Privacy Policy

1. Who we are

Bouwens Marketing Services ("Homing", "we", "us", "our") operates the Homing platform — a WhatsApp AI assistant service. We are responsible for the personal data we collect and process. You can reach us at hello@homing.pro.

2. What data we collect

We collect the following categories of personal data:

Account data — your email address and password hash when you register.
Business configuration — your business name, services list, tone settings, qualification questions, and tone-of-voice prompt that you enter in the dashboard.
WhatsApp message content — inbound and outbound message text that passes through your assistant, including the WhatsApp number (contact ID) of each person who messages you.
WhatsApp session credentials — encrypted authentication tokens and Signal protocol keys required to keep your WhatsApp linked-device connection active.
Lead data — name, phone number, and intent information extracted from conversations, stored as leads in your dashboard.
Calendar data — if you connect a calendar: OAuth access and refresh tokens, your calendar ID, and working-hours preferences (days, start/end time, meeting duration, timezone).
Usage data — conversation counts, plan tier, and timestamps.

3. How we use your data

We use the data we collect to:

Provide and operate the Homing service.
Send message content to the Claude AI model (operated by Anthropic, PBC) to generate assistant responses.
Detect and surface leads in your dashboard.
Enforce plan limits. Billing and payment details are handled directly by our payment processor and are not stored by us.
Send transactional emails (account confirmations, plan changes, service notices).
Investigate security incidents and comply with legal obligations.

4. Lawful basis (GDPR)

We process personal data on the following lawful bases under the GDPR:

Contract — to deliver the service you have subscribed to.
Legitimate interests — for security monitoring, fraud prevention, and product improvement, where those interests are not overridden by your rights.
Legal obligation — to comply with applicable laws and regulations.

5. AI transparency

To provide AI-powered functionality, we use Claude, an AI model operated by Anthropic, PBC. When your customers send messages to your WhatsApp assistant, that message content is sent to Anthropic's API to generate a reply. Anthropic does not use API traffic to train its models by default. No message content is used for any purpose other than generating the assistant's response.

See anthropic.com/privacy for Anthropic's full privacy policy.

6. Google Calendar

If you connect Google Calendar, we access your calendar data solely to read your availability and create appointments on your behalf. We use Google Calendar data only to provide and improve the appointment-booking functionality of Homing. We do not use Google user data for advertising, marketing, or any purpose unrelated to scheduling. Our use of data received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.

7. Third-party sub-processors

We share data with the following categories of sub-processors to operate the service:

Anthropic, PBC — AI model provider (see section 5). Located in the United States.
Railway — backend application hosting. Hosted in the EU-West region (Amsterdam, Netherlands).
Supabase — database hosting (PostgreSQL). Hosted in the EU-West-1 region (Ireland).
Vercel — frontend hosting and edge network. Served from EU edge regions (e.g. Frankfurt) where available.
Stripe, Inc. — payment processing and subscription management. Located in the United States. We do not store your full card details; all payment data is handled directly by Stripe.

We do not sell your data to any third party.

8. Your customers' data and the DPA

When your customers message you on WhatsApp and our assistant responds, their messages — including their WhatsApp number and message content — are stored in our database on your behalf. Under the GDPR, you are the data controller for your customers' data and we are your data processor. GDPR Article 28 requires a written Data Processing Agreement (DPA) to be in place between us. By accepting our Terms of Service you also accept our Data Processing Agreement, which sets out the full terms of how we process your customers' data.

As data controller you are responsible for:

Having a lawful basis (e.g. legitimate interests or contract) to process your customers' messages.
Informing your customers that an AI assistant may respond to their messages and that conversations are stored. This can be done via an auto-reply, your website privacy policy, or a WhatsApp status message.
Handling any data subject requests (access, erasure, etc.) from your customers and forwarding them to us if our assistance is needed.

9. Data retention

We apply the following retention periods:

WhatsApp message content — 12 months from the date of the message, then automatically deleted.
Lead data — 24 months from creation, or until you delete the lead manually.
WhatsApp session credentials — retained only while an active session exists; deleted immediately when you disconnect.
Calendar OAuth tokens — retained only while the calendar integration is connected; deleted immediately on disconnection.
Account and business configuration data — retained for the lifetime of your account, then deleted within 30 days of account closure.

You can request earlier deletion of any data by contacting us at hello@homing.pro.

10. Data transfers

Our application hosting (Railway, EU-West/Amsterdam), database (Supabase, EU-West-1/Ireland), and frontend hosting (Vercel, EU edge regions) are all located within the European Economic Area. The one exception is Anthropic, our AI model provider, which processes message content in the United States in order to generate assistant replies — there is currently no EU-only processing option for this service. For this transfer we rely on Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework, to ensure an adequate level of protection.

11. Your rights

Under the GDPR you have the right to:

Access — request a copy of the personal data we hold about you.
Rectification — ask us to correct inaccurate data.
Erasure — ask us to delete your data (subject to legal obligations).
Portability — receive your data in a machine-readable format.
Object — object to processing based on legitimate interests.
Restriction — ask us to restrict processing in certain circumstances.

To exercise any of these rights, email us at hello@homing.pro. To verify your identity before we act on your request, we will ask you to send a copy of a valid identity document. Please black out your photo, passport number, and any national ID number before sending — we only need your name and the document type to verify you. We will respond within four weeks. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

12. Security

We implement industry-standard security measures including encrypted connections (TLS), hashed passwords, and access controls. No method of transmission over the internet is 100% secure, and we cannot guarantee absolute security. We will notify you without undue delay if a data breach occurs that is likely to result in a high risk to your rights and freedoms.

13. Cookies

We use only essential session cookies required for authentication and to keep you logged in to the dashboard. We do not use tracking or advertising cookies.

14. Children

Homing is not directed at children under 16. We do not knowingly collect personal data from children. If you believe we have inadvertently done so, please contact us and we will delete the data promptly.

15. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you by email or in-app notice at least 14 days before material changes take effect. The "last updated" date at the top of this page reflects the most recent revision.

16. Contact

For any privacy-related questions or requests, contact our privacy team at hello@homing.pro.