Privacy Policy

This Privacy Policy describes how Foxtly Inc. and our affiliated companies (collectively, "Foxtly", "we", "our" or "us") collect, store, use, disclose and process personally identifiable information ("Personal Information") in the course of our business, including our website located at www.foxtly.com (the "Website") and our AI Marketing Platform that we make available via the Website for purposes of management, monitoring, optimization, and execution of marketing campaigns across Meta (Facebook and Instagram), Google, and other digital advertising platforms, and all other Foxtly services, technology, data, programs, and materials. The Website, our Platform, and all related offerings are collectively called the "Services."

Your privacy is important to us. We are strongly committed to making our practices regarding your Personal Information fair and transparent. Please read this Privacy Policy carefully. By accessing and using the Website or other Services, you acknowledge that you have read this Privacy Policy and agree to be bound by all terms and conditions.

1. Information We Collect

1.1 Account Registration Information

When you create a Foxtly account, we collect:

Full name and email address
Company name and website URL
Billing information (processed securely via Stripe; we do not store full credit card numbers)
Password (stored in hashed, encrypted form)

1.2 Information from Meta (Facebook & Instagram) Integration

When you connect your Facebook or Instagram account to the Services via Meta's official OAuth 2.0 authorization flow, we request and receive the following data solely to provide the Services:

Facebook Pages you manage: page names, IDs, access tokens, engagement metrics (likes, comments, shares, reach, impressions)
Instagram Business or Creator accounts linked to your Facebook Pages: profile data, follower counts, media objects, post-level insights
Ad Accounts and Campaigns: campaign names, ad set data, spend data, performance metrics (CTR, CPM, ROAS, conversions) from Facebook Ads Manager
Messaging data: DM volume, response rate statistics, comment counts — aggregated metrics only; we do not read or store the content of private messages
Page insights and analytics: reach, impressions, engagement rates, audience demographics (aggregated, not individual user data)

Important: We only access data from accounts you explicitly authorize. We do not access data from accounts you do not own or manage. All Meta data is retrieved through the official Meta Graph API and subject to Meta's Platform Terms and Data Policy.

1.3 Google Services Integration

When you connect Google Search Console or Google Ads, we collect SEO performance data including keyword rankings, organic traffic, click-through rates, and search query data, solely to display this information in your Foxtly dashboard.

1.4 Automatically Collected Information

When you use the Services, we automatically collect:

Log data: IP address, browser type, pages visited, time and date of visits, referring URL
Device information: operating system, device type, screen resolution
Usage data: features used, session duration, click paths within the platform
Cookies and similar tracking technologies (see Section 1.5)

1.5 Cookies

We use cookies and similar technologies to operate the Services, remember your preferences, and understand how the Services are used. Types of cookies we use:

Essential cookies: required for the Services to function (authentication, session management)
Analytics cookies: help us understand usage patterns to improve the Services
Preference cookies: remember your settings and personalization choices

Most web browsers allow you to block or delete cookies. If you do, some features of the Services may not function properly. We do not respond to Do Not Track (DNT) browser signals.

2. How We Use Your Information

We use the information we collect to:

Provide, operate, and maintain the Services, including displaying your advertising analytics, social media metrics, and SEO data in your dashboard
Connect to and retrieve data from Meta (Facebook and Instagram), Google, and other third-party platforms you authorize, on your behalf
Generate AI-powered insights, recommendations, and campaign optimizations
Process payments and manage billing
Send you transactional emails (account confirmations, billing receipts, security alerts)
Send product updates, newsletters, and marketing communications (you may opt out at any time)
Provide customer support and respond to inquiries
Monitor and analyze usage to improve the Services
Detect, prevent, and respond to fraud, abuse, security incidents, and technical issues
Comply with applicable laws, regulations, and legal obligations
Enforce our Terms of Service and other agreements

2.1 Use of Meta Platform Data

Data obtained through Meta's APIs is used exclusively to: (a) display your own business's advertising and social media performance within your Foxtly dashboard; (b) provide AI-generated optimization recommendations for your campaigns; and (c) generate reports at your request. We do not use Meta Platform Data for any purpose beyond what is disclosed in this Privacy Policy and permitted under Meta's Platform Terms.

3. Legal Bases for Processing (GDPR)

For users located in the European Economic Area (EEA) or the United Kingdom, we process your Personal Data under the following legal bases:

Performance of a contract: to provide the Services you have subscribed to
Legitimate interests: to operate, secure, and improve the Services, provided such interests are not overridden by your rights
Compliance with legal obligations: where we are required to process your data by applicable law
Consent: where you have provided explicit consent (e.g., optional marketing communications)

4. Data Sharing and Disclosure

We do not sell your Personal Information. We do not share your Personal Information or Meta Platform Data with third parties except in the following limited circumstances:

4.1 Service Providers

We engage trusted third-party service providers to help us operate the Services, including:

Stripe — payment processing
Supabase / AWS — cloud hosting and database storage
Vercel — web application hosting
DataForSEO — SEO data services
Analytics providers — internal usage analytics

These providers are contractually bound to process Personal Information only on our instructions, to maintain appropriate security, and not to use it for their own purposes.

4.2 Legal Requirements

We may disclose Personal Information if required to do so by law, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a legal process.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your Personal Information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Website of any such change in ownership or use of your Personal Information.

4.4 With Your Consent

We may share your information with third parties when you have explicitly consented to such sharing.

5. Meta Platform Data — Restricted Use

In addition to the general provisions above, with respect to data received through Meta's APIs, we confirm the following:

We only request permissions that are necessary to provide the Services you have requested
We do not transfer Meta Platform Data to third-party advertising networks, data brokers, or any other parties for purposes of targeted advertising
We do not use Meta Platform Data to build user profiles for advertising purposes outside the Services
We do not scrape or aggregate Meta user data
We store Meta access tokens securely using AES-256 encryption and restrict access to authorized personnel only
We will promptly delete Meta Platform Data upon your request or upon termination of your account
We comply with all applicable provisions of the Meta Platform Terms and Supplemental Terms for specific products

6. Data Retention

We retain Personal Information for as long as necessary to provide the Services and fulfill the purposes described in this Privacy Policy, including for legal, accounting, or reporting requirements. Specifically:

Account data: retained for the duration of your account and for up to 90 days after deletion, to allow account recovery
Meta Platform Data: retained only as long as needed to display current analytics; we do not store historical raw API data beyond 90 days
Billing records: retained for 7 years as required by applicable accounting and tax laws
Log data: retained for up to 12 months for security and debugging purposes

You may request deletion of your Personal Information at any time by contacting us at support@foxtly.com or through your account settings.

7. Data Security

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your Personal Information against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

AES-256 encryption for data at rest
TLS 1.2+ encryption for all data in transit
Encrypted storage of all third-party OAuth tokens and API credentials
Access controls and least-privilege principles for internal systems
Regular security audits and vulnerability assessments

Despite these measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security. In the event of a data breach that poses a risk of harm to users, we will notify affected individuals as required by applicable law.

8. International Data Transfers

Foxtly Inc. is incorporated in the State of Delaware, United States. If you are located outside the United States, your Personal Information may be transferred to and processed in the United States or other countries. Where required by applicable law (e.g., GDPR), we rely on approved transfer mechanisms such as Standard Contractual Clauses (SCCs) to ensure that your Personal Information receives adequate protection.

9. Your Rights Under GDPR (EEA & UK Users)

If you are located in the European Economic Area or the United Kingdom, you have the following rights regarding your Personal Data:

Right of access: to request a copy of your Personal Data we hold
Right to rectification: to request correction of inaccurate or incomplete data
Right to erasure: to request deletion of your Personal Data ("right to be forgotten")
Right to restriction: to request that we limit how we process your data
Right to data portability: to receive your data in a structured, machine-readable format
Right to object: to object to processing based on legitimate interests or for direct marketing
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 support@foxtly.com. We will respond within 30 days. You also have the right to lodge a complaint with your local data protection supervisory authority.

10. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you have the following rights:

Right to know what Personal Information we have collected, used, disclosed, or sold in the past 12 months
Right to delete your Personal Information, subject to certain exceptions
Right to correct inaccurate Personal Information
Right to opt-out of the sale or sharing of Personal Information (note: we do not sell or share Personal Information as defined under CCPA/CPRA)
Right to non-discrimination for exercising your privacy rights

Categories of Personal Information Collected (California):

Identifiers: name, email address, IP address, account identifiers
Commercial information: subscription records, payment history
Internet/network activity: usage data, log files, browsing activity within the Services
Professional information: company name, job title, business website
Inferences: insights drawn from usage data to personalize the Services

We do not knowingly sell Personal Information of minors under 16 years of age. To exercise your California privacy rights, contact us at support@foxtly.com.

11. Revoking Third-Party Access

You may revoke Foxtly's access to your Meta (Facebook/Instagram), Google, or other third-party accounts at any time:

Within Foxtly: navigate to Settings → Connected Accounts → Disconnect
Via Meta: go to Facebook Settings → Apps and Websites and remove Foxtly
Via Google: visit your Google Account security settings and revoke access

Upon revocation, we will cease collecting new data from those accounts. Existing data will be deleted within 30 days upon your request.

12. Children's Privacy

The Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If you believe a child has provided us with Personal Information, please contact us at support@foxtly.com and we will promptly delete such information.

13. Links to Third-Party Services

The Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party service you connect to through Foxtly, including Meta, Google, and other advertising platforms.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time at our sole discretion. If we make material changes, we will notify you by email and/or by posting a prominent notice on our Website at least 30 days before the changes take effect. Your continued use of the Services after the effective date constitutes acceptance of the updated Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Foxtly Inc.
A Delaware Corporation
1111B South Governors Ave, Suite 80381, Dover, DE 19904, United States
Email: support@foxtly.com
Website: www.foxtly.com