This Privacy Policy explains how Fluxo Ltda. (“Fluxo”, “we”,
“us”, or “our”) collects, uses, discloses, retains, and protects information in
connection with the Fluxo application and related services made available at
app.fluxo.ltda (collectively, the “Service”). By accessing or using the Service, or
by connecting an Instagram or Meta account to it, you acknowledge that you have read and understood this
Policy. If you do not agree, do not use the Service.
This Policy addresses two groups:
For End-User data received from Meta (defined below), the Operator is the data controller and Fluxo acts as a data processor / service provider, processing that data only on the Operator’s documented instructions and as described here.
When an Operator connects an Instagram professional account through Meta’s official APIs (using Facebook Login for Business and the permissions the Operator grants), we receive and process, strictly to provide the Service:
We access only the permissions (scopes) the Operator explicitly grants and only the data needed for the features in use.
fluxo_session) used to keep you signed in. We do not
use advertising or cross-site tracking cookies.| Purpose | Legal basis (GDPR, where applicable) |
|---|---|
| Provide, operate, and secure the Service (authentication, dashboards, messaging, analytics, automation you configure) | Performance of a contract; legitimate interests |
| Send transactional email (verification, password reset, service notices) | Performance of a contract; legitimate interests |
| Deliver automated replies and lead capture that an Operator explicitly configures | The Operator’s legitimate interests / consent obtained by the Operator from the End User |
| Maintain security, prevent abuse and fraud, and enforce our terms | Legitimate interests; legal obligation |
| Comply with law and respond to lawful requests | Legal obligation |
We do not sell personal information, and we do not use Platform Data to build advertising profiles, to train unrelated machine-learning models, or for any purpose incompatible with the reason it was collected. We use Platform Data solely to provide and improve the Service to the connecting Operator, in compliance with the Meta Platform Terms, Meta Developer Policies, and the Instagram Platform Policy.
We share information only as follows, and never sell it:
We retain personal information only as long as necessary for the purposes described here, to provide the Service, to comply with legal obligations, resolve disputes, and enforce agreements. Operators can configure retention windows for certain data (such as cached insights and captured leads). Encrypted access tokens are kept only while an account remains connected and are deleted when the connection is removed. When data is no longer needed, or upon a valid deletion request, we delete or de-identify it.
The windows in the table below are the defaults the Service is configured with. A scheduled job runs daily and permanently deletes data that has passed its window. An Operator may configure a shorter window for their own tenant; where they have, that shorter window is what applies to their data. Rows marked indefinite by default have no automatic expiry — that data is removed when the Operator deletes it, disconnects the account, closes their account, or when we act on a valid deletion request (Section 6).
| Data | Default retention | Notes |
|---|---|---|
| Direct messages | ||
| Direct message content — the text of messages sent to or from a connected account, as shown in the Service’s inbox | 365 days (about 12 months) | Deleted permanently. Meta’s API serves only the most recent messages of a conversation, so purged message text cannot be re-fetched. The conversation record itself is kept — it holds the messaging-window and opt-out state we need to comply with Meta’s policies, and contains no message text. |
| People who interact with the account | ||
| Engager activity timeline — a record of each message, comment, or story interaction, including an excerpt of up to 280 characters of what was written | 400 days | Backs the Operator’s audience view and engagement scoring. |
| Engager profile — the Instagram username, display name, and profile picture of a person who has interacted with a connected account | 730 days (2 years) with no interaction at all | Measured from that person’s last interaction. Deleting a profile also deletes their entire activity timeline. |
| Captured leads | ||
| Leads captured by an automation — for example an email address or phone number a person provides in a message | 90 days | Each Operator sets this per automation; 90 days applies where they choose no other value. |
| Analytics | ||
| Raw cached account insights — unprocessed metric readings fetched from Meta | 90 days | Account-level aggregates only: no message content and no individual End-User identities. |
| Daily insight rollups — one aggregated figure per metric per day, used for long-range charts | 800 days (about 26 months) | Aggregate account metrics only; no personal data about individual End Users. |
| Per-post metric history — how a published post performed over time | 400 days | The post catalogue itself (caption, link, latest figures) is kept while the account stays connected. |
| Hourly story metric polls — intermediate readings collected while a story is live | 30 days | Each story’s final figures are copied to the row below before these are discarded. |
| Final per-story results — one row of aggregate figures per published story | Indefinite by default | Meta serves story insights for 24 hours only, so these figures cannot be re-fetched once discarded and they therefore have no automatic expiry. An Operator may set one. |
| Raw platform payloads | ||
| Raw platform payloads received from Meta — the unprocessed webhook events, which can contain message text and commenter usernames | 30 days | Kept only to detect duplicate deliveries and to diagnose failures; nothing reads them afterwards. |
Backups. We take database backups for disaster recovery. Backups are kept on their own rotation and are not pruned on the schedules above, so information deleted under a retention window, or on a deletion request, can remain inside an existing backup until that backup is itself rotated out. Backups are used only to restore the Service as a whole; they are not queried to retrieve individual records.
Depending on your jurisdiction, you may have rights to access, correct, export, restrict, object to, or delete your personal information, and to withdraw consent. To exercise these rights:
app.fluxo.ltda/privacy/data-deletion; when we receive a valid request we delete the corresponding
connected data and return a confirmation code.We honor valid deletion requests within 30 days (or sooner where required by law). We may retain limited information where necessary to comply with legal obligations or resolve disputes.
We apply technical and organizational safeguards designed to protect information, including: encryption in transit (HTTPS/TLS); encryption of access tokens at rest; strict tenant isolation so one Operator cannot access another’s data; least-privilege access controls; rate limiting; and security hardening of our infrastructure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We and our sub-processors may store and process information in countries other than your own, including the United States. Where required, we rely on appropriate safeguards (such as the European Commission’s Standard Contractual Clauses) for cross-border transfers of personal data.
The Service can send automated replies to inbound messages that an Operator configures. Operators are responsible for obtaining any consent required by law and by Meta’s policies before messaging End Users, for honoring opt-out requests, and for the content of their automations. The Service enforces Meta’s messaging guardrails (for example, inbound-initiated messaging within permitted windows and opt-out handling).
The Service is intended for businesses and users aged 18 or older and is not directed to children. We do not knowingly collect personal information from children under the age of 13 (or the minimum age in your jurisdiction). If you believe a child has provided us information, contact us and we will delete it.
The Service integrates with Meta’s platforms and may link to third-party sites. Their handling of your information is governed by their own privacy policies, including the Meta / Instagram Privacy Policy. We are not responsible for the practices of third parties.
We may update this Policy from time to time. Material changes will be posted at this URL with an updated “Last updated” date, and where required we will provide additional notice. Your continued use of the Service after changes take effect constitutes acceptance. We retain prior in-effect versions of this Policy.
To the fullest extent permitted by applicable law: the Service is provided on an “as is” and “as available” basis without warranties of any kind, whether express or implied, including merchantability, fitness for a particular purpose, and non-infringement. Fluxo does not warrant that the Service will be uninterrupted, secure, or error-free, or that data processed through Meta’s APIs will be accurate or complete. To the fullest extent permitted by law, Fluxo and its affiliates, officers, employees, and suppliers will not be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages, or for any loss of profits, data, goodwill, or other intangible losses, arising out of or relating to your use of (or inability to use) the Service. Nothing in this Policy limits liability that cannot be limited or excluded under applicable law (including certain statutory data-protection rights). This Policy describes our data practices only and does not by itself grant any rights beyond those required by applicable law.
Where Fluxo acts as a controller, our legal bases are set out in Section 3. Where we act as a processor for an Operator, we process personal data only on that Operator’s instructions. You have the rights described in Section 6 and the right to lodge a complaint with your local supervisory authority. To exercise your rights or to reach our privacy contact, email support@fluxo.ltda.
In the preceding 12 months we may have collected the categories of personal information described in Section 2 (identifiers, internet/network activity, commercial information, and content of communications) for the business purposes in Section 3. We do not sell or “share” personal information as those terms are defined under California law, and we do not use sensitive personal information for purposes requiring a right to limit. California residents may exercise rights to know, delete, correct, and non-discrimination by contacting us as described above.
We process personal data in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, Lei nº 13.709/2018, “LGPD”). Our legal bases (bases legais) for processing include the execution of a contract or preliminary procedures at your request, our legitimate interests, compliance with a legal or regulatory obligation, and your consent (consentimento) where required. As a data subject (titular) you have the rights set out in Article 18 of the LGPD, including: confirmation that we process your data; access to it; correction of incomplete, inaccurate, or out-of-date data; anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in non-compliance with the LGPD; data portability; deletion of personal data processed on the basis of your consent; information about the public and private entities with which we have shared your data; information about the possibility of refusing consent and the consequences of doing so; and revocation of consent. You may exercise these rights, or reach our data protection officer (Encarregado), by emailing support@fluxo.ltda. You also have the right to petition the National Data Protection Authority (Autoridade Nacional de Proteção de Dados — ANPD). Where we transfer personal data internationally, we do so in accordance with Article 33 of the LGPD.
Questions, requests, or complaints about this Policy or your data: