PRIVACY POLICY
Last Updated: [INSERT DATE]
Effective Date: [INSERT DATE]

1. INTRODUCTION

This Privacy Policy describes how [YOUR COMPANY NAME] (“we,” “us,” or “our”) collects, uses, and handles information when you use our application (“App”). This App is an internal tool used solely for collecting and analyzing Instagram data via the Meta Graph API.

We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the LGPD (Lei Geral de Proteção de Dados) of Brazil, and Meta’s Developer Policies.

2. DATA CONTROLLER

[YOUR COMPANY NAME]
[YOUR FULL ADDRESS]
[YOUR CITY, STATE, ZIP CODE]
[YOUR COUNTRY]
Contact Email: [YOUR EMAIL]

3. SCOPE OF THIS POLICY

This App is an internal-use application. It is not a public-facing consumer product. Access is restricted to authorized personnel of [YOUR COMPANY NAME]. This policy applies to all data processed through this App in connection with the Meta/Instagram platforms.

4. DATA WE COLLECT

Through the Meta Graph API and Instagram API, we may collect the following categories of data:

a) Instagram Account Data:
– Instagram user ID
– Instagram username (handle)
– Profile information (name, biography, profile picture URL)
– Follower and following counts
– Account type (personal, business, creator)

b) Instagram Content Data:
– Posts, reels, stories, and other media metadata
– Engagement metrics (likes, comments, shares, reach, impressions)
– Hashtags and captions associated with content
– Media URLs and timestamps

c) Instagram Insights and Analytics Data:
– Audience demographics (aggregated and anonymized)
– Reach, impressions, and engagement rates
– Profile visit statistics

d) Technical Data:
– Access tokens (OAuth tokens) used to authenticate API requests
– API request logs (timestamps, endpoints accessed)
– Error logs for debugging purposes

5. DATA WE DO NOT COLLECT

We do not collect:
– Private messages or direct messages (DMs)
– Payment or financial information
– Sensitive personal data (health, religion, political views, racial or ethnic origin)
– Data from users who have not authorized access through Meta’s authorization flow
– Data from minors

6. LEGAL BASIS FOR PROCESSING

We process data under the following legal bases:
– Legitimate Interest: To operate, maintain, and improve our internal analytics capabilities.
– Contract: To fulfill obligations arising from Meta’s Developer Terms of Service and Platform Policies.
– Legal Compliance: To comply with applicable Brazilian law (LGPD) and Meta’s policies.

7. HOW WE USE YOUR DATA

Data collected through this App is used exclusively for:
– Internal Instagram performance analytics and reporting
– Monitoring account metrics for business decision-making
– Debugging and maintaining the technical functionality of the App

We do not use data for:
– Advertising or marketing to third parties
– Sale, rental, or trade of personal data to any third party
– Determining eligibility for housing, employment, insurance, education, credit, or government benefits
– Discriminating against individuals based on any protected characteristic
– Any purpose beyond what is declared in our Data Use Checkup (DUC) submitted to Meta

8. DATA SHARING AND DISCLOSURE

We do not sell, trade, or transfer your personal data to third parties, except:
– When required by law or court order
– To Meta/Instagram as part of the API integration (as governed by Meta’s own Privacy Policy)
– To service providers acting as data processors on our behalf who are bound by confidentiality and data protection agreements

All third-party processors are contractually required to process data only as instructed and to maintain appropriate security measures.

9. META BUSINESS TOOLS

This App uses the following Meta Business Tools and APIs:
– Instagram Graph API
– Meta Graph API (Facebook Login / Business Login)

By using this App, data may be transmitted to Meta in accordance with Meta’s Data Policy, available at: https://www.facebook.com/policy.php

We use these tools solely for the internal data collection and analytics purposes described in this policy.

10. COOKIES AND TRACKING TECHNOLOGIES

This App may use session tokens and authentication cookies strictly necessary for the functioning of the Meta API login flow. We do not use third-party advertising cookies or behavioral tracking technologies.

Users may manage browser cookies through their browser settings. Disabling necessary cookies may impair the App’s functionality.

11. DATA RETENTION

We retain data collected through the App for a maximum of [INSERT RETENTION PERIOD, e.g., 12 months] from the date of collection, unless a shorter or longer retention period is required by law or by Meta’s policies.

Upon the expiration of the retention period, or upon a valid deletion request, data is permanently deleted from all our systems.

12. DATA SECURITY

We implement appropriate technical and organizational measures to protect data against unauthorized access, accidental loss, destruction, or alteration. These measures include:
– Encryption of data in transit (TLS/HTTPS)
– Access controls limited to authorized personnel only
– Secure storage of API access tokens
– Regular security reviews

13. USER RIGHTS

To the extent applicable under the LGPD and other applicable laws, individuals whose data we process have the following rights:
– Right to access: Request a copy of the data we hold about you.
– Right to correction: Request correction of inaccurate data.
– Right to deletion: Request deletion of your data (see Section 14 below).
– Right to data portability: Request transfer of your data in a structured format.
– Right to object: Object to certain types of processing.
– Right to withdraw consent: Where processing is based on consent, you may withdraw at any time.

To exercise any of these rights, contact us at: [YOUR PRIVACY CONTACT EMAIL]

14. DATA DELETION REQUESTS

You may request the deletion of your data at any time by:

Option 1 — Email Request:
Send an email to [YOUR DELETION EMAIL, e.g., [email protected]] with the subject line “Data Deletion Request.” Include your Instagram username or user ID so we can locate and delete your data.

Option 2 — Meta Platform:
If you connected this App through Meta’s authorization flow, you may revoke the App’s permissions at any time by visiting:
https://www.facebook.com/settings?tab=applications

Upon revocation, we will process your data deletion request within 30 days and send you a confirmation.

15. CHILDREN’S PRIVACY

This App is intended for internal business use only and is not directed at individuals under the age of 18. We do not knowingly collect data from minors. If we become aware that a minor’s data has been collected inadvertently, we will delete it promptly.

16. INTERNATIONAL DATA TRANSFERS

If data is transferred outside Brazil, we ensure that adequate safeguards are in place in accordance with the LGPD, including standard contractual clauses or equivalent mechanisms.

17. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We will notify relevant users of material changes by updating the “Last Updated” date at the top of this document. Continued use of the App after changes are published constitutes acceptance of the updated policy.

18. CONTACT US

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, contact:

[YOUR COMPANY NAME]
Privacy Officer / Data Controller
Email: [YOUR PRIVACY EMAIL]
Address: [YOUR FULL ADDRESS]
Phone: [YOUR PHONE NUMBER]

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This Privacy Policy is compliant with:
– Meta Platform Terms and Developer Policies
– LGPD — Lei Geral de Proteção de Dados (Brazil, Law No. 13,709/2018)
– GDPR principles (EU General Data Protection Regulation)