UTELL COMMUNICATIONS

Privacy Notice

Effective 7 July 2026

1. Who this notice covers

Utell Communications is operated by Kitjimanitou Studios Inc. The service can be used by customer organisations to deliver approved business communications through channels such as email and the WhatsApp Business Platform. Depending on the service arrangement, the customer may determine the purpose and means of processing its customer data, while Utell may process that data to provide, secure, support, and improve the service.

2. Information handled by the service

The service may process information needed to send, receive, secure, support, and audit communications. This can include:

• business account, tenant, administrator, and support-contact details;
• recipient contact details, such as name, email address, and mobile number;
• message, template, routing, delivery, opt-in, opt-out, and consent information;
• technical information such as IP address, request identifiers, timestamps, device/browser metadata, and service logs; and
• provider configuration metadata required to operate approved integrations.

3. Why information is used

Information is used to provide and maintain the communications service, validate and route requests, deliver messages, manage opt-in and opt-out preferences where configured, investigate delivery failures, prevent misuse, protect the platform, provide support, and meet contractual or legal obligations.

4. Legal and privacy responsibilities

Barbados’ Data Protection Commission identifies the Data Protection Act, 2019-29 as the local framework for processing personal data and for controller and processor responsibilities. Where the GDPR applies, the relevant organisation must provide the required transparency information and implement security measures appropriate to risk. The applicable customer agreement should identify the responsible controller, processor, and privacy contact for each processing activity.

5. WhatsApp and other providers

When a customer uses the WhatsApp Business Platform or another third-party provider, information required to deliver a communication may be shared with that provider. Customers must ensure they have a valid basis to contact recipients and comply with applicable provider terms, consent requirements, template rules, and messaging policies.

6. Retention

Information is retained only for as long as needed for delivery, security, support, reconciliation, audit, legal obligations, and the applicable customer agreement. Retention settings may vary by tenant, channel, and message type. Where data is no longer needed, it should be securely deleted, anonymised, or otherwise handled according to the applicable retention schedule.

7. Security

Utell uses technical and organisational measures intended to protect information against unauthorised access, loss, misuse, alteration, and disclosure. These may include access control, encryption where appropriate, managed identities, secret management, audit logging, monitored delivery workflows, and restricted operational access. No system can guarantee absolute security.

8. Rights and requests

Individuals may have rights to request access, correction, deletion, restriction, objection, or portability of personal information, depending on applicable law and the role of the customer organisation. Requests should normally be sent to the customer organisation that initiated the communication. Utell will support customers with validated requests where required by the applicable agreement or law.

9. Contact and complaints

For privacy questions relating to Utell Communications, contact privacy@kitjistudios.com. For Barbados regulatory information or complaints, see the Data Protection Commission.

10. Changes

This notice may be updated when the service, legal obligations, or data-handling practices change. The effective date above identifies the latest published version.