Privacy Policy — PandaShop Chat Assistant

Effective date: 21 August 2026 · Updated: 2 October 2026

1. Who we are

This Privacy Policy explains how Eliteh Trade S.R.L. (IDNO 1013600028810; registered office: bd. Mircea cel Bătrân 8/2, Chișinău, Republic of Moldova; store: str. Moscova 21, Chișinău), the operator of the online store PandaShop.md (“PandaShop”, “we”, “us”), processes personal data when you communicate with us through our chat channels: Facebook Messenger, Instagram Direct and the chat widget on www.pandashop.md (together, the “Chat Assistant”). The Chat Assistant is a messaging application connected to the Meta platform and operated by PandaShop for its own customer service only.

Contact for privacy matters: [email protected], +373 22 815-819 (Mon–Fri 8:00–19:00, Sat–Sun 9:00–18:00).

This policy supplements the general Privacy Policy of PandaShop.md, which applies to purchases on our website.

2. What data we process

• Channel identifiers — the identifier Meta assigns to you for our Facebook Page or Instagram account (page-scoped or Instagram-scoped user ID), or an anonymous session identifier for the website widget.
• Profile data — your name and profile picture as made available by Meta for your Messenger or Instagram profile.
• Conversation content — text and voice messages, photos, videos and other attachments, button selections and timestamps of your conversations with the Chat Assistant and our operators, including replies our staff send through Meta Business Suite. In the website chat a voice message is recorded from your microphone only while you are recording it.
• Order data you provide in chat — name, phone number, delivery address, e-mail address (for card payment links), the products you ask about or order, payment and delivery methods, order numbers and order status.
• Contact details for a call-back — in the chat on our website you can leave a phone number, the way you want to be contacted (a call, Viber or Telegram) and, optionally, your name, so that an operator can reach you after you leave the site.
• Website chat context — whether you currently have our website open with the chat, when you left it, the address (without query parameters) and title of the page where the chat is open, and which of our replies you have seen; the operator uses this to know whether a reply in the chat will reach you.
• IP address in the website chat — the network address your messages in the chat on our website come from; we use it to protect the chat from spam and abuse, including closing the chat to an address abusers write from.
• Technical data — message delivery status, error logs and the raw notifications we receive from Meta (webhook events).

We do not intentionally collect special categories of personal data. Please do not send payment card numbers or identity documents in chat.

3. Why we process it and on what legal basis

• To answer your questions and provide customer support in the channel you contacted us through — steps taken at your request and performance of a contract; our legitimate interest in customer service.
• To call you or write to you in the messenger you chose, when you left your phone number in the website chat — steps taken at your request.
• To place, check, change or cancel orders at your request and to arrange refunds — performance of a contract; legal obligations in accounting.
• To operate the automated assistant: your messages are analysed by an AI language model to generate a reply or to hand the conversation over to a human operator — our legitimate interest in fast, round-the-clock support; you can ask for a human at any time.
• To maintain, secure and improve the service: troubleshooting, preventing abuse (including closing the website chat to addresses used for spam or abuse), reviewing the quality of replies — legitimate interest.
• To comply with the law and respond to lawful requests of public authorities — legal obligation.

We do not use your conversations for advertising, we do not use them to train AI models, and we do not sell personal data.

4. Automated assistant

The first line of support in our chat channels is an automated assistant (chatbot) that uses large language models provided by Anthropic and/or OpenAI. It answers questions based on our knowledge base and can place or manage orders when you ask it to. The assistant can make mistakes: all order terms (prices, delivery, payment, returns) are governed by the Public Offer published on pandashop.md, and our managers verify orders before processing. You can request a human operator at any time by writing “operator” (or the equivalent in your language); the conversation is then handled by our staff.

5. Who receives your data

We share personal data only with service providers that process it on our behalf and under our instructions, or where the law requires it:

• Meta Platforms Ireland Ltd. (Facebook, Messenger, Instagram) — delivers messages between you and us. Meta processes your data under its own Privacy Policy.
• Anthropic, PBC and OpenAI, L.L.C. (USA) — AI providers that process conversations to generate the assistant's replies: the text, the photos you send, and voice messages, which OpenAI turns into text. Under their API terms they do not use this data to train their models.
• Simla.com — the CRM system in which our orders and customer records are kept.
• Hetzner Online GmbH (Germany) — hosting of the Chat Assistant's servers and databases; Cloudflare, Inc. — network security and content delivery.
• Telegram — internal notifications to our accounting staff about refunds for cancelled orders (order number, amount, reason; no chat history), and to our customer service team about chats nobody has answered yet (your name or phone number and your last message).
• Viber, Telegram — when you ask us to contact you in one of these messengers, our staff write to you there; the messenger processes the conversation under its own privacy policy.
• Courier and postal services — to deliver your orders, as described in the general Privacy Policy.
• Public authorities — where required by the law of the Republic of Moldova.

Transfers outside the Republic of Moldova are made to countries that ensure an adequate level of protection or on the basis of contractual safeguards agreed with the provider.

6. How long we keep data

• Conversation history and contact data — for as long as we need them to provide support and handle questions about your orders; you can request deletion at any time (section 8).
• Raw technical notifications from Meta (webhook logs) — up to 30 days.
• Cached profile picture — until the contact is deleted.
• IP addresses of website chat messages — together with the conversation they belong to; an address blocked for abuse — until the block ends or is lifted.
• Order, payment and refund records in our CRM and accounting systems — for the periods required by the accounting and tax legislation of the Republic of Moldova.
• Security and error logs — for the limited period needed for security and troubleshooting.

7. How we protect data

Access to conversations is limited to authorised PandaShop staff who sign in to the operator console with personal credentials and roles. Access tokens and API keys are stored encrypted (AES-256-GCM). Notifications from Meta are verified by digital signature before processing. Connections are protected with TLS. Servers are located in the European Union (Germany).

8. Your rights

Under the personal data protection legislation of the Republic of Moldova you have the right to access your data, to have it corrected or deleted, to restrict or object to processing, and to data portability where applicable. To exercise these rights, write to us in the same chat or at [email protected]. We respond within 30 days. To delete your chat data, follow our Data Deletion Instructions. You may also lodge a complaint with the National Center for Personal Data Protection of the Republic of Moldova (www.datepersonale.md).

You can stop the conversation at any time by blocking or muting our Page or account in Messenger or Instagram; Meta's settings and Privacy Policy explain how.

9. Children

The Chat Assistant is not intended for children under 16. If you believe a child has provided us with personal data, contact us and we will delete it.

10. Changes to this policy

We may update this policy from time to time. The current version is always published at chatbot.pandashop.md/privacy together with its effective date.