Social Content Privacy Policy

SOCIAL CONTENT APP

Privacy Policy

Effective date: 17 March 2026 · Last updated: 17 March 2026 · Version 1.0

This Privacy Policy explains how the Social Content Meta application ("the App") collects, uses, and protects data accessed via the Instagram Graph API. The App is operated by Comfort Cloud (ABN: 13 675 599 078) for internal business automation purposes only and is not available to the general public.

1. About This Application

Social Content is a private Meta developer application used exclusively by Comfort Cloud to enable an internal AI automation system (OpenClaw) to interact with the Comfort Cloud Instagram business account. The App does not serve third-party users and is not published on the Meta App Store or any public platform.

We access only the minimum permissions necessary for the App's stated functions. We do not request or use any API permissions beyond what is required for the purposes described in this policy.

2. Data We Access

Through the Instagram Graph API, the App may access the following categories of data in connection with the Comfort Cloud Instagram business account. Some of this data, including public comments that contain usernames, constitutes Restricted Platform Data (as defined under Meta's Platform Terms) because it may be used to identify a specific user.

Instagram business profile information (username, biography, profile picture, follower counts)
Media objects (posts, reels, stories) published to the account
Media insights and engagement metrics (impressions, reach, likes, comments, saves, shares)
Comments and replies on Comfort Cloud's own media, which may include usernames of commenters
Direct messages sent to the Comfort Cloud business account (if applicable)
Hashtag and content performance data associated with the account

The App does not access data from personal Instagram accounts and does not access data belonging to Instagram users beyond what those users have voluntarily made public through interactions with the Comfort Cloud account.

3. How We Use This Data

Data accessed via the App is used solely for the following internal business purposes:

Automating content scheduling, publishing, and management for the Comfort Cloud Instagram account
Monitoring engagement metrics to inform marketing decisions
Generating reports and performance summaries for internal use
Responding to comments and messages on behalf of Comfort Cloud

We only process Platform Data in the ways clearly described in this policy and in accordance with all applicable laws, regulations, and Meta's Platform Terms.

4. What We Do Not Do

We are committed to responsible data use. The following practices are expressly prohibited under this policy and under Meta's Platform Terms, and we do not engage in any of them:

Selling, licensing, or transferring Instagram Platform Data to any third party
Using Platform Data to build or augment user profiles for advertising purposes
Using Platform Data for surveillance, tracking, or monitoring individuals
Combining Platform Data with data from other sources to identify or profile individual Instagram users
Using Platform Data in any way that is inconsistent with Meta's Platform Terms, Developer Policies, or applicable law

5. Data Sharing and Disclosure

We do not sell, trade, or rent Instagram Platform Data to third parties. Data accessed through the App is not shared outside of Comfort Cloud except in the following limited circumstances:

Service providers: We use Anthropic's Claude API to power our internal AI agent. Prompts and responses may include summarised social data. Anthropic is contractually bound to handle any such data in compliance with Meta's Platform Terms and applicable data protection law, and is prohibited from using it for any purpose beyond providing the service to us. Anthropic's practices are also governed by Anthropic's Privacy Policy.
Legal obligations: We may disclose information if required to do so by law or in response to valid legal process. We retain documentation of any such legal requirement and will provide it to Meta on request.

6. Data Storage and Security

Instagram data retrieved by the App is processed in-memory by the OpenClaw automation system running on Comfort Cloud's private infrastructure (a Mac Mini M4 located on Comfort Cloud's internal network). We do not persistently store raw Instagram API responses beyond what is necessary for operational logging.

We implement reasonable technical and organisational measures to protect data against unauthorised access, including:

Encrypted connections (TLS) for all data in transit
Private network access controls via Tailscale
Secure external webhook routing via Cloudflare Tunnel
Access restricted to authorised Comfort Cloud personnel only

7. Data Retention and Deletion

We retain operational logs for a period of up to 90 days for debugging and audit purposes. Aggregated performance metrics (with no personally identifiable information) may be retained for up to 12 months for business analysis.

We will delete Platform Data, including any data held by our service providers, without undue delay in the following circumstances:

When an Instagram user requests deletion of their data
When the data is no longer necessary to provide the App's functionality
When we cease using a service provider that has received Platform Data
When deletion is requested by Meta
When required by applicable law or regulation

To submit a data deletion request, please contact us at the address in Section 12.

8. Your Rights

If you are an Instagram user who has interacted with the Comfort Cloud account and have questions or requests regarding how your data is handled, you may contact us at the address in Section 12. You may also exercise rights under Meta's Platform Terms and Meta's Data Policy by managing your own Instagram privacy settings.

Comfort Cloud complies with applicable Australian privacy legislation, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

9. Meta Platform Compliance

This App is built and operated in accordance with:

This policy does not supersede, modify, or conflict with Meta's Platform Terms or other applicable Meta policies. Where any conflict exists, Meta's Platform Terms shall prevail.

10. Children's Privacy

This App is an internal business tool and is not directed at or intended for use by children under the age of 13. We do not knowingly collect personal information from minors.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be reflected by updating the "Last updated" date and version number at the top of this page. We retain all prior versions of this policy and will provide them to Meta upon request.

Version

Date

Summary of changes

1.0

17 March 2026

Initial version

12. Contact Us

For any questions, concerns, or data deletion requests relating to this Privacy Policy, please contact:

Comfort Cloud
Somerton Park, South Australia, Australia
Email: hello@comfortcloud.com.au