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Privacy Policy

newtwelve strategist · Last updated: September 6, 2026

This Privacy Policy explains what personal data newtwelve ("newtwelve," "we," "us"), a small business based in the United States, collects through newtwelve strategist at strategist-production-cf58.up.railway.app (the "Service"), how we use it, who we share it with, and the rights you have over it. It goes together with our Terms of Service.

1. What we collect

2. Where the data comes from

We collect data directly from you (account signup, chats, uploads), from your Instagram account and Facebook Pages through Meta's official APIs if you choose to connect them, from public social-media sources through our data provider, and from Stripe for subscription status.

3. How we use your data

4. Legal bases (GDPR)

Where the EU or UK GDPR applies, we process your data on these bases: performance of a contract (providing the Service you signed up for, including AI processing and billing), consent (connecting your Instagram account, receiving recap emails), legitimate interests (securing the Service, preventing abuse, improving reliability), and legal obligation (records we must keep by law).

5. AI processing

The AI agents in the Service are powered by Anthropic's Claude models. To generate responses, your chat content, uploaded files and images, and connected account data are sent to Anthropic's API. We use your content only to operate and provide the Service to you, including letting your AI team learn from your content to improve your own agents' output. We do not use one customer's private content to serve other customers, and we do not train our own foundation models on user content. AI outputs can be wrong, so treat them as suggestions, not facts or professional advice.

6. Instagram connection

You can optionally connect an Instagram professional account through Meta's official OAuth flow ("Instagram API with Instagram Login"). If you do, we store your access token and fetch your profile information, media, per-post insights (saves, shares, reach), account insights, and follower demographics. We comply with Meta's Platform Terms.

Agencies managing Facebook Pages can additionally connect through Meta's "Facebook Login for Business" flow. If you do, we store the access tokens Meta issues, the list of Pages you granted, the single Page you explicitly select for a brand workspace, that Page's insights (such as reach, engagement, views and fan count), and basic profile and post data of the Instagram account linked to that Page. These permissions are read-only: the Service cannot post, message, or run ads on your behalf.

You can disconnect at any time: in the app, by removing the app in your Instagram or Facebook settings, or through Meta's data-deletion flow. Disconnecting deletes the access tokens and all Instagram and Facebook data we fetched for that connection.

Data deletion requests: deleting your account in Account Settings erases your data, including connected-platform tokens and fetched platform data. We also honor Meta's automated deauthorization and data-deletion callbacks. You can additionally request deletion by emailing info@newtwelve.com.

7. Public social data and image display

The Service fetches public social-media profile and post data (Instagram, TikTok) through a third-party data provider, ScrapeCreators, to power insights and trend features. We also proxy and thumbnail public CDN images so they can display inside the app; these images are used for display only. Instagram and TikTok data remains subject to those platforms' own terms. We are not affiliated with or endorsed by Meta or TikTok.

8. Emails and your choices

We send daily or periodic recap emails to your account email through Resend or an SMTP relay. Every recap email includes an unsubscribe link, and you can also opt out in the app. Transactional emails (such as verification and billing notices) are separate from recaps and are sent as needed to operate your account.

9. Sub-processors and sharing

We share personal data only with service providers that help us run the Service, and only as needed:

We may also disclose data if the law requires it. We do not sell your personal data, and we do not share it for targeted advertising.

10. Retention

11. Security

We protect your data with HTTPS for all traffic, hashed passwords, and access controls that keep each account's data isolated. The Service is hosted on Railway in the United States, with database backups to a managed Postgres. No system is perfectly secure, but we work to protect your data and will notify you of breaches as the law requires.

12. International transfers

We host and process data in the United States. If you use the Service from outside the US, your data is transferred to and processed in the US, where privacy laws may differ from those in your country. We protect it as described in this Policy wherever it is processed.

13. Children

The Service is for users 16 and older. People under 16 are not permitted to use it, and we never knowingly collect data from children under 13. If you believe a child has created an account, contact us and we will delete it.

14. Your rights and how to use them

Depending on where you live (including under the EU/UK GDPR and the California CCPA/CPRA), you have the right to access, correct, delete, and export your personal data, and to object to or restrict certain processing. We do not sell personal data and do not share it for targeted advertising, so there is nothing to opt out of on that front. We will not discriminate against you for exercising your rights.

15. Cookies and Do Not Track

We use a single first-party session cookie to keep you signed in. It is strictly necessary to operate the Service. We do not use advertising cookies or third-party trackers. Because we do not track you across other sites, the Service behaves the same whether or not your browser sends a Do Not Track signal.

16. Changes to this Policy

We may update this Policy from time to time. If a change is material, we will notify you through the Service or by email before it takes effect. The date at the top shows when it was last revised.

17. Contact

Privacy questions, rights requests, and support: info@newtwelve.com.


See also our Terms of Service.

newtwelve · Contact: info@newtwelve.com