This policy explains how Nomads United, MB, the company behind worklab, handles personal data when you call or message our AI voice assistant on WhatsApp. Calls and messages are answered by an artificial intelligence system powered by OpenAI (the technology behind ChatGPT). You are always talking to an AI, not a human, unless we tell you otherwise.

  1. Who we are
  2. What this policy covers
  3. Data we process
  4. Why we process it and legal bases
  5. How the AI works
  6. Who receives your data
  7. International transfers
  8. How long we keep data
  9. Your rights
  10. Deleting your data
  11. Security
  12. Children
  13. Changes to this policy
  14. Contact and complaints

1. Who we are

The controller responsible for your personal data is Nomads United, MB, a company registered in the Republic of Lithuania, which operates the website worklab.biz and the worklab WhatsApp assistant (“worklab”, “we”, “us”). We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, “GDPR”) and the Law on Legal Protection of Personal Data of the Republic of Lithuania.

CompanyNomads United, MB
Legal formMažoji bendrija (small partnership), Republic of Lithuania
Company code305569211
VAT codeLT100015648119
Registered addressAteities g. 14-13, LT-37342 Panevėžys, Lithuania
Business addressPanerių g. 39, 7th floor, LT-03209 Vilnius, Lithuania
E-mailhello@worklab.biz · info@nomads.lt
Phone+370 662 49326
Websitesworklab.biz · nomads.lt

Contact for all privacy matters: hello@worklab.biz.

2. What this policy covers

This policy applies when you:

WhatsApp itself is operated by WhatsApp Ireland Limited / Meta Platforms Ireland Limited. Their processing of your data as a WhatsApp user is governed by the WhatsApp Privacy Policy, not by this policy.

3. Data we process

CategoryExamplesSource
IdentifiersWhatsApp phone number, WhatsApp profile name, WhatsApp user IDWhatsApp Business Platform
Call contentYour voice audio while the call is live, and the text transcript of what you and the AI saidYou, during the call
Message contentText messages, voice notes, images, documents and repliesYou
Call and message metadataDate, time, duration, call status, message IDs, delivery and read statusWhatsApp Business Platform
Consent recordsYour permission for us to call you, opt-in and opt-out historyYou, via WhatsApp
Account and business dataName, company, e-mail and preferences, if you share them or have a worklab accountYou
Technical logsServer logs, error reports, IP addresses of website visitorsOur systems

Please do not share special categories of data (such as health, religious beliefs, political opinions, biometric or genetic data, sex life or sexual orientation), payment card numbers, passwords or other sensitive information during calls or in messages. If you do so voluntarily, we will process it only as necessary to respond to you and will delete it according to the retention rules below.

We do not use your voice to identify you (no voiceprints or biometric identification), and we do not create advertising profiles.

4. Why we process it and legal bases

PurposeLegal basis (GDPR)
Answering your calls and messages with the AI assistant and providing the service you requestedArt. 6(1)(b) – performance of a contract or steps at your request
Calling you on WhatsApp (business-initiated calls) and sending you follow-up messagesArt. 6(1)(a) – your consent, given through WhatsApp’s call-permission and opt-in features; you can withdraw it at any time
Keeping transcripts so the assistant can remember context and so we can follow up on your requestArt. 6(1)(b) – contract; and Art. 6(1)(f) – our legitimate interest in providing a consistent service
Quality assurance, troubleshooting and improving prompts and settings of our assistant (we do not train AI models on your data)Art. 6(1)(f) – legitimate interest in a reliable and safe service
Preventing abuse, fraud, spam and security incidentsArt. 6(1)(f) – legitimate interest in protecting our users and systems
Complying with legal obligations (e.g. accounting, responding to authorities)Art. 6(1)(c) – legal obligation
Establishing, exercising or defending legal claimsArt. 6(1)(f) – legitimate interest

Where we rely on legitimate interests, we have balanced them against your rights and you may object at any time (see Your rights).

5. How the AI works

6. Who receives your data

We do not sell your personal data. We share it only with service providers who process it on our behalf under data processing agreements (Art. 28 GDPR), or where the law requires it:

7. International transfers

We store data primarily on servers in the European Union. Some providers (in particular OpenAI and Meta) may process data in the United States or other countries outside the European Economic Area. In these cases we rely on the EU–U.S. Data Privacy Framework where the recipient is certified, or on the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR) together with supplementary measures. You can request a copy of the relevant safeguards by contacting us.

8. How long we keep data

DataRetention
Live call audioNot stored; processed only for the duration of the call
Call transcripts and message content90 days after the last interaction, then deleted or anonymised, unless you ask us to delete them sooner
Call and message metadata12 months
Consent and opt-out recordsAs long as consent is active and up to 3 years after withdrawal, to prove compliance
Server and security logsUp to 90 days
Contract, invoice and accounting recordsAs required by applicable tax and accounting law (typically up to 10 years)
Data at OpenAIOpenAI may retain API inputs and outputs for up to 30 days for abuse and misuse monitoring, after which they are deleted, unless the law requires otherwise

Where data is needed to establish or defend a legal claim, we may keep it until the matter is resolved.

9. Your rights

Under the GDPR you have the right to:

To exercise your rights, e-mail hello@worklab.biz or send us a WhatsApp message. We will reply within one month, which may be extended by two further months for complex requests. We may ask you to confirm your identity, for example by messaging us from the same WhatsApp number. Exercising your rights is free of charge.

10. Deleting your data

You can ask us to delete all data associated with your WhatsApp number at any time:

We will delete your transcripts, messages and profile data within 30 days and confirm when it is done. We may keep only what the law requires us to keep (for example invoices) and a minimal record of your request. To stop receiving calls or messages without deleting data, send STOP, withdraw call permission in WhatsApp, or block our number.

11. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit (TLS), access controls limited to authorised personnel, separation of environments, regular updates and backups, and data processing agreements with our providers. WhatsApp encrypts calls and messages in transit; once they reach our systems through the WhatsApp Business Platform, they are processed by us and our providers as described in this policy. If a personal data breach is likely to result in a risk to your rights, we will notify the competent supervisory authority within 72 hours and inform you where required by law.

12. Children

The service is not intended for children under 16. We do not knowingly process personal data of children under 16 (or the lower age set by the law of your EU Member State) without parental consent. If you believe a child has used the service, contact us and we will delete the data.

13. Changes to this policy

We may update this policy when our service or the law changes. The “Last updated” date at the top shows the latest version. If changes are significant, we will inform you through WhatsApp or by other appropriate means before they take effect.

14. Contact and complaints

For any question about this policy or your data, contact us at hello@worklab.biz.

You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). Our lead supervisory authority is the State Data Protection Inspectorate of the Republic of Lithuania (Valstybinė duomenų apsaugos inspekcija, L. Sapiegos g. 17, LT-10312 Vilnius, vdai.lrv.lt). You may also complain to the authority in the EU Member State of your habitual residence, place of work or the place of the alleged infringement. A list of EU authorities is available on the European Data Protection Board website. We would appreciate the chance to address your concern first.

See also our Terms and Conditions.