Privacy Policy

Social Media Loyalty

Effective Date: February 11, 2026 | Version 1.0

Social Media Loyalty (“SML,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect information when you use our platform at campaign.socialmedialoyalty.com.

1. Who We Are

Social Media Loyalty (SML) is a data analytics marketplace headquartered in the State of Texas, United States. We provide engagement analytics tools to business clients (“Account Owners”) who manage Instagram marketing campaigns.

Important Distinction:

SML operates as a Data Processor. The Account Owner (brand/business) is the Data Controller and bears full legal responsibility for data collection activities. SML does not directly scrape or extract data from Instagram — all data retrieval is performed by Third-Party APIs at the Account Owner's direction and responsibility.

2. Categories of Users

This Privacy Policy addresses three categories of individuals:

CategoryWho They AreData Relationship
Account OwnerBrand manager, campaign owner, or business that registers on SMLProvides account data directly; acts as Data Controller
End UserInstagram user who interacts with campaign posts (likes, comments, stories)Public engagement data processed; identity protected by default
Site VisitorAnyone who visits the SML website (public pages, leaderboards, counter pages)Standard web analytics and cookies (with consent)

3. Information We Collect

3.1 Account Owner Information (Provided Directly)

  • Full name and username
  • Email address (verified)
  • Password (stored hashed with bcrypt)
  • Company/organization name
  • Instagram business account username(s)
  • Login activity (timestamps, IP address, device/browser info)

3.2 End User Information (Collected via Third-Party APIs)

Note: This data is collected by Third-Party APIs at the Account Owner's request and responsibility. SML does not directly scrape, crawl, or extract any data from Instagram.

  • Instagram username (displayed masked by default — e.g., joh***23)
  • Display name (full name as shown on Instagram profile)
  • Profile picture (displayed blurred by default)
  • Instagram user ID (numeric identifier)
  • Engagement data: which campaign posts the user liked, commented on, or shared via stories
  • Comment text content
  • Derived metrics: engagement scores, rankings, loyalty analysis

3.3 Information NOT Collected About End Users

  • Email addresses or phone numbers
  • Private or direct messages
  • Precise geolocation
  • Financial or payment information
  • Data from private Instagram accounts
  • Follower/following lists
  • Content from non-campaign posts

3.4 Automatically Collected Information (Site Visitors)

  • IP address (used for security logging)
  • Browser type and version
  • Operating system
  • Pages visited and timestamps
  • Referring URL

4. How We Use Your Information

PurposeData UsedLegal Basis
Provide analytics services to Account OwnersEnd User engagement dataContractual necessity / Legitimate interest
Generate leaderboards and rankingsEngagement scores, usernames (masked)Contractual necessity
Account authentication and securityLogin credentials, IP address, device infoLegitimate interest (security)
Send system emails (verification, reports, OTP)Email addressContractual necessity
Website analytics (with consent)Page views, device infoConsent
Fraud prevention and abuse detectionLogin attempts, IP addressesLegitimate interest (security)

We do not sell, rent, or trade any personal data to third parties for marketing purposes.

5. Privacy by Default

How We Protect End User Identity:

  • Username Masking: Internal characters of usernames are replaced with asterisks (*). Example: joh***23. For short usernames (<8 characters): mik***.
  • Profile Picture Blurring: All profile pictures are displayed with a CSS blur filter, making identification impossible.
  • No Direct Identification: The Account Owner can never see the exact Instagram username or view the profile picture clearly.
  • Opt-In Only Reveal: Full End User information is only viewable if the End User explicitly grants permission (Opt-In).

These protections are applied across all viewing contexts:

  • Owner dashboard (private)
  • Public leaderboard (shared links)
  • Counter pages (staff lookup)
  • Admin panel

6. Data Collection Methods

SML does NOT directly scrape, crawl, or extract data from Instagram.

All data retrieval is performed through Third-Party APIs at the Account Owner's express direction and under the Account Owner's full legal responsibility. The Account Owner acknowledges awareness of all applicable laws and Meta/Instagram Terms of Service.

SML's role is limited to:

  • Receiving data from Third-Party APIs
  • Processing and converting data into numerical scores
  • Generating analytics, leaderboards, and reports
  • Applying Privacy by Default protections (masking, blurring)

7. Information Sharing and Disclosure

We may share information in the following circumstances:

RecipientData SharedPurpose
Account OwnerEnd User engagement data (masked/blurred)Campaign analytics
Google AnalyticsPage views, device info (anonymized)Website analytics (with consent)
Email service providerEmail addressSystem notifications
Cloud storage providerProfile pictures, media filesFile storage and delivery
Law enforcementAs required by lawLegal obligation

We do not sell personal data. We do not share End User data with any party other than the Account Owner who manages the relevant campaign.

8. Cookies and Tracking Technologies

8.1 Essential Cookies

These are required for the platform to function and cannot be disabled:

  • Session cookies: Maintain your login state
  • Security cookies: Fraud prevention and access control

8.2 Analytics Cookies (Consent Required)

We use Google Analytics (GA4, Measurement ID: G-F5QXF6X9FS) to understand how the platform is used. These cookies are only loaded with your consent:

  • _ga — Distinguishes unique visitors (expires: 2 years)
  • _gid — Distinguishes visitors within 24 hours (expires: 24 hours)

8.3 Managing Cookies

You can manage your cookie preferences through your browser settings. Disabling essential cookies may prevent the platform from functioning properly.

9. Data Retention

Data TypeRetention PeriodReason
Account Owner dataDuration of account + 90 daysService delivery and data export period
End User engagement dataDuration of associated campaignCampaign analytics
Security logsRetained for platform securityLegitimate interest (fraud prevention, security)
Deletion request recordsPermanently retainedLegal compliance and audit trail
Backup dataRolling backups (overwritten periodically)Disaster recovery

10. Data Rights and Responsibilities

Important:

As SML operates solely as a Data Processor (a marketplace tool), all data privacy rights, obligations, and compliance responsibilities under GDPR, CCPA, PIPEDA, or any other applicable regulation rest entirely with the Account Owner (Data Controller). SML does not accept, guarantee, or assume any rights or obligations on behalf of End Users or Account Owners.

10.1 Account Owner's Responsibility for End User Rights

The Account Owner, as the Data Controller, is solely responsible for:

  • Complying with all applicable data protection regulations (GDPR, CCPA, PIPEDA, etc.) in their jurisdiction
  • Fulfilling End User data access requests
  • Fulfilling End User data deletion requests
  • Responding to End User privacy inquiries
  • Informing End Users about data collection and their rights
  • Obtaining any required consent from End Users

10.2 Data Deletion Convenience Tool

SML provides a Delete My Data page as a convenience tool only. This tool does not constitute SML accepting any legal obligation, guarantee, or responsibility for data deletion compliance. The Account Owner remains the sole party responsible for fulfilling all data rights under applicable law.

End Users may submit a deletion request through this tool. Upon receiving a valid request, SML will process the removal of data from its systems as a service to the Account Owner. All legal liability for compliance with deletion obligations remains with the Account Owner.

10.3 Regulatory Framework Reference

For informational purposes only, the following regulations may apply to the Account Owner's use of the Platform. Compliance with these regulations is entirely the Account Owner's responsibility:

RegulationJurisdictionResponsible Party
GDPR (Articles 15-20)European Union / EEAAccount Owner (Data Controller)
CCPA (Section 1798.105)California, United StatesAccount Owner (Data Controller)
PIPEDA (Principle 4.3.8)CanadaAccount Owner (Data Controller)
Meta/Instagram Terms of ServiceGlobalAccount Owner

10.4 No Acceptance of Liability

SML expressly does not accept any liability, obligation, or responsibility for:

  • Compliance with GDPR, CCPA, PIPEDA, or any other data protection regulation
  • Fulfilling data subject rights (access, erasure, rectification, portability, restriction)
  • Any claims, damages, or legal actions arising from the collection, processing, or use of End User data
  • Compliance with Meta/Instagram Terms of Service
  • Any failure by the Account Owner to inform End Users about data collection

The Account Owner agrees to indemnify and hold harmless SML from all such claims as outlined in our Terms & Conditions.

11. Data Security

We implement appropriate technical and organizational measures to protect your data:

  • Encryption in Transit: All connections use HTTPS/TLS
  • Password Security: Passwords hashed with bcrypt (never stored in plain text)
  • Two-Factor Authentication: OTP via email for admin access
  • Access Control: Role-based permissions; users only see their assigned campaigns
  • Activity Logging: Comprehensive audit trail of all access
  • Regular Backups: Automated encrypted backups
  • API Key Rotation: Regular rotation of Third-Party API credentials

While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

12. Children's Privacy

SML is a business-to-business (B2B) platform. Account Owners must be at least 18 years of age. The Platform relies on Instagram's own age verification and restrictions for End Users (minimum 13 years in most jurisdictions).

We do not knowingly collect personal data from children under 13. If we become aware that data has been collected from a child under 13, we will delete it promptly.

13. International Data Transfers

SML is headquartered in the United States. If you access the Platform from outside the United States, your data may be transferred to and processed in the United States. By using the Platform, you consent to this transfer.

We serve Account Owners in any country permitted by U.S. federal law. The Platform may not be used from sanctioned countries (Cuba, Iran, North Korea, Syria, Crimea region, etc.).

14. Third-Party Services

The Platform integrates with third-party services. Each has its own privacy policy:

  • Google Analytics: Website usage analytics — Google Privacy Policy
  • Third-Party APIs: Instagram data retrieval (at Account Owner's direction)
  • Cloud Storage Provider: Media file storage
  • Email Service: System notifications and reports

We are not responsible for the privacy practices of third-party services.

15. Account Owner Privacy Responsibilities

All Privacy Responsibilities Rest with the Account Owner

As the Data Controller, the Account Owner bears sole and complete responsibility for all privacy-related obligations. SML provides tools only and accepts no liability for the Account Owner's compliance or non-compliance.

The Account Owner is solely and exclusively responsible for:

  • Complying with GDPR, CCPA, PIPEDA, COPPA, and all applicable privacy laws in their jurisdiction
  • Complying with Meta/Instagram Terms of Service
  • Informing End Users that their public engagement data is being tracked
  • Providing transparency about data collection in their Instagram bio and campaign posts
  • Fulfilling all End User data rights (access, erasure, rectification, portability, restriction of processing)
  • Responding to End User privacy inquiries and complaints
  • Obtaining any required consent from End Users under applicable law
  • Maintaining records of compliance activities
  • Bearing all legal liability for any claims, fines, or penalties arising from data collection and processing

The Account Owner agrees to indemnify and hold harmless SML from any and all claims, damages, fines, penalties, or legal actions related to privacy, data protection, or data rights compliance.

For detailed guidance, Account Owners should refer to the Campaign Owner Privacy Guide provided during onboarding.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify Account Owners of material changes via email at least 30 days before the changes take effect. The “Effective Date” at the top of this page indicates when this policy was last revised.

Continued use of the Platform after changes constitutes acceptance of the updated Privacy Policy.

17. Contact Us

If you have questions about this Privacy Policy, want to exercise your privacy rights, or have concerns about your data, please contact us:

Social Media Loyalty

Summary of Key Points

TopicSummary
What We AreA data analytics marketplace (Data Processor)
Data ControllerThe Account Owner (business/brand)
Data ScrapingNOT by SML; by Third-Party APIs at Account Owner's direction
Privacy by DefaultUsernames masked, photos blurred; revealed only via Opt-In
Data SellingWe do NOT sell personal data
Data RightsAll data rights compliance is Account Owner's responsibility
Delete My DataConvenience tool at /delete-my-data (no SML liability)
Governing LawState of Texas, United States

By using Social Media Loyalty, you acknowledge that you have read and understood this Privacy Policy.

© 2026 Social Media Loyalty - Pedram Bahaeabadi. All Rights Reserved.