Privacy Policy

This Privacy Policy explains how Foreman L.L.C-FZ (Foreman, we, us, or our), a free zone limited liability company registered in the United Arab Emirates, collects, uses, and protects personal information when you use the Apex38 platform, website, and related services (the Service).

1. Who We Are

Foreman L.L.C-FZ is the data controller for the personal information processed to operate the Service and provide it to you. For any privacy question, you can reach us at hello@apex38.com.

2. Information We Collect

• Account information — such as your name, email address, phone number, and organisation details.
• Connected channel data — information needed to link your messaging accounts, including WhatsApp, such as the connected number and session status.
• Lead and contact data — the names, phone numbers, notes, and message history of the leads and contacts you import or manage in the Service.
• Content you create — messages, campaigns, stories, and other material you generate or schedule.
• Usage and device data — log data such as IP address, browser type, pages viewed, and timestamps, collected automatically when you use the Service.

3. How We Use Information

• To provide, operate, maintain, and improve the Service.
• To schedule, automate, and deliver the messages and follow-ups you configure.
• To generate AI-assisted content such as suggested messages and stories.
• To understand the replies your leads send — interest, questions, automatic replies, and requests not to be contacted again — and act on them, for example by no longer messaging a lead who asks to stop.
• To produce analytics and insights about your pipeline and performance.
• To secure the Service, prevent abuse, and provide customer support.
• To comply with legal obligations and enforce our terms.

4. Messaging Data

To enable scheduling and automation, the Service processes the content and metadata of messages you send and receive through connected channels. Messages are transmitted through your own connected accounts. Apex38 is not affiliated with WhatsApp LLC or Meta Platforms, Inc., and their handling of your data is governed by their own policies.

If you use email newsletters, the Service stores the names, email addresses and, where your CRM has them, phone numbers of the contacts you import from your CRM (such as Bitrix24) or from a file, and sends your newsletters through our email delivery provider, Resend. Every newsletter carries an unsubscribe link, and a contact who unsubscribes is never emailed from your account again.

5. AI Processing

When you use AI features, relevant content may be sent to reputable third-party AI providers that process it to generate the requested output. Some features also run automatically: the text of replies your leads send and the names under which your contacts are saved may be analysed to recognise what a reply means, which word in a saved name is the person's first name, and whether a contact looks like a client. These providers currently include Google (Gemini), for writing and translating content, and TypeSafe AI (Jev), for classifying replies and saved contact names. We take reasonable steps to work only with providers that offer appropriate confidentiality and security commitments.

6. How We Share Information

We do not sell your personal information. We share it only as follows:

• Service providers — hosting, infrastructure, analytics, messaging, and AI vendors who process data on our behalf under appropriate safeguards.
• Legal and safety — where required by law or to protect the rights, safety, and security of Foreman, our users, or the public.
• Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this Policy.

7. Your Responsibilities

For the lead and contact data you import into the Service, you act as the controller of that data. You are responsible for having a lawful basis and any required consent to collect and process it, and for responding to the privacy requests of your own contacts.

8. Data Retention

We retain personal information for as long as your account is active or as needed to provide the Service, and thereafter as required to comply with our legal obligations, resolve disputes, and enforce our agreements. You may request deletion of your data as described below.

9. Data Security

We use technical and organisational measures designed to protect personal information against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

10. International Transfers

We operate from the United Arab Emirates and may process and store information in other countries where our service providers operate. Where required, we put appropriate safeguards in place for such transfers.

11. Your Rights

Subject to applicable law, you may request access to, correction of, or deletion of your personal information, and you may object to or restrict certain processing. To exercise these rights, contact us at hello@apex38.com.

12. Cookies

The Service uses cookies and similar technologies to keep you signed in, remember your preferences, and understand how the Service is used. You can control cookies through your browser settings, though some features may not function properly without them.

13. Children's Privacy

The Service is intended for business use by adults and is not directed to children under 18. We do not knowingly collect personal information from children.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the date above and, where appropriate, provide additional notice.

15. Contact Us

If you have questions about this Privacy Policy or how we handle your information, contact Foreman L.L.C-FZ at hello@apex38.com.