1. Introduction

WEBROVA, a simplified joint stock company (SAS) with a capital of €1,000.00, registered in the Bordeaux Trade and Companies Register under number 822 845 160, whose registered office is located at 76 rue des Vergers, 33560 Carbon-Blanc, France (“the Company”), operates the WR Social Manager platform (“the Product”).

This Privacy Policy describes how we collect, use, store, and protect your personal data in compliance with the General Data Protection Regulation (GDPR), the French Data Protection Act, and other applicable laws. By using our Product, you agree to this Policy.

2. Data We Collect

Depending on your interactions with our Product and Facebook, we may collect:

• Facebook Page ID and Page Access Token
• Facebook User ID, name, and profile picture (as provided by Facebook APIs)
• Public comments posted on your Facebook Page (text, IDs, timestamps)
• Private messages sent via Messenger (only when you enable private replies)
• Engagement signals like likes to posts/comments (when enabled)
• Campaign configuration and audit metadata (keywords, rules, logs, timestamps)
• Technical information (IP address, browser/user agent, usage logs)

3. Purpose of Processing

• Detect comments matching your campaign rules (e.g., keywords)
• Post public replies and/or like comments when enabled
• Send private replies via Messenger when enabled
• Operate, secure, improve, and support the Product
• Provide customer support and troubleshoot issues

4. Legal Basis

• Your consent (Article 6(1)(a) GDPR) when connecting your Facebook Page
• Performance of a contract (Article 6(1)(b) GDPR) for delivering the service
• Legitimate interests (Article 6(1)(f) GDPR) to operate and improve the Product

5. Data Retention

We retain data only as long as necessary for the purposes stated above or to comply with legal obligations. Comment texts processed by the bot are retained for no longer than 30 days after processing unless a longer period is legally required. Campaign configuration and audit logs may be retained longer to ensure service continuity and compliance.

6. Sharing of Data

We do not sell or rent personal data. Data may be shared only with:

• Authorised employees of WEBROVA (need-to-know basis)
• Service providers strictly necessary to operate the Product (hosting, databases, monitoring)
• Competent authorities when legally required

7. Security Measures

We implement technical and organizational measures appropriate to the risk, including encryption in transit, access controls, least-privilege, secure backups, and regular testing of safeguards.

8. Your Rights

• Access, rectification, and deletion
• Restriction or objection to processing
• Data portability (when applicable)
• Withdrawal of consent at any time (without affecting prior lawful processing)
• Right to define post-mortem instructions (where applicable)

To exercise your rights, contact us at [email protected]. We may ask for proof of identity to process your request.

9. Data Deletion Instructions (Required by Meta)

If you want to delete your data collected by WR Social Manager, you can:

1. Use the in-app “Delete my data” feature (Settings > Privacy & Data), or
2. Send an email to [email protected] with the subject “Data Deletion Request” and include your Facebook User ID and/or Page ID.

We will confirm receipt and process the deletion within 7 business days. Removing our app from your Facebook account via your Facebook Business Integrations will also trigger deletion of stored data linked to your account.

10. Requests from Public Authorities

WEBROVA has established internal procedures for handling any potential requests from public authorities for user personal data. These include:

• Legal Review – Any request will be reviewed to verify its legal validity before any response is provided.
• Data Minimization – If disclosure is legally required, only the minimum amount of data strictly necessary for the stated purpose will be shared.
• Documentation – All such requests, along with the legal basis, scope of data provided, and the parties involved, will be documented internally for accountability.

WEBROVA does not provide user personal data to public authorities for purposes related to national security or surveillance unless required to do so by applicable law.

11. Children’s Data

Our Product is not intended for children under the age required by applicable law (e.g., 13 or older depending on jurisdiction). We do not knowingly collect personal data from children.

12. International Data Transfers

If data is processed outside the European Economic Area, we ensure appropriate safeguards (such as Standard Contractual Clauses) are in place to protect personal data in accordance with GDPR requirements.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page with an updated revision date.

Last updated: August 2025

14. Contact

For questions about this Privacy Policy or data deletion, contact:
Email: [email protected]
Address: WEBROVA, 76 rue des Vergers, 33560 Carbon-Blanc, France