{{PLACEHOLDER}} values must be finalised before publication.Privacy Policy
Fanogram Reach (“Reach”, “we”, “us”) is a creator-CRM service that lets a creator connect their own Instagram and WhatsApp Business accounts to a single unified inbox so they can read and respond to messages from their audience in one place. This policy explains what data we access, why, how long we keep it, who we share it with, and how to request deletion.
Data controller: {{LEGAL_ENTITY_NAME}}, {{REGISTERED_ADDRESS}}. Contact: {{PRIVACY_CONTACT_EMAIL}}.
Last updated: 2026-05-29 (DRAFT — pending legal review)
1. Who this policy is for
It covers two groups: (a) creators who authorise Reach to access their connected Instagram / WhatsApp Business accounts, and (b) the people who message those creators (“fans”), whose messages flow through the connected account into the creator’s inbox.
2. What we access, and the permissions we use
When a creator connects an account, Meta asks them to grant specific permissions. We request only what the unified-inbox function needs:
- Instagram —
instagram_business_basic(the connected account’s id, username, and profile basics) andinstagram_business_manage_messages(read the Instagram direct messages sent to the connected account and send replies on the creator’s behalf). - WhatsApp —
whatsapp_business_messaging(read inbound WhatsApp messages to the connected business number and send replies), withwhatsapp_business_managementandbusiness_managementused to identify the business account and phone number being connected.
Through these permissions we process: connected-account identifiers and profile basics (username, display name, avatar URL, follower count); message content and metadata (text, attachments’ references, timestamps, delivery/read status) for conversations in the connected inbox; and the connected account’s message-template and account-health signals. We do not request permissions to post content, read your contacts list, or access financial information.
3. How we use the data
- Present the creator’s Instagram and WhatsApp conversations in a single inbox and let them reply.
- Provide optional AI-assisted reply drafting. Draft suggestions are generated for the creator to review and edit; we do not auto-send.
- Show the creator basic engagement and account-health information (e.g. messaging-window status, message-template quality) so they can stay within the platform’s policies.
- Operate, secure, debug, and improve the service.
We do not sell personal data, and we do not use message content to train third-party advertising models.
4. Legal basis ({{IF_GDPR_APPLIES}})
Where UK/EU data protection law applies, we rely on: performance of our contract with the creator (operating the inbox they asked us to run); our legitimate interests in securing and improving the service; and consent where required (e.g. optional AI features). Counsel to confirm the final basis per processing purpose.
5. Who we share data with (sub-processors)
We share data only with service providers that help us run Reach, under contract and only as needed:
- Meta Platforms — the source of the connected accounts; we exchange messages and metadata with Meta’s Graph and WhatsApp Cloud APIs.
- Cloud hosting & database ({{HOSTING_PROVIDER}}, {{DATABASE_PROVIDER}}) — to run the service and store connection + conversation records.
- Key management ({{KMS_PROVIDER}}) — to encrypt access tokens at rest.
- AI provider(s) ({{AI_PROVIDER}}) — only when the creator uses AI reply drafting, and only for the content needed to generate a draft.
- Error monitoring ({{ERROR_MONITORING}}) — operational diagnostics. We redact identifiers and message bodies from monitoring data.
A current sub-processor list is available at {{SUBPROCESSOR_LIST_URL}}. We do not share personal data with third parties for their own marketing.
6. Retention
We keep connection records and conversation history for as long as the creator’s account is connected and active, and for {{RETENTION_PERIOD}} thereafter, unless a shorter period is required. Access tokens are deleted promptly when a creator disconnects an account or deletes their Reach account. Backups are purged on our standard rolling schedule ({{BACKUP_RETENTION}}).
7. Your rights & how to delete your data
Creators can disconnect any account at any time from their dashboard; disconnecting revokes our access and deletes the stored access token. To request deletion of all data we hold about you — whether you are a creator or someone who messaged a connected creator — contact {{DATA_DELETION_CONTACT}} or use {{DATA_DELETION_URL}}. We respond within {{DELETION_SLA}}.
Depending on your location you may also have rights to access, correct, port, or restrict processing of your data, and to lodge a complaint with a supervisory authority.
Engineering note for counsel: Meta requires a defined data-deletion mechanism. Choose one — (a) a public Instructions URL describing how to request deletion, or (b) an automated Data Deletion Request Callback that Meta calls. The engine supports either; the choice drives whether {{DATA_DELETION_URL}} is a static page or a callback endpoint.
8. How we protect data
Access tokens are encrypted at rest using per-tenant managed keys. Database access is isolated per tenant (row-level security). Identifiers and message bodies are redacted from operational logs. Access to production data is limited to authorised personnel.
9. International transfers
Data may be processed in {{PROCESSING_REGIONS}}. Where data is transferred across borders we use appropriate safeguards ({{TRANSFER_MECHANISM}}).
10. Children
Reach is for use by adult creators and their adult audiences. It is not directed to anyone under 18, and we do not knowingly collect data from minors.
11. Changes
We may update this policy; material changes will be posted here with a new “last updated” date.
12. Contact
Questions or requests: {{PRIVACY_CONTACT_EMAIL}}, or write to {{LEGAL_ENTITY_NAME}}, {{REGISTERED_ADDRESS}}.