Privacy Policy

Last Updated: December 2024

1. Introduction

NextGen Marketing and Automation LLC ("Company," "we," "our," or "us"), operating under the brand name CommentKeyword, provides the CommentKeyword platform (the "Service") that helps businesses automate their Instagram engagement through keyword monitoring, automated direct messaging, and AI-powered conversation management.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. By using CommentKeyword, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Account Information

• Registration Data: Email address, name, password, company information
• Billing Information: Payment details processed securely through Stripe
• Profile Data: Business category, marketing goals, team member information

2.2 Instagram Integration Data

• Instagram Business Account: Account ID, username, profile information
• Content Data: Posts, comments, and engagement metrics from your connected accounts
• Message Data: Direct messages sent and received through our automation
• Analytics Data: Engagement rates, reach, impressions, and performance metrics

2.3 Usage Information

• Service Usage: Features used, keywords configured, campaign performance
• Technical Data: IP address, browser type, device information, log files
• Communication Data: Support tickets, feedback, and communication history

2.4 AI Processing Data

• Conversation Content: Messages analyzed for AI response generation
• User Preferences: Response styles, conversation goals, brand voice settings
• Performance Data: Success rates, engagement metrics, conversion tracking

3. How We Use Your Information

3.1 Service Provision

• Monitor Instagram comments for specified keywords
• Send automated direct messages and follow-up sequences
• Generate AI-powered conversation responses
• Provide analytics and performance reporting
• Manage user accounts and billing

3.2 Service Improvement

• Analyze usage patterns to improve features
• Train AI models for better conversation quality
• Develop new automation capabilities
• Optimize system performance and reliability

3.3 Communication

• Send service updates and feature announcements
• Provide customer support and technical assistance
• Share best practices and usage tips
• Send billing notifications and account alerts

4. Instagram API Compliance

CommentKeyword integrates with Instagram through Meta's official Instagram Business API. We:

• Only access data you explicitly authorize through Instagram's OAuth process
• Comply with Meta's Platform Terms and Instagram API Terms of Service
• Implement rate limiting to respect Instagram's usage guidelines
• Use secure, encrypted connections for all Instagram API communications
• Regularly audit our integration to maintain compliance standards

5. AI and Machine Learning

Our AI features process your conversation data to provide intelligent automation:

• Local Processing: Most AI operations occur on our secure servers
• Third-Party AI: We may use services like OpenAI for advanced language processing
• Data Anonymization: Personal identifiers are removed from AI training data
• Model Training: Aggregated, anonymized data may improve our AI models
• Opt-Out: You can request exclusion from AI model training

6. Data Sharing and Disclosure

6.1 We Never Sell Your Data

CommentKeyword does not sell, rent, or trade your personal information to third parties for marketing purposes.

6.2 Service Providers

We share limited data with trusted service providers:

• Stripe: Payment processing (billing information only)
• Railway: Cloud hosting and infrastructure
• Supabase: Database services with encryption
• OpenRouter/OpenAI: AI processing (anonymized content only)
• Mailgun: Email delivery services

6.3 Legal Requirements

We may disclose information when required by law:

• Comply with legal processes or government requests
• Protect the rights, property, or safety of CommentKeyword or others
• Investigate fraud, security issues, or terms violations
• Enforce our Terms of Service

7. Data Security

We implement comprehensive security measures to protect your information:

• Encryption: Data encrypted in transit (TLS 1.3) and at rest (AES-256)
• Access Controls: Role-based permissions and multi-factor authentication
• Infrastructure: SOC 2 compliant hosting with Railway and Supabase
• Monitoring: Continuous security monitoring and incident response
• Regular Audits: Periodic security assessments and penetration testing

8. Data Retention

• Account Data: Retained while your account is active
• Instagram Data: Stored for service functionality, deleted upon account closure
• Usage Analytics: Aggregated data retained for up to 2 years
• Support Data: Communication history retained for 3 years
• Financial Records: Billing data retained for 7 years (legal requirement)

9. Your Privacy Rights

9.1 Access and Control

• Account Access: View and edit your account information
• Data Export: Request a copy of your data in standard formats
• Data Deletion: Delete your account and associated data
• Service Disconnect: Revoke Instagram API access at any time

9.2 GDPR Rights (EU Residents)

• Right to Access: Obtain confirmation and details about data processing
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of personal data
• Right to Portability: Receive data in machine-readable format
• Right to Restrict: Limit processing of your personal data
• Right to Object: Object to processing based on legitimate interests

9.3 CCPA Rights (California Residents)

• Right to Know: Information about data collection and use
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of data sales (we don't sell data)
• Non-Discrimination: Equal service regardless of privacy choices

10. Cookies and Tracking

CommentKeyword uses cookies and similar technologies to:

• Essential Cookies: Authentication, security, and basic functionality
• Analytics Cookies: Understand usage patterns and improve our service
• Preference Cookies: Remember your settings and customizations

You can control cookies through your browser settings. Note that disabling certain cookies may limit service functionality.

11. International Data Transfers

CommentKeyword operates globally with infrastructure primarily in the United States. If you're located outside the US, your data may be transferred to and processed in countries with different privacy laws. We ensure appropriate safeguards are in place for international transfers.

12. Children's Privacy

CommentKeyword is not intended for use by individuals under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware of such collection, we will promptly delete the information.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or applicable law. We will:

• Notify users via email of material changes
• Update the "Last Updated" date at the top of this policy
• Provide 30 days notice for significant changes
• Obtain consent for changes that expand data collection

14. Contact Information

For questions about this Privacy Policy or to exercise your privacy rights, contact us:

• Email: [email protected]
• Mail: NextGen Marketing and Automation LLC, Privacy Team, [Address]
• Data Protection Officer: [email protected]