Privacy Policy
This Privacy Policy explains how Conor Comment (“we”, “us”, “our”) collects, uses, shares, and protects personal data when you visit our website, contact us, request a pilot, or use our services (the “Service”).
If you use the Service through your employer or an agency relationship, your organization is typically the data controller and we may act as a processor/service provider for certain data (see “B2B customers and roles”).
1. Scope
This Privacy Policy applies to (a) our marketing website (including forms and pilot requests) and (b) the Service provided to business customers.
This policy does not cover third-party platforms you may access via links (for example, Meta/Facebook). Their privacy practices are governed by their own policies.
2. Data we collect
We collect personal data in three main ways: (1) data you provide, (2) data collected automatically when you use the website or Service, and (3) data provided by business customers (or their authorized users) when using the Service.
- Contact and business details: name, email, company, role, country, and any message you submit.
- Account and workspace data (Service): user identifiers, access scopes/permissions, and settings required to operate the Service.
- Service content (Service): URLs to ads/dark posts, comment templates, configuration rules, logs of published actions, and related metadata. Some workflows may also process screenshots or page captures to verify comment state.
- Technical and usage data: IP address, device information, browser type, pages viewed, approximate location (derived from IP), timestamps, and diagnostic logs.
- Communications: emails, support requests, and feedback you send us.
3. How we use data
- Provide and operate the website and Service, including pilot onboarding and customer support.
- Process requests you submit (for example, a 30-day pilot request).
- Maintain security, prevent fraud/abuse, and debug issues.
- Measure performance and improve the Service (for example, reliability and reporting).
- Comply with legal obligations and enforce our agreements.
4. Legal bases (EU/UK)
If EU/EEA or UK data protection laws apply, we rely on the following legal bases depending on context:
• Contract: to provide the Service or respond to your request before entering a contract.
• Legitimate interests: to secure, maintain, and improve our website and Service (for example, preventing abuse and ensuring reliability), balanced against your rights.
• Consent: for certain non-essential cookies or marketing communications where required.
• Legal obligation: to comply with applicable laws and lawful requests.
6. International transfers
We may transfer and process personal data outside your country (including outside the EU/EEA or UK). When we do, we use appropriate safeguards, such as Standard Contractual Clauses (EU SCCs) and, for the UK, the UK International Data Transfer Agreement (IDTA) or the UK Addendum, where applicable.
7. Data retention
We retain personal data only as long as necessary for the purposes described in this policy, including to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements.
Typical retention examples:
- Contact form data: retained as long as needed to respond and maintain a business record of the request.
- Service logs and operational records: retained based on customer configuration, contract terms, and reasonable operational needs.
8. Security
We use reasonable technical and organizational measures to protect personal data, including access controls, least-privilege practices, and monitoring for abuse.
No method of transmission or storage is 100% secure, so we cannot guarantee absolute security.
10. Your rights (EU/UK)
If EU/EEA or UK data protection laws apply, you may have rights including: access, rectification, deletion, restriction, portability, and objection. You may also withdraw consent at any time where processing is based on consent.
To exercise rights, contact us using the details in the Contact section. We may need to verify your identity before fulfilling requests.
11. Your rights (US)
Depending on your US state of residence, you may have rights to access, delete, correct, or obtain a copy of personal information we hold about you, and to opt out of certain types of processing (such as targeted advertising where applicable).
We do not sell personal information. If we engage in “sharing” for cross-context behavioral advertising as defined by certain laws, we will provide an opt-out mechanism.
- Right to know/access: request categories and specific pieces of personal information collected.
- Right to delete: request deletion of personal information (subject to exceptions).
- Right to correct: request correction of inaccurate personal information (where applicable).
- Right to opt out: opt out of sale/sharing or targeted advertising (where applicable).
- Non-discrimination: you will not receive discriminatory treatment for exercising privacy rights.
12. B2B customers and roles
If you use the Service as part of a business customer account (for example, an in-house marketing team or an agency), that organization is typically the controller of Service content and related personal data, and we act as a processor/service provider.
In that case, privacy requests about Service data should generally be directed to your organization first. We support our customers in responding to lawful requests as required by contract and applicable law.
13. Children
Our website and Service are not intended for children, and we do not knowingly collect personal information from children under 13 (or under 16 where applicable). If you believe a child has provided us personal data, contact us and we will take appropriate steps to delete it.
14. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and update the “Last updated” date.
If changes are material, we may provide additional notice as required by law.