Privacy Policy

Effective Date: Draft, not yet in effect
Application: Agenca
Entity: Code Clouders

1. Introduction and Scope

This Privacy Policy explains how Code Clouders ("we", "us", or "our") collects, uses, stores, and protects information when you access or use Agenca (the "Service").

Agenca is a business-to-business (B2B) Software-as-a-Service application built for marketing agencies and marketing teams. The Service connects to third-party advertising platforms—specifically Meta ad accounts—to compute read-only performance analytics, assemble persistent client context, and generate draft reports and advisory recommendations for human review.

This policy applies to authorized users of customer workspaces, visitors to our public pages, and individuals whose data is processed through customer-authorized configurations of the Service.

2. Who We Are and Contact Details

Code Clouders acts as:

1. A Data Controller for user account information, billing details, identity credentials, and direct communications.
2. A Data Processor (or service provider) for workspace content, client business records, and advertising performance metrics ingested on behalf of our agency customers.

Data Protection Contact:

• Entity: Code Clouders
• Address: to be confirmed
• Email: to be confirmed

3. Categories of Data We Process

3.1 Account and Identity Data

• Direct registration: Name, email address, password hash, workspace assignment, and role (owner, staff).
• Social sign-in (Google and Facebook Login): Name, verified email address, and provider subject identifier per requirement FR-046. Social sign-in is used solely for user authentication; it does not grant advertising permissions.

3.2 Workspace and Client Business Data

• Agency workspace details, client account profiles, brand identity rules, target audience notes, objectives, price and currency configurations, and user feedback entered into client profiles (requirement FR-006).

3.3 Connected Advertising Platform Data (Meta)

• When a customer explicitly connects a Meta ad account via our authorized integration (requirement FR-011):
  • Provider identifiers: Account IDs, campaign IDs, ad set IDs, and ad creative references.
  • Aggregated performance metrics: Daily spend, impressions, clicks, attributed conversion counts, and conversion values (requirements FR-012, FR-013).
  • Attribution settings, reporting timezones, and account currencies.
• Read-only boundary: In the current release, our integration requests read-only permissions (ads_read, read_insights). The Service does not ingest raw individual consumer identities or personal tracking records from Meta ad accounts (requirement FR-037).

3.4 Telemetry, Error Diagnostics, and Email

• Product telemetry (PostHog): Scoped user actions and product feature usage. Events carry workspace and client scope identifiers only; client business content is never sent to telemetry (decision D-026).
• Error diagnostics (Sentry): Application stack traces, runtime exceptions, and performance traces. Operational diagnostic traces redact credentials, access tokens, and sensitive client content (decision D-026, requirement BR-24).
• Transactional communications (Resend): Email address, recipient name, invitation tokens, password reset links, and report share links (decision D-025).

3.5 Artificial Intelligence Model Processing

• Data sent to our model providers (OpenAI, Anthropic, Google, and OpenRouter) consists of bounded context excerpts: verified profile facts, deterministic metric summaries, and drafting instructions (requirement FR-026).
• No model training: None of our model providers are permitted to use customer data, advertising metrics, or workspace inputs to train their base models (requirement BR-23, requirement FR-042).

4. Purposes and Legal Bases for Processing

We process personal and operational data under the European Union General Data Protection Regulation (GDPR) and the Egyptian Personal Data Protection Law No. 151/2020:

1. Performance of Contract (GDPR Art. 6(1)(b); Law 151/2020 Art. 6): Creating accounts, authenticating users, synchronizing connected ad accounts, generating weekly draft reports, and delivering core platform features.
2. Legitimate Interests (GDPR Art. 6(1)(f); Law 151/2020 Art. 6): Securing workspaces, monitoring system stability, detecting application errors, preventing abuse, and enforcing tenant isolation.
3. Consent (GDPR Art. 6(1)(a); Law 151/2020 Art. 5): Connecting external provider accounts, optional integrations, or specific marketing communications.
4. Legal Compliance (GDPR Art. 6(1)(c); Law 151/2020 Art. 6): Complying with financial recordkeeping, statutory audits, and valid law enforcement requests.

5. Protection of Meta Platform Data

We respect the privacy and security of Meta Platform Data:

1. Limited Use: Data obtained through Meta APIs is used exclusively to provide analytics, draft reporting, and advisory recommendations to the specific customer who connected the ad account.
2. No Sale or Commercial Transfer: Meta Platform Data is never sold, licensed, rented, or transferred to data brokers or advertising networks.
3. Strict Isolation: Meta data is segregated by tenant scope (workspace_id and client_account_id) using PostgreSQL Row-Level Security (RLS). Cross-tenant aggregation and cross-agency learning are disabled by default (requirements FR-037, FR-042, BR-23).
4. Disconnection and Deletion: When a customer disconnects a Meta ad account, the stored provider access token is deleted and metric synchronization halts; ad account data already imported is purged when the customer requests deletion, in accordance with Section 8.

6. Hosting Infrastructure and International Transfers

Agenca is hosted on servers located in the European Union (Hetzner Online GmbH, Germany and Finland) per decision D-023. Off-server backups are stored in encrypted European Union facilities.

Where data is processed by sub-processors outside the European Economic Area (EEA) or Egypt, transfers are safeguarded through:

• European Commission Standard Contractual Clauses (SCCs).
• Contractual commitments prohibiting the use of customer data for machine learning model training.
• Commercial data protection agreements providing equivalent protections under Egyptian Law No. 151/2020.

7. Sub-processors

We engage selected third-party service providers to support application delivery. Each sub-processor is bound by data protection agreements containing confidentiality and data protection terms:

8. Data Retention and Deletion Schedule

We retain data strictly in accordance with product requirement FR-040:

1. Advertising Performance Metrics: Retained for 24 months from ingestion to allow year-over-year performance reporting, after which records are purged.
2. Conversations and Redacted Diagnostic Traces: Retained for 90 days, then deleted.
3. Audit and Decision Evidence: Retained for 24 months to preserve reproducible accountability for published reports, user authorizations, and operational logs.
4. Database Backups: Automated rolling backups expire within 35 days unless an approved legal hold applies.
5. Account Termination: Upon a verified customer request to delete a workspace, operational records are purged within 30 days, with residual backup copies expiring on their standard 35-day cycle.

9. Security Safeguards

We protect customer data through layered technical and organizational controls:

• Encryption: TLS 1.3 for data in transit; AES-256 for data at rest (NFR-07).
• Credential Protection: Provider access tokens are envelope-encrypted using dedicated master keys; tokens are never exposed in model contexts, browser storage, logs, or reports (requirement FR-011, decision D-031).
• Tenant Isolation: Every client table carries mandatory workspace_id and client_account_id identifiers. PostgreSQL Row-Level Security (RLS) is forced on all tenant tables, preventing cross-tenant access at the database engine level (requirement NFR-11, tenancy.md).
• Controlled Support Access: Platform administrator access and impersonation require an explicit business reason, carry an automatic expiration (default 60 minutes, maximum 24 hours), display a continuous active banner, and create immutable audit log entries (requirements FR-044, BR-24).

10. Data Subject Rights

Under GDPR (Articles 15–22) and Egyptian Law No. 151/2020, you have the right to:

1. Access: Request a copy of the personal data we hold about you.
2. Rectification: Request correction of inaccurate or incomplete records.
3. Erasure ("Right to be Forgotten"): Request deletion of personal records, subject to statutory retention requirements.
4. Restriction and Objection: Restrict or object to processing based on legitimate interests.
5. Data Portability: Receive your data in a structured, machine-readable format.
6. Withdraw Consent: Revoke previously granted consent (such as disconnecting an ad account) at any time.

To exercise these rights, submit your request to to be confirmed, or disconnect Meta in the app, as described in our Data Deletion Guide. Deleting a workspace or a user account is a request by email. We respond to verified requests within 30 days.

11. Children's Privacy

Agenca is exclusively a commercial enterprise service. We do not knowingly solicit or collect personal information from individuals under 18 years of age. If we become aware that an account has been registered by a minor, the account and associated records will be deleted immediately.

12. Changes to this Policy

We may update this Privacy Policy from time to time to reflect operational changes, new integrations, or evolving legal obligations. When material updates occur, we will notify registered workspace owners via email or through a visible dashboard notification at least 30 days prior to the effective date.

13. Contact and Regulatory Inquiries

For questions, privacy inquiries, or regulatory notices, please contact:

Privacy Office Code Clouders to be confirmed Email: to be confirmed