Privacy Policy

Effective date: August 20, 2026

Fireclay (“Fireclay,” “we,” “us,” or “our”) operates the website at fireclay.ph (the “Site”) and provides an AI-powered chatbot service delivered through Meta’s messaging platforms, including Facebook Messenger, WhatsApp Business, and Instagram Direct (collectively, the “Chatbot”). This Privacy Policy explains what personal data we collect when you use the Chatbot, how we use and protect it, who we share it with, and what rights you have over it.

This Policy is written to align with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as, where applicable, the EU General Data Protection Regulation (GDPR) for visitors from the European Economic Area, the UK, or Switzerland. If any provision below is inconsistent with mandatory law in your jurisdiction, that law controls.

1. Who We Are

Fireclay is the data controller (or “Personal Information Controller” under Philippine law) responsible for the personal data described in this Policy. You can reach us using the contact details in Section 11.

2. What Data We Collect

When you interact with the Chatbot through Messenger, WhatsApp, or Instagram, we collect:

  • Name — as provided by you directly, or as made available to us by the Meta platform you’re messaging us from (e.g., your Messenger or WhatsApp profile name).
  • Email address — when you provide it during the conversation, for example to receive a follow-up, a quote, or a support reply.
  • Conversation content — the full text of your messages to the Chatbot and its replies, including any details, questions, attachments, or files you choose to share during the chat.
  • Platform and technical identifiers — such as your Meta-assigned user/contact ID for the relevant channel (Messenger PSID, WhatsApp phone number, or Instagram ID), timestamps, and basic delivery metadata (e.g., message status), which Meta provides to us so we can respond to you.

We do not ask for or knowingly collect sensitive personal information (such as health, financial account numbers, or government IDs) through the Chatbot. Please avoid sharing this type of information in the chat; if you do, we will handle it with the same safeguards described here but recommend against volunteering it.

3. How We Collect It

We collect this data directly from you when you message the Chatbot, and indirectly from Meta’s messaging APIs (Messenger Platform, WhatsApp Business Platform, and Instagram Messaging API), which pass your message content and basic profile/contact identifiers to our systems so the Chatbot can respond.

4. Why We Use Your Data

We process your personal data for the following purposes:

  • To operate the Chatbot and respond to your messages, questions, or requests.
  • To identify you across a conversation and, where you consent, follow up by email.
  • To improve the Chatbot’s accuracy and quality, including reviewing conversation logs and, where used, refining any AI models or prompts involved.
  • To maintain records of customer interactions for support, quality assurance, and dispute resolution.
  • To comply with legal obligations, and to detect, prevent, or investigate fraud, abuse, or security incidents.

5. Legal Basis for Processing

Where GDPR applies, we rely on the following legal bases: your consent (given by choosing to message the Chatbot and, separately, if asked to opt in to marketing follow-ups), our legitimate interests in operating and improving a customer-facing chatbot, and, where relevant, the need to process data to take steps requested by you before or in connection with a contract (e.g., responding to a quote request). Under the Philippine Data Privacy Act, we process your data based on your consent and our legitimate interests as a business responding to customer inquiries.

6. Who We Share Your Data With

  • Meta Platforms, Inc. — Because the Chatbot runs on Messenger, WhatsApp Business, and/or Instagram, Meta processes your messages and profile/contact identifiers to deliver them to us and to operate its own messaging infrastructure. Meta’s handling of your data is also governed by Meta’s own privacy policy and, for WhatsApp Business API traffic, the WhatsApp Business Data Processing Terms. We encourage you to review Meta’s privacy policy at https://www.facebook.com/privacy/policy/ and WhatsApp’s privacy policy at https://www.whatsapp.com/legal/privacy-policy.
  • Service providers — such as hosting, chatbot/AI platform, and customer support tool providers who process data on our behalf under confidentiality and data protection obligations, solely to help us operate the Chatbot.
  • Legal and safety disclosures — where required by law, regulation, court order, or to protect the rights, property, or safety of Fireclay, our users, or others.

We do not sell your personal data, and we do not share your conversation content with third parties for their own independent marketing purposes.

7. International Data Transfers

Because Meta’s infrastructure operates globally, your data may be processed on servers located outside the Philippines, including in the United States or other countries where Meta or our service providers operate. Where required, we and our processors rely on appropriate safeguards (such as standard contractual clauses or equivalent mechanisms) for these transfers.

8. Data Retention

We keep the conversation records, names, and email addresses collected through the Chatbot for 12 months after your last message, so we can use them for the purposes explained in Section 4. Afterwards, we delete them — except where we’re still required to keep them to meet legal, accounting, or reporting obligations, or to resolve an ongoing dispute, in which case we delete them once that need has passed.

9. How We Protect Your Data

We apply reasonable organizational, physical, and technical safeguards to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including access controls, encryption in transit, and limiting access to personal data to personnel who need it to perform their duties. No system is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you have the right to:

  • Be informed about how your personal data is processed.
  • Access the personal data we hold about you.
  • Correct or update inaccurate or outdated data.
  • Object to or restrict certain processing, including withdrawing consent at any time (this will not affect the lawfulness of processing before withdrawal).
  • Request erasure or blocking of your data, subject to our legal retention obligations.
  • Request a copy of your data in a portable format, where applicable.
  • Lodge a complaint with the Philippine National Privacy Commission (https://privacy.gov.ph) or, if the GDPR applies to you, with your local data protection supervisory authority.

To exercise any of these rights, contact us using the details in Section 11. You can also stop messaging the Chatbot, or block/unsubscribe from it directly within Messenger, WhatsApp, or Instagram, at any time.

11. Contact Us

If you have questions about this Privacy Policy or want to exercise your data protection rights, contact us at:

Email: inquiry@fireclay.ph

12. Children’s Privacy

The Chatbot is not directed at children, and we do not knowingly collect personal data from children without appropriate parental or guardian consent as required by applicable law. If you believe a child has provided us personal data through the Chatbot, please contact us so we can delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Chatbot’s functionality, or legal requirements. We will post the revised version on this page with an updated “Last updated” date, and where changes are material, we will provide additional notice as required by law.