLALO WhatsApp automation platform (collectively, the "Services").

By using our Services you agree to the collection and use of information as described in this policy. If you do not agree, please discontinue use of the Services.

1. Information We Collect

1.1 Information You Provide Directly

• Contact information — your name, email address, phone number, and business name when you fill out a contact form, request a quote, or start a project with us.
• Account credentials — username, password, and business details if you register for a HABLALO subscription.
• Billing information — billing address and payment method details, which are handled by third-party payment processors. We do not store full card numbers on our own servers.
• Communications — messages, support requests, and feedback you send to us.

1.2 Information Processed Through the HABLALO Platform

HABLALO is a WhatsApp Business automation service built on the WhatsApp Business Platform (Cloud API) operated by Meta Platforms, Inc. Our use of this platform is governed by the WhatsApp Business Policy and the Meta Platform Terms, and all data processing described below is carried out in compliance with those terms. When end-customers interact with a WhatsApp Business number managed through HABLALO, the platform processes the following data on behalf of our business subscribers:

• Phone numbers — the sender's WhatsApp phone number as provided by the WhatsApp Business Platform.
• Display name — the WhatsApp profile name associated with the sender's account, if available.
• Message content — text messages, quick-reply selections, and any information the end-customer voluntarily shares during the conversation.
• Messaging metadata — timestamps, message status (sent, delivered, read), automated-flow identifiers, and session identifiers.
• Customer-provided data — order or product interest data voluntarily provided by end-customers (e.g., item inquiries, quantities, delivery information).

In this context, Gain With Media acts as a data processor on behalf of the HABLALO subscriber (the business client), who is the data controller responsible for obtaining appropriate consent from their end-customers under applicable law and the WhatsApp Business Policy.

1.3 Automatically Collected Technical Data

• Server log data — IP address, browser type and version, operating system, referring URL, pages visited, and access timestamps when you visit our website.
• Session cookies — small identifiers stored in your browser to maintain your session and basic site preferences. See Section 7 for more detail.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve our Services.
• Process HABLALO subscriptions, manage accounts, and deliver billing and support communications.
• Power the AI-assisted first-response, quick-reply, and human-escalation features within HABLALO.
• Respond to inquiries and business communications.
• Send transactional messages — account confirmations, billing receipts, service alerts, and product updates.
• Comply with applicable legal obligations and enforce our Terms of Service.
• Analyze aggregated, de-identified usage trends to improve product performance and reliability.

We do not sell your data or end-customer WhatsApp conversation data to third parties. We do not use end-customer conversation data — including any WhatsApp message content or phone numbers — to train general-purpose AI or machine learning models, and we do not use such data to build advertising profiles for any party. Data processed through the WhatsApp Business Platform is used solely to operate and deliver the HABLALO messaging automation service as described in this policy.

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share it only in the following limited circumstances:

• Service providers — third-party vendors who assist with hosting, payment processing, transactional email, and analytics. These providers are contractually bound to handle data only as directed by us and to maintain appropriate confidentiality.
• Meta Platforms / WhatsApp Business Platform — message data is transmitted through Meta's Cloud API infrastructure as a required technical dependency of the HABLALO service. Meta's own data practices are governed by Meta's Privacy Policy and WhatsApp Business Policy.
• Legal requirements — when required by applicable law, regulation, court order, or governmental authority; or when necessary to protect the rights, property, or safety of our Company, clients, end-customers, or the public.
• Business transfers — in connection with a merger, acquisition, asset sale, or restructuring, subject to appropriate confidentiality and data-protection obligations for any affected users.

4. WhatsApp Business Platform — Specific Disclosures

HABLALO uses the WhatsApp Business Platform (Cloud API) operated by Meta Platforms, Inc. Our use of that platform is governed by Meta's WhatsApp Business Policy and Meta Platform Terms.

For end-customers who interact with a WhatsApp number powered by HABLALO:

• All messages are transmitted over Meta's infrastructure and subject to WhatsApp's end-to-end encryption and data practices.
• The business client (HABLALO subscriber) is responsible for disclosing to their customers that an automated system may respond to messages on their behalf.
• End-customers may opt out of automated messaging at any time by replying STOP to any HABLALO-powered number. We will honor opt-out requests within one business day.

5. Data Retention

We retain account and subscription data for as long as your account remains active, and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements — typically no longer than 3 years following account closure.

End-customer conversation logs processed through HABLALO are retained for up to 12 months from the date of each conversation, after which they are purged from active storage. HABLALO subscribers may request earlier deletion of their data by contacting us (see Section 6).

6. Your Rights and Choices

Depending on your location and the laws applicable to you, you may have the following rights regarding your personal information:

• Access — request a copy of the personal data we hold about you.
• Correction — request correction of inaccurate or incomplete information.
• Deletion — request deletion of your personal data, subject to any legal retention requirements.
• Portability — request your data in a structured, machine-readable format where technically feasible.
• Opt-out of marketing emails — unsubscribe at any time via the link in any marketing email we send.
• Opt-out of WhatsApp automated messaging — if you are an end-customer interacting with a HABLALO-powered WhatsApp number, you may opt out of automated messages at any time by replying STOP. We will honor opt-out requests within one business day and will not send further automated messages to that number unless you re-initiate contact.

To exercise any of these rights, please contact us at info@gainwithmedia.com. We will respond within 30 days.

7. Cookies

Our website uses essential session cookies required for basic functionality. We may also use analytics cookies to understand aggregate, anonymous traffic patterns and improve site performance. You can control or disable cookies through your browser settings; however, doing so may affect certain website features. We do not use cookies to serve behavioral advertising.

8. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, and we encourage you to use strong, unique passwords for any accounts you hold with us.

9. Children's Privacy

Our Services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at info@gainwithmedia.com and we will take prompt steps to delete such information.

10. Third-Party Links

Our website and communications may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any external services you access.

11. Changes to This Policy

We may update this Privacy Policy periodically. When we do, we will revise the "Last updated" date at the top of this page. Material changes will be communicated to active subscribers via email or via a prominent notice on our website. Your continued use of the Services after changes become effective constitutes your acceptance of the updated policy.

12. Contact Us

For questions, concerns, or to exercise your privacy rights, please contact us:

• Email: info@gainwithmedia.com
• Phone: +1 (904) 599-2075
• Mailing address:
  Francisco Javier Jaramillo LLC (DBA Gain With Media)
  St. Augustine, FL, USA