Saker CRM Privacy Policy

Effective Date: January 1, 2026 Last Updated: September 16, 2026

1. Introduction

EPAIFA GENERAL TRADING L.L.C ("we", "us") takes the protection of your personal information seriously. The Service is offered to users worldwide. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you use Saker CRM (the "Service"), as well as the rights available to you. We will honor the rights afforded to you under the data protection laws applicable to your jurisdiction (including, without limitation, the UAE PDPL, the EU GDPR, and the PRC PIPL).

Please read this Policy carefully before using the Service. By using the Service, you agree to the processing of your personal information as described herein.

2. Information We Collect

2.1 Information You Provide

• Account information: name, phone number, email, company name, job title;
• Business data: customer records, sales data, quotations, follow-up notes, attachments, and other content you create or upload through the CRM;
• Feedback and communications: information you provide via email, phone, or support channels.

2.2 Information Collected Automatically

• Device and log data: IP address, browser type, operating system, access time, operation logs;
• Cookies and similar technologies: used for session management, security verification, and feature optimization.

2.3 Sensitive Personal Information

The Service may involve the following sensitive personal information (depending on what you input):

• Phone numbers
• Email addresses
• Customer or project requirement data

3. How We Use Information

We use your personal information for the following purposes:

1. Provide, maintain, and improve the Service;
2. Authentication, account management, and security;
3. Send service notifications, updates, and security alerts;
4. Customer support;
5. Statistical analysis to improve product experience (using de-identified or anonymized data);
6. Fulfill legal obligations;
7. Other purposes with your separate consent.

4. How We Share, Transfer, and Disclose Information

4.1 Sharing

We do not sell your personal information. We may share it only in the following cases:

• With your explicit consent;
• With third-party service providers necessary to deliver the Service (see Section 5);
• When required by law or government authorities;
• When necessary to protect our or users' legitimate rights.

4.2 Transfer

We do not transfer your personal information except with your consent or as required by law. In the event of merger, acquisition, or bankruptcy, we will require the recipient to abide by this Policy and notify you accordingly.

4.3 Public Disclosure

We will publicly disclose your personal information only with your explicit consent or as required by law.

5. Third-Party Services

The Service integrates or relies on the following third-party services. Each processes your information under its own privacy policy:

⚠ When using AI/LLM features, content you input may be transmitted to third parties for processing. Avoid entering sensitive trade secrets or personal information unless you understand and accept this.

5.1 Ad Platform Integrations (TikTok / Meta Marketing APIs)

When you, as an authorized user of your tenant, connect a TikTok Ads Manager account or a Meta Business advertiser account to Saker CRM via OAuth, we receive and process the following data through the respective Marketing APIs:

• Advertiser identifiers: TikTok Advertiser ID, Meta Ad Account ID, linked Page / identity IDs, display names and handles.
• Campaign metadata: campaign name, status, budget, schedule, and associated creative / identity references.
• Ad performance metrics: impressions, clicks, spend, conversions, and other aggregated metrics returned by the platform reporting endpoints.
• Lead Gen submissions (only if you enable the Lead Gen webhook subscription for a given advertiser): the end-user fields captured by the Instant Form / Lead Ad (for example name, phone, email) together with the platform-generated lead ID and the associated campaign / identity IDs.

We use this data only to:

1. display campaign and performance reports inside the CRM to authorized users of your tenant;
2. route newly submitted leads to your sales team for follow-up, assignment, and conversion;
3. attribute leads to the originating campaign and content account for reporting;
4. if you turn on Conversion feedback, send the processing outcome of leads from Meta lead forms (new lead, qualified, won, lost) together with the lead ID issued by Meta back to Meta to optimize your ad delivery; no phone numbers, emails or other contact details are sent.

We do not resell or share this data with any third party beyond the sub-processors listed above (cloud hosting, email, AI assistance as applicable) and the lead outcome feedback to Meta described in item 4 above. OAuth access tokens are stored encrypted at rest and are used only server-side to call the platform APIs on your behalf. You can revoke access at any time from the Ad Channels page in the CRM or from the platform's own settings; once revoked, we stop calling the API, mark the stored credentials as revoked, and delete data derived from the Meta Marketing API within thirty (30) days, except where retention is required by applicable law or for security incident response.

Data Deletion Requests. To request deletion of data we obtained on your behalf via the Meta Marketing API (or via the TikTok Marketing API), email contact@sakercrm.com with the subject line Meta data deletion request (or TikTok data deletion request) and include the connected ad account ID. We will confirm receipt within 5 business days and complete deletion within 30 days, unless retention is required by law.

Your use of the connected advertiser account is also subject to TikTok's and Meta's own terms and privacy policies; we process this data strictly under the scope you authorize via OAuth. Our processing of Meta Platform data is performed in accordance with Meta's Platform Terms and Meta's developer policies.

5.2 Gmail Mailbox Sync (Google Gmail API)

If you, as a salesperson using Saker CRM, choose to connect your Gmail account in your personal settings, we access that mailbox to (a) bring your correspondence with CRM customers and leads onto their cards, and (b) let you send or reply from the CRM using your own Gmail identity. Connecting is entirely optional, is initiated by you, and can be disconnected by you at any time.

Scopes requested. Two scopes only: the restricted scope https://www.googleapis.com/auth/gmail.readonly (read-only sync of correspondence), and the sensitive scope https://www.googleapis.com/auth/gmail.send (send or reply from the CRM using your connected Gmail). We do not request modify, delete, or full-mailbox control (gmail.modify, gmail.compose, or https://mail.google.com/). Mail is sent only from your connected Gmail, and only to customers or leads you own in the CRM. Managers can view the timeline but cannot send on your behalf. There is no bulk send.

What we ingest — and what we deliberately do not. We work in two stages. First, we retrieve only the message headers (sender, recipients, subject line, timestamp) and match the From / To / Cc addresses against the contact email addresses recorded for customers and leads within your own tenant. Only when a message matches a contact already recorded in your CRM do we then retrieve its body and attachments.

For messages that do not match any customer or lead — including your personal correspondence, vendor mail, newsletters, and any other private mail — we do not retrieve their full body or attachments, do not store them, and do not display them. During the address check, Google's header response also includes a very short preview snippet (roughly one to two hundred characters, which cannot be turned off via the API); those headers and that snippet are held only in memory for that single address check — we do not read the snippet's content, and they are discarded immediately and never stored. For matched messages only, we store: subject, message body, sender and recipient addresses, timestamp, and attachments.

How we use it. Read data is used solely to display correspondence on the matched customer's or lead's card inside the CRM. Send is used solely so you can email those customers or leads from Saker CRM as yourself. Nothing else.

Limited Use. Saker CRM's use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular:

• We do not use Gmail data for advertising, and we do not sell or transfer it to data brokers, information resellers, or any other third party.
• Saker's own personnel do not read your Gmail data, except (a) where you have given affirmative agreement for us to view specific messages, (b) where it is necessary for security purposes such as investigating a bug or abuse, (c) where it is necessary to comply with applicable law, or (d) where the data has been aggregated and anonymised for internal operations.
• We do not submit Gmail message content or attachments to any AI or large-language-model service, including the AI features described elsewhere in this Policy. Gmail data is excluded from those features.

Who inside your company can see it — please read this before connecting. The purpose of this feature is to put your correspondence with a customer onto that customer's card in your company's CRM. That means your colleagues will see it: specifically, the salesperson who owns the customer record and that salesperson's manager, under the same permission model that governs every other piece of customer data in the CRM. This is a deliberate, user-facing part of the feature, not an incidental disclosure — we state it on screen before you authorise, and connecting your mailbox is your agreement to it. If you are not comfortable with your manager seeing your correspondence with your customers, do not connect your mailbox. Correspondence is never visible to another tenant, and never to colleagues outside that permission scope.

Security and storage. OAuth access and refresh tokens are encrypted at rest and used only server-side to call the Gmail API on your behalf. Message content and attachments are stored in the Alibaba Cloud Dubai (UAE) Region, as described in Section 6, and are isolated per tenant. Message content is never written to our application logs.

Disconnecting. You can disconnect your Gmail account at any time from your personal settings in the CRM, or by revoking access at myaccount.google.com/permissions. On disconnection we immediately stop syncing and sending, and delete your stored OAuth tokens. Correspondence that was already synced is retained as part of your tenant's customer records — it is business correspondence belonging to the customer relationship, not to the connection, and removing it would erase your colleagues' record of that customer. If you or your tenant administrator want previously synced correspondence deleted, see the request path below; we will delete it.

Data Deletion Requests. To request deletion of correspondence we synced from your Gmail account, email contact@sakercrm.com with the subject line Gmail data deletion request, from the connected Gmail address or from your tenant administrator's account. We will confirm receipt within 5 business days and complete deletion within 30 days, unless retention is required by applicable law or for security incident response.

5.3 Facebook and Instagram Direct Messages (Meta Messenger Platform)

If an authorized administrator of your tenant connects a Facebook Page — and, where applicable, the Instagram professional account linked to that Page — to Saker CRM via Facebook Login for Business, we receive and process direct messages sent to that Page or Instagram account so that your team can read and reply to them from a single inbox inside the CRM.

Permissions requested. pages_show_list, pages_messaging, pages_manage_metadata, business_management, instagram_basic, and instagram_manage_messages. We request no other Meta messaging permission.

What we receive and store.

• Connected asset identifiers: the Facebook Page ID and, where linked, the Instagram account ID, together with their display names.
• Sender identifiers: the platform-scoped user ID that Meta issues for the person messaging the Page (a Page-Scoped ID for Messenger, an Instagram-Scoped ID for Instagram) and the display name Meta returns with it. These IDs are scoped to the connected Page — they are not the person's Facebook or Instagram account ID, and they cannot be used to look that person up elsewhere on Meta's platforms. We do not receive, request, or store the person's Facebook or Instagram profile, friend list, email address, or phone number from the messaging APIs.
• Message content: the text of each message, its direction (inbound or outbound), its timestamp, the platform's message ID, and delivery status. Message bodies are encrypted at rest using AES-256-GCM.
• Attachments: images, audio, video, and documents sent in the conversation are downloaded to private (non-public) object storage in the Alibaba Cloud Dubai (UAE) Region, as described in Section 6.

How we use it. Solely to operate the messaging inbox for the connected business: displaying the conversation to authorized users of that tenant, letting them reply as the Page, and — only when a staff member explicitly confirms the match — linking a conversation to an existing customer, contact, or lead record in that tenant's CRM. Conversations are not linked to customer records automatically.

What we do not do.

• We do not use Messenger or Instagram message data for advertising, ad targeting, or audience building.
• We do not sell or transfer this data to data brokers, information resellers, or any other third party.
• We do not use message content to train any AI or machine-learning model.
• Messages received by one tenant are never visible to any other tenant.

Optional processing. If your tenant enables the AI follow-up summary or inbox translation features, message text may be sent to the sub-processors named in Section 5.5. See that section for exactly what is sent and what is not.

If you messaged a business that uses Saker CRM. When you send a direct message to a Facebook Page or Instagram account, that business — not Saker — decides how it handles your message, and it is the controller of that conversation; Saker processes it on the business's behalf as a service provider. You may ask for your messages to be deleted from our systems using the request path below, and we will action it whether or not you are a customer of ours. You can also stop the flow of new messages at any time by ceasing to message the Page, or by using Meta's own controls to block or report it.

Disconnecting. A tenant administrator can unbind a Page or Instagram account at any time from the Channel Connections page in the CRM, or revoke Saker's access from Facebook Settings → Business Integrations. On disconnection we immediately stop receiving new messages, unsubscribe from the Page's message webhooks, and delete the stored access token. Conversations already received remain in that tenant's records as business correspondence; to have them deleted as well, use the request path below.

Data Deletion Requests. To request deletion of Facebook or Instagram message data held in Saker CRM, email contact@sakercrm.com with the subject line Meta messaging data deletion request. Please include the Facebook Page or Instagram account the conversation was with, and either the sender's handle or an approximate date range, so we can locate the conversation. We will confirm receipt within 5 business days and complete deletion within 30 days, unless retention is required by applicable law or for security incident response. Deletion covers the stored message bodies, attachments, and sender identifiers for the conversations concerned.

Our processing of Meta Platform data is performed in accordance with Meta's Platform Terms and Meta's developer policies. Your use of Messenger and Instagram is also subject to Meta's own terms and privacy policy.

5.4 TikTok Direct Messages (TikTok Business Messaging API)

Status: not yet live. Saker CRM has applied to TikTok for access to the Business Messaging API and has not yet been granted it. This section states how we will process TikTok direct-message data once access is granted and a tenant connects an account. Until then we neither receive nor store any TikTok direct-message data.

If an authorized administrator of your tenant connects their own TikTok Business Account to Saker CRM via TikTok OAuth, we receive and process direct messages sent to that account, so that your team can read and reply to them from the same inbox they already use for WhatsApp, Messenger and Instagram.

Permissions requested. message.list.read, message.send, and message.manage, scoped to the TikTok Business Account you authorize. We request no other TikTok messaging permission.

What we receive and store.

• Connected account identifiers: the TikTok Business Account ID and its display name / handle.
• Sender identifiers: the conversation-scoped user ID TikTok issues for the person messaging the business account, and the display name TikTok returns with it. We do not receive, request, or store that person's TikTok profile, follower or following list, email address, or phone number.
• Message content: the text of each message, its direction (inbound or outbound), its timestamp, TikTok's message ID, and delivery status. Message bodies are encrypted at rest using AES-256-GCM.
• Attachments: images and other media sent in the conversation are downloaded to private (non-public) object storage in the Alibaba Cloud Dubai (UAE) Region, as described in Section 6.

How we use it. Solely to operate the messaging inbox for the connected business: displaying the conversation to authorized users of that tenant, letting them reply as the business within TikTok's permitted reply window, and — only when a staff member explicitly confirms the match — linking a conversation to an existing customer or lead record in that tenant's CRM. Conversations are never linked to customer records automatically, and never by TikTok identity: a match is only ever proposed when the user has voluntarily typed a phone number or email address into the chat.

What we do not do.

• We never initiate a conversation. We send only in reply to a user who has messaged the business first, and only within TikTok's permitted reply window. Saker CRM provides no bulk send, no broadcast, and no marketing outreach over TikTok messaging.
• We do not use TikTok message data for advertising, ad targeting, or audience building.
• We do not sell or transfer this data to data brokers, information resellers, or any other third party.
• We do not use message content to train any AI or machine-learning model.
• Messages received by one tenant are never visible to any other tenant.

Optional processing. If your tenant enables the AI follow-up summary or inbox translation features, message text may be sent to the sub-processors named in Section 5.5. See that section for exactly what is sent and what is not.

If you messaged a business that uses Saker CRM. When you send a direct message to a TikTok Business Account, that business — not Saker — decides how it handles your message, and it is the controller of that conversation; Saker processes it on the business's behalf as a service provider. You may ask for your messages to be deleted from our systems using the request path below, and we will action it whether or not you are a customer of ours.

Disconnecting. A tenant administrator can unbind a TikTok Business Account at any time from the Channel Connections page in the CRM, or revoke Saker's access from TikTok's own settings. On disconnection we immediately stop receiving new messages, unsubscribe from the account's message webhooks, and delete the stored access token. Conversations already received remain in that tenant's records as business correspondence; to have them deleted as well, use the request path below.

Data Deletion Requests. To request deletion of TikTok message data held in Saker CRM, email contact@sakercrm.com with the subject line TikTok messaging data deletion request. Please include the TikTok Business Account the conversation was with, and either the sender's handle or an approximate date range, so we can locate the conversation. We will confirm receipt within 5 business days and complete deletion within 30 days, unless retention is required by applicable law or for security incident response. Deletion covers the stored message bodies, attachments, and sender identifiers for the conversations concerned.

Your use of TikTok is also subject to TikTok's own terms and privacy policy. We process TikTok data strictly under the scope you authorize via OAuth, and in accordance with TikTok's developer terms and policies.

5.5 Optional AI and Translation Processing of Inbox Messages

Two optional inbox features send the text of conversations to a sub-processor named in the table above. Both are off unless your tenant has them enabled, and each applies only to the tenant that enabled it.

• AI follow-up summaries. Where enabled for your tenant, the text of the recent messages in a conversation is sent to our LLM provider so it can draft a follow-up log entry for the salesperson. Only message text is sent — attachments, images, audio and documents are never sent; a media message is represented to the model by its type alone (for example, "sent an image, no text").
• Inbox translation. Where a machine-translation provider is configured, and only when a user presses translate on a specific message or on a draft reply, that single message or draft is sent to the translation provider.

This applies equally to WhatsApp, Facebook, Instagram and — once live — TikTok conversations. We do not use message content to train any AI or machine-learning model, and we do not send message content to these providers for any other purpose.

6. Data Location and Cross-Border Transfer

The Service is offered to users worldwide, with primary data storage located in the Alibaba Cloud Dubai (UAE) Region. Certain third-party providers (e.g., Google email, OpenAI, DeepSeek) operate servers in other countries or regions. Accordingly, regardless of your location, your information may be transmitted to and processed in a country or region outside your own. We commit to:

• Minimizing the scope of personal information transferred;
• Requiring overseas recipients to apply safeguards consistent with generally accepted international security standards;
• Fulfilling compliance obligations under the laws applicable to your jurisdiction (including but not limited to UAE PDPL, EU GDPR, and PRC PIPL), such as personal information protection impact assessments, separate user consent, and Standard Contractual Clauses (SCCs), where applicable;
• Notifying you and obtaining any required consent at registration or other key points involving cross-border processing.

If you do not agree to such cross-border transfers, some features may not be available.

7. Data Storage

7.1 Location

Data is primarily stored on Alibaba Cloud Dubai (UAE) Region infrastructure.

7.2 Retention

• While the account is active: retained continuously;
• After account deletion: retained for 15 days for possible recovery, then permanently deleted or anonymized;
• Longer retention applies where required by law (e.g., logs retained for ≥ 6 months).

7.3 Backup

We perform periodic backups to ensure business continuity. Backup strategy is governed by internal security standards (recommended: daily full backup plus hourly incrementals).

8. Information Security

We apply the following measures to protect your personal information:

• Encryption in transit: HTTPS/TLS;
• Access control: role-based access control (RBAC), least-privilege principle;
• Tenant isolation: multi-tenant data is separated by tenantId;
• Audit logs: critical operations are logged;
• Periodic security assessments: vulnerability scanning, code review.

Despite these reasonable safeguards, no system on the internet is absolutely secure. In the event of a data breach, we will notify you promptly in accordance with applicable law and take remedial action.

9. Your Rights

Subject to the data protection laws applicable to your jurisdiction (including but not limited to the UAE PDPL, the EU GDPR, and the PRC PIPL), you have the following rights regarding your personal information:

1. Right to be informed and to decide how your information is processed;
2. Right of access and copy;
3. Right to correction and supplementation;
4. Right to deletion, where applicable;
5. Right to withdraw consent;
6. Right to data portability — you may obtain a copy of your data via the in-product self-service export;
7. Right to an explanation of our processing rules;
8. Right to deregister your account (via self-service or support).

To exercise these rights, contact: contact@sakercrm.com. We will respond within the time limits required by law.

10. Children's Privacy

The Service is intended for enterprise users and is not directed to minors under 18. Minors should review this Policy with their guardian and use the Service only with guardian consent.

11. Updates to This Policy

We may update this Policy from time to time. Updated versions will be notified via email or posted on our corporate website. For material changes (e.g., new processing purposes or new third-party sharing), we will provide more prominent notice and obtain renewed consent where necessary.

12. Contact Us

For questions, comments, or complaints about this Policy, or to exercise your rights:

• Email: contact@sakercrm.com
• Phone: +971 58 581 4667
• Address: 504, Al Khor Building, Baniyas Road, Deira, Dubai, United Arab Emirates

We will respond within 15 business days of receipt.

We have not appointed a dedicated Data Protection Officer (DPO) at this time. For complaints regarding personal information protection, you may also report to the UAE Data Office or your local data protection authority.