[LEGAL] PRIVACY — META ADS MANAGEMENT APP

Privacy Policy.

Last updated: June 30, 2026

This Privacy Policy describes how FinPro Solutions, LLC ("FinPro," "we," "us," or "our") collects, uses, stores, and protects data through our Meta Ads Management Application (the "App") that integrates with the Meta Marketing API to manage advertising campaigns for our clients.

By connecting your Meta ad account to our App, you agree to the practices described in this Privacy Policy.

1. Data We Access

The App accesses the following data from your connected Meta ad accounts, Pages, and Business Manager accounts:

Ad Account and Campaign Data

▸Campaign names, ad set configurations, ad creatives, and performance metrics.
▸Budget settings, bid strategies, and scheduling configurations.
▸Targeting parameters (audience definitions, interests, demographics, geographies).
▸Ad creative assets (images, videos, ad copy, headlines, descriptions).
▸Insights and reporting data (impressions, clicks, conversions, spend, reach, frequency, CTR, CPA, ROAS).

Business Manager Data

▸Business account names and IDs.
▸Assigned user roles and permissions within Business Manager.
▸Connected ad accounts, Pages, and Instagram accounts.

Page Data

▸Page names and IDs associated with ad accounts.
▸Page engagement metrics relevant to ad performance.

User Profile Data (limited)

▸Name and profile picture for users who have granted access to the App.
▸User IDs associated with business assets.

The App does not collect:

▸Personal health information.
▸Financial account numbers or payment instrument details.
▸Private messages or direct messages.
▸Data from personal Facebook profiles beyond what is required to manage ads.

2. How We Use Your Data

We use the data accessed through the App exclusively for:

▸Campaign Management: Creating, editing, pausing, and optimizing advertising campaigns, ad sets, and individual ads across connected accounts.
▸Performance Analysis: Pulling insights and reporting data to analyze campaign effectiveness, identify trends, and measure key performance indicators.
▸Optimization Recommendations: Evaluating performance data to recommend budget reallocation, creative improvements, audience adjustments, and bidding strategy changes.
▸Creative Operations: Uploading, organizing, and testing ad creative assets (images, videos, copy variations).
▸Audience Management: Building, updating, and refining targeting audiences.
▸Cross-Channel Reporting: Combining Meta ads data with performance data from other advertising platforms to provide unified analytics.
▸Automated Monitoring: Checking campaign performance on a scheduled basis to detect anomalies, budget pacing issues, creative fatigue, or performance thresholds that require attention.

We do not use your data to:

▸Sell or rent data to third parties.
▸Build user profiles for purposes unrelated to ad management.
▸Retarget your data for our own marketing.
▸Share your data with other clients.

3. Legal Basis for Data Processing

We process data based on:

▸Contractual necessity: Data is processed to fulfill our service agreement with you for advertising management services.
▸Legitimate interest: Monitoring and optimizing campaigns to deliver the services you engaged us for.
▸Consent: Where required, we obtain explicit consent before accessing specific data elements.

4. Data Storage and Retention

Where data is stored

▸Performance data may be stored temporarily in our analytics, data warehouse, or reporting platforms for analysis and historical comparison.
▸Campaign configuration data is accessed in real time from Meta's APIs and is not permanently replicated unless stored for reporting purposes.
▸Ad creative assets are stored in Meta's systems and may be cached locally for operational efficiency.

How long we retain data

▸Campaign performance data: Retained for the duration of the client engagement plus 24 months for historical benchmarking, unless you request earlier deletion.
▸Creative assets: Retained in Meta's ad library for the life of the campaign.
▸Access tokens and credentials: Removed within 24 hours of engagement termination.

Security measures

▸API tokens and credentials stored using encrypted environment variables.
▸Access restricted to authorized FinPro personnel and approved automation systems.
▸All API communication conducted over HTTPS/TLS.
▸No data stored on portable or removable media.

5. Third-Party Services

In the course of providing ad management services, the App relies on a limited set of third-party service providers (sub-processors), including:

▸Advertising platform: Meta (Facebook/Instagram), for campaign management, insights, and creative operations via the Meta Marketing API.
▸Analytics and cross-channel reporting providers: For aggregating campaign performance data and attribution across advertising platforms.
▸Cloud hosting and data warehouse providers: For historical data storage and reporting.
▸AI orchestration and automation providers: For analyzing performance data and assisting with campaign management.

Each third-party service maintains its own privacy policy and data-handling practices. We share only the minimum data necessary to provide the services described in this policy. Our specific sub-processors may change over time as we improve our services; the categories above describe the types of providers we use. You may request a current list of named sub-processors by contacting us at the address below.

6. Data Sharing

We do not sell, rent, or trade your data. We share data only:

▸With the third-party service providers described above, as necessary to provide ad management services.
▸With Meta (Facebook) as part of normal API operations.
▸When required by law, court order, or government regulation.
▸In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations.

7. Your Rights

Depending on your jurisdiction (including under the GDPR, the California Consumer Privacy Act as amended by the CPRA, and other applicable privacy laws), you may have the right to:

▸Access: Request a copy of the personal data we hold about you.
▸Rectification: Request correction of inaccurate or incomplete data.
▸Erasure: Request deletion of your data (see Data Deletion below).
▸Restriction: Request that we limit processing of your data.
▸Portability: Receive your data in a structured, machine-readable format.
▸Objection: Object to processing based on legitimate interests.
▸Non-discrimination: Exercise your privacy rights without receiving discriminatory treatment.
▸Withdraw Consent: Disconnect your ad account at any time, which revokes the App's access to your data.

California residents: We do not "sell" or "share" your personal information as those terms are defined under the CCPA/CPRA, and we have not done so in the preceding 12 months. Because the App is a business-to-business advertising tool, we do not use or disclose sensitive personal information for purposes that would require an opt-out.

To exercise any of these rights, contact us at support@finpro.consulting.

8. Data Deletion

To request deletion of your data from our systems:

▸Disconnect your ad account: Remove the App from your Meta Business Settings or Facebook Settings > Apps and Websites. This immediately revokes API access.
▸Submit a deletion request: Email support@finpro.consulting with the subject line "Data Deletion Request" and include the ad account ID(s) associated with your request.
▸Processing timeframe: We process deletion requests within 30 days of receipt. You will receive a confirmation email once deletion is complete.

Data Deletion Callback URL: Upon disconnecting the App, Meta sends a data deletion signal to our callback endpoint, which triggers automated removal of associated tokens and cached data.

9. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence, including the United States. Where applicable, we use standard contractual clauses or other legally recognized transfer mechanisms to ensure appropriate safeguards for international data transfers.

10. Children's Privacy

The App is designed exclusively for business-to-business advertising management. We do not knowingly collect data from individuals under 18. Meta's advertising platform requires users to be at least 18 years old.

11. Cookies and Tracking

The App itself does not use cookies. However, the Meta advertising platform uses cookies and similar technologies on ad placements, which are governed by Meta's own Cookie Policy. We do not control Meta's use of cookies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email or through the App interface at least 30 days before the changes take effect. The "Last updated" date at the top of this policy reflects the most recent revision.

13. Contact Information

For questions, concerns, or requests related to this Privacy Policy or your data:

FinPro Solutions, LLC
Email: support@finpro.consulting
Mailing address: 1239 Harvard Ave, Billings, MT 59102

We will respond to all legitimate inquiries within 30 days.

14. Supervisory Authority

If you believe we have not addressed your privacy concern satisfactorily, you have the right to lodge a complaint with your local data protection authority. For EU residents, you may lodge a complaint with the supervisory authority in your member state.