Privacy Policy

Last updated August 20, 2026

This Privacy Policy explains what personal data Musak Leads Media (“Musak Leads,” “we,” “us”) collects, why we collect it, how it is used and shared, and the choices available to you. It applies to the Musak Leads website and CRM application, and to data processed through our integration with the WhatsApp Business Platform (Cloud API) operated by Meta Platforms, Inc. (“Meta”).

1. Data Controller vs. Data Processor

Your relationship with Musak Leads depends on who you are, and the role we play changes accordingly:

  • If you are a business using Musak Leads (a "Tenant") to manage your own leads and contacts, Musak Leads CRM acts as a Data Processor on your behalf. You are the Data Controller for the personal data of your leads, contacts, and end-customers — you decide what data to collect from them and why, and we process it strictly on your instructions to provide the service. The specific terms of that processing relationship are set out in our Data Processing Agreement.
  • For your own registration and payment data — the information you give us directly to create and pay for your Musak Leads account (name, business email, billing details) — Musak Leads is the Data Controller, and this Privacy Policy governs that data directly.

2. Meta / WhatsApp Cloud API Disclosure

Musak Leads uses Meta Platforms, Inc. and the official WhatsApp Business Platform (Cloud API) to send, receive, and store WhatsApp messages on your behalf. This means:

  • Your contacts' phone numbers, message contents, and associated metadata (timestamps, delivery/read status) necessarily pass through Meta's infrastructure as part of how WhatsApp messaging works — this is not optional to the service and cannot be disabled while using WhatsApp features.
  • Meta acts as an independent data processor/sub-processor for this data under its own terms; Meta's handling of that data is additionally governed by Meta's WhatsApp Business Data Processing Terms.
  • We do not control, and are not responsible for, Meta's own retention or processing practices once data has been transmitted through the Cloud API, beyond what Meta discloses in its own terms.

3. Data Types We Collect

Account details. Name, email, business name, role, and password (stored as a salted hash, never in plain text). Payment is handled via tokenized processing through Supabase and our payment processors (Stripe and CMI) — we do not store full card numbers on our own servers.

Messaging data. Contact phone numbers, WhatsApp display names, WhatsApp Business Account (WABA) IDs, message payloads (text and media), media files, delivery/read timestamps, and conversation metadata needed to operate the unified inbox.

Contact & lead data. Names, phone numbers, tags, notes, and any other lead/contact fields our Tenants add to manage their pipeline.

Usage & device data. Log data, IP address, browser type, and pages visited, collected automatically to secure and improve the service.

AI feature data. Where AI-assisted features are enabled, relevant conversation content is processed by our configured AI/LLM provider to generate a response. See Section 6.

4. How We Use Data

  • To provide, operate, and maintain the Musak Leads platform, including the unified inbox, CRM, and automation features;
  • To process subscription payments and manage billing, including automatic recurring charges;
  • To communicate with you about your account, service updates, or support requests;
  • To detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service or Meta's platform policies;
  • To comply with legal obligations, including responding to lawful requests from authorities;
  • To improve the platform, including aggregated and de-identified analysis of feature usage.

We do not sell personal data, and we do not share personal data with third parties for their own advertising purposes. See Section 8 for California-specific disclosures.

6. AI Disclosure & Automated Processing

If your Musak Leads workspace has AI-assisted features enabled — automated replies, message suggestions, conversation summaries, or lead scoring — personal data from your conversations (including messages from your end-contacts) may be processed by an AI language model to generate a response or output. This is a form of automated processing within the meaning of the EU AI Act and applicable state AI-transparency laws.

  • AI features are optional and can be disabled in workspace settings.
  • Where an AI system generates a reply that a contact receives, that contact may request human intervention or review at any time; Tenants are responsible for making a path to a human available in their own messaging flows, and Musak Leads' automation tools are built to support handoff to a human agent on request.
  • We do not permit our AI providers to use your data to train their general-purpose models. AI request metadata (token counts, cost, timestamps) is retained for billing and abuse prevention; we avoid retaining raw message content in AI logs beyond what's needed to generate the response.

7. Who We Share Data With

We share data only as needed to operate the service, and only with:

  • Meta / WhatsApp — to send and receive messages via the WhatsApp Cloud API, as described in Section 2;
  • Payment processors — Stripe and CMI, to process subscription payments; they receive only the data needed to complete a transaction;
  • Infrastructure providers — Supabase (database and authentication), our hosting provider, and cloud storage providers, who process data on our behalf under contract and are not permitted to use it for their own purposes;
  • AI providers — as described in Section 6, only when AI features are enabled;
  • Legal & safety — where required to comply with law, enforce our Terms, or protect the rights, property, or safety of Musak Leads, our customers, or the public.

A full list of sub-processors handling Tenant data is maintained in our Data Processing Agreement.

8. California Privacy Rights (CCPA/CPRA)

Musak Leads does not sell or share personal data for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act. Because we don't sell or share personal data, no opt-out is required to take effect — but California residents may still submit a request at any time:

Do Not Sell or Share My Personal Information

We do not knowingly collect, sell, or share the personal data of consumers under 16 years of age without the opt-in consent required by CCPA/CPRA. California residents also have the right to know, delete, and correct their personal data, and the right to non-discrimination for exercising these rights.

9. International Data Transfers

Our infrastructure and service providers may be located outside your country, including in the European Union and the United States. Where we transfer personal data originating from the EU/EEA or UK to a country not recognized as providing an adequate level of protection — including transfers to US-based sub-processors such as our database, hosting, and AI providers — we rely on the European Commission's Standard Contractual Clauses (Module Two: Controller to Processor, or Module Three: Processor to Processor, as applicable) and, for transfers from the UK, the UK International Data Transfer Addendum to those clauses, as the transfer mechanism. The specific mechanism used per sub-processor is detailed in our Data Processing Agreement.

10. Data Retention

  • Account and billing data is retained for as long as your account is active, and for a limited period afterward as required for tax, accounting, and legal purposes.
  • Contact and conversation data is retained for as long as the relevant Tenant account is active, or until the Tenant deletes it, whichever is earlier.
  • Upon subscription cancellation, WhatsApp Business Account tokens and customer message logs are permanently deleted from our Supabase database within 30 days, consistent with our Data Processing Agreement, except where retention is required by law (for example, financial records).
  • Data tied to a specific data-deletion request is deleted or irreversibly anonymized within 30 days.

11. Your Rights (GDPR / CCPA)

Depending on your location, you may have the right to access, correct, export, or delete your personal data (the "Right to Erasure" / "Right to be Forgotten" under GDPR), restrict or object to certain processing, and withdraw consent where processing is based on consent. To exercise these rights:

  • Account holders (Tenants) can manage most data directly from account settings, or export/delete their workspace data from the admin panel;
  • End-contacts, or anyone unsure who to contact, should see our Data Deletion Instructions or email info@musakleads.com.

We acknowledge verified requests within 5 business days and complete them within 30 days.

If you are located in Morocco, you may also exercise the statutory rights described in Section 5, including the right to lodge a complaint directly with the CNDP, independent of contacting us first.

12. Security

We use administrative, technical, and physical safeguards designed to protect personal data, including encryption in transit (TLS/HTTPS), encryption at rest (via Supabase's managed PostgreSQL encryption), role-based access controls, and tenant isolation between customer workspaces enforced at the database level (Row-Level Security). No system is completely secure, and we encourage you to use a strong, unique password and enable multi-factor authentication where available.

13. Children's Privacy

Musak Leads is a business tool and is not directed at, or intended for use by, children. We do not knowingly collect personal data from children under 16. If you believe a child has provided us with personal data, contact us and we will delete it.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email or through the platform at least 14 days before they take effect. The "Last updated" date at the top of this page reflects the most recent revision.

15. Contact Us

Musak Leads Media — info@musakleads.com

Musak Leads has appointed a Privacy Lead responsible for handling data protection inquiries and requests, reachable at the email address above. A formal Data Protection Officer has not been appointed, as Musak Leads' processing activities do not meet the large-scale or core-activity monitoring thresholds under Article 37 of the GDPR that would make such an appointment mandatory. We will appoint a DPO and update this Policy if that changes.

EU Representative (GDPR Article 27). Musak Leads is established in Morocco. Article 27 requires the designation of an EU representative only where our processing relates to offering goods or services to, or monitoring the behavior of, data subjects located in the EU. Musak Leads' services are not currently marketed or offered on a targeted basis to customers established in the EU; should that change, we will designate an EU representative in accordance with Article 27 in advance of that expansion, and this Policy will be updated with their contact details.