Effective Date: June 24, 2025

This Privacy Policy describes how Surfside Social AI ("we," "us," or "our") collects, uses, and shares information in connection with your use of our Facebook application, "Surfside Social AI" (the "App"), and related services. By using our App, you agree to the collection and use of information in accordance with this policy.

1. Introduction

Surfside Social AI provides automated tools designed to enhance your social media management on platforms like Facebook and Instagram. Our App assists in tasks such as:

• Automating responses to comments on Facebook and Instagram posts.

• Moderating Facebook groups for our customers.

We are committed to protecting your privacy and handling your data with transparency and care.

2. Information We Collect

We collect various types of information to provide and improve our services. The specific information collected will depend on how you use the App and the permissions you grant.

A. Information You Provide Directly

This includes information you explicitly give us when you register for the App, configure its settings, or interact with our support. This may include:

• Account Information: Your name, email address, company name, and login credentials for the Surfside Social AI dashboard.

• Configuration Data: Specific rules, keywords, and moderation settings you define within the App to manage automated responses and group moderation.

B. Information We Collect from Third-Party Platforms (e.g., Facebook, Instagram)

When you connect your Facebook or Instagram accounts to our App, you authorize us to access certain information from those platforms, in accordance with their respective terms and your privacy settings. This information is necessary for the App's functionality. This may include:

• Public Profile Information: Public profile ID, name, and profile picture of the connected account.

• Facebook Page/Group Information (for administrators): Access to Facebook Page names and Page IDs for use with our apps; access to Facebook Group names and Group IDs for moderation purposes; access to comments on posts, group member lists, group posts, group events, and insights necessary for moderation and auto-response features.

• Instagram Business Account Information (for connected accounts): Access to Instagram Business Account names and IDs, and access to comments on posts and media information for auto-response purposes.

• Content of Comments and Posts: The text content of comments on your connected Facebook Pages/Instagram Business Profiles and posts within your moderated Facebook Groups. This content is processed for auto-response and moderation purposes.

• User IDs and Names: Identifiers and names of users who post or comment on your connected Facebook Pages/Instagram Business Profiles or participate in your moderated Facebook Groups. This data is used for interacting with the user (e.g., auto-responding) and for content moderation.

• User Contact Information (from Pages): We may also collect the name, email address, Facebook ID, and Instagram ID of the users who interact with your connected Facebook Pages.

C. Automatically Collected Information

When you access or use our App, we may automatically collect certain information about your device and usage. This may include:

• Log Data: IP address, browser type, operating system, pages viewed, time spent on the App, and interaction with features.

• Usage Data: Features used, frequency of use, and performance metrics of the App's automations.

• Cookies and Tracking Technologies: We may use cookies and similar tracking technologies (e.g., web beacons, pixels) for analytics purposes, to understand how users interact with our App, and to improve our services. You can control the use of cookies at the individual browser level.

3. How We Use Your Information

We use the information we collect for various purposes, primarily to provide, maintain, and improve our App and services.

A. To Provide and Operate the App

• Automated Responses: To analyze comments on your connected Facebook and Instagram posts and generate automated replies based on your defined rules, using poster/commenter names and IDs for direct interaction.

• Group Moderation: To monitor activity within your designated Facebook groups, apply moderation rules (e.g., approve/decline posts, remove members, flag content), and manage group settings as configured by you. This includes using post/comment content to maintain a safe environment.

• Account Management: To manage your user account, provide customer support, and communicate with you about your service.

B. To Improve and Develop Our Services

• Analysis and Research: To understand how users interact with our App, identify trends, and improve its features and performance. This includes using data collected via cookies and tracking technologies.

• AI Model Training: We may use collected Page data (name and ID), Poster/Commenter names and IDs, and Post/Comment content to help train and improve our AI models, enabling them to better service our customers (Page owners) by enhancing automation and moderation capabilities.

• Troubleshooting: To diagnose and resolve technical issues.

C. For Communication

• Service-Related Communications: To send you updates, security alerts, and administrative messages.

• Marketing and Follow-up: We use the collected user contact information (name, email address, Facebook ID, Instagram ID) for marketing initiatives and follow-up communications.

• Marketing (with consent): We may send you marketing communications where we have obtained your consent to do so. You can opt-out of receiving marketing communications at any time by emailing us at [email protected].

D. For Security and Compliance

• Fraud Prevention: To detect and prevent fraudulent or unauthorized activity.

• Legal Compliance: To comply with legal obligations, enforce our terms and conditions, and protect our rights, privacy, safety, or property, and that of our users or others.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• With Your Consent: We may share information when you give us explicit permission to do so.

• Service Providers: We may share information with third-party vendors and service providers who perform services on our behalf, such as hosting, analytics, customer support, and payment processing. These providers are obligated to protect your information and use it only for the purposes for which it was disclosed.

• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).

• Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be transferred.

• Aggregated or Anonymized Data: We may share aggregated or anonymized data that cannot reasonably be used to identify you.

5. Data Retention

We retain your information for as long as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our agreements. Information used for training AI models (such as Page data, Poster/Commenter names and IDs, and Post/Comment content) is not stored long-term after it has served its purpose for model improvement. User contact information collected from Pages (name, email address, Facebook ID, Instagram ID) is retained indefinitely for marketing and follow-up purposes, unless you request its removal.

6. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• Access: The right to request access to the personal information we hold about you.

• Rectification: The right to request correction of inaccurate or incomplete information.

• Erasure: The right to request deletion of your personal information, subject to certain exceptions. You can request the removal of your user contact information (name, email address, Facebook ID, Instagram ID) at any time by emailing us at [email protected].

• Objection/Restriction: The right to object to or request restriction of our processing of your personal information.

• Data Portability: The right to receive your personal information in a structured, commonly used, and machine-readable format.

To exercise these rights, please contact us using the information provided below.

7. Data Security

We implement reasonable technical and organizational measures designed to protect your information from unauthorized access, use, alteration, and disclosure. However, no internet transmission or electronic storage method is 100% secure.

8. Third-Party Links

Our App may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies of any third-party sites you visit.

9. Geographical Scope and GDPR

Our products and applications are intended for use exclusively within the United States. They are not designed to comply with, and we do not claim compliance with, the General Data Protection Regulation (GDPR) or similar privacy laws outside of the United States. Users located outside of the United States should not use our application. If users outside of the United States choose to use the application, they do so at their own risk and should not assume that local privacy laws or regulations will be followed.

Regardless of your location, you can request the removal of your data by emailing us at [email protected]. Please refer to the "Data Removal" section (Section 6, "Erasure" subheading) for more details.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes.