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Legal

Privacy Policy

Last updated: June 2026  ·  Effective date: June 2026

Contents
  1. Who We Are
  2. Data We Collect
  3. How We Use Your Data
  4. Third-Party Services
  5. Meta / Facebook & Instagram
  6. AI-Assisted Services
  7. Cookies & Browser Storage
  8. Data Retention
  9. Your Rights
  10. Data Security
  11. Children's Privacy
  12. Changes to This Policy
  13. Contact Us

1. Who We Are

Devy Agency ("Devy", "we", "us", "our") is a social media management and digital marketing agency based in Auckland, New Zealand. We operate the website at devyagency.com and a client management platform used to deliver our services.

This Privacy Policy explains how we collect, use, share, and protect personal information when you interact with our website, contact form, or client platform. It applies to prospective clients, active clients, and authorised users of our systems.

By using our services you agree to the practices described in this policy. If you do not agree, please do not use our services.

2. Data We Collect

2.1 Information you provide directly

  • Full name and contact name
  • Email address
  • Phone number (including country code)
  • Business / brand name and industry
  • Social media platform preferences
  • Description of your marketing challenges (free-text fields)
  • Login credentials (stored securely, never in plain text)
  • Billing contact and address details

2.2 Information from connected social accounts

When you connect your Instagram or Facebook account to our platform, we access:

  • Profile information (username, display name, biography, profile picture)
  • Follower and following counts, media count
  • Post content, captions, media, and engagement metrics
  • Audience analytics (reach, impressions, follower growth, demographics by age, gender, country, and city)
  • Page and account identifiers required for publishing
  • Access credentials used to publish content on your behalf

2.3 Information generated through our services

  • Content created on your behalf (captions, briefs, revision notes)
  • Invoice and payment records
  • Meeting notes and strategy session records
  • Advertising spend records per platform
  • AI-assisted conversation and content history
  • Brand strategy profiles (brand voice, content pillars, target audience)

2.4 Automatically collected information

  • Browser and device type
  • IP address (logged by our hosting infrastructure)
  • Pages visited and basic interaction data on our website

3. How We Use Your Data

PurposeLegal basis
Responding to enquiries and delivering the free brand auditLegitimate interest / pre-contractual steps
Delivering social media management and content creation servicesPerformance of contract
Sending invoices and processing paymentsPerformance of contract
Publishing content to your social accounts on your behalfPerformance of contract
AI-assisted content creation and brand auditsPerformance of contract
Sending transactional emails (invoices, account invitations, password resets)Performance of contract
Analytics and performance reportingPerformance of contract
Improving our services (aggregated, anonymised data only)Legitimate interest

We do not sell your personal data to third parties. We do not use your data for unsolicited marketing without your consent.

4. Third-Party Services

We share data with trusted third-party service providers strictly as needed to operate our services. These providers are contractually required to handle data in accordance with applicable privacy laws.

CategoryPurposeData shared
Cloud database & hostingSecure storage of all account and client dataUser accounts, client profiles, content, billing records
Website hostingServing our website and processing form submissionsForm submissions, IP addresses
Payment processing (Stripe)Credit and debit card paymentsPayment amount, email. Card details never touch our servers
Payment processing (PayPal)Alternative payment methodPayment amount, invoice reference
Email deliverySending transactional emailsName, email address, email content
AI content generationAssisting with content creation and brand auditsBrand profile, content context (see Section 6)
Meta (Facebook / Instagram)Social media publishing and analyticsAccount connections, post content (see Section 5)

We do not use advertising networks or data brokers. We do not share your data with any party not listed above without your explicit consent.

5. Meta / Facebook & Instagram

Our platform integrates with the Meta Graph API to manage Instagram and Facebook content for our clients. When you authorise Devy Agency to connect to your Meta account, we request the following permissions:

  • instagram_basic: read your profile information and media
  • instagram_content_publish: publish content to your Instagram account on your behalf
  • pages_manage_posts: manage posts on your connected Facebook Page
  • pages_read_engagement: read engagement metrics from your Facebook Page

Data retrieved from Meta is used solely to manage your accounts and generate performance reports. It is not shared with any other party or used for advertising purposes beyond managing your campaigns.

You can revoke Devy Agency's access at any time via your Facebook App Settings.

Devy Agency complies with the Meta Platform Terms and Meta Developer Policies.

6. AI-Assisted Services

We use AI tools to assist our team with content creation, brand strategy, and account management. When our team uses these features on your behalf:

  • Your brand profile (brand voice, content pillars, target audience) may be included as context
  • Content drafts and conversation history may be processed to generate relevant outputs
  • During brand audits, publicly accessible content from your website may be reviewed

All AI-generated content is reviewed and approved by our team before delivery or publication. We do not represent AI-generated output as fact without verification.

By engaging our services, you consent to your brand information being used as context in AI-assisted workflows.

7. Cookies & Browser Storage

Our marketing website (devyagency.com) does not use tracking cookies or analytics tools. Standard browser caching may occur via our hosting CDN.

Our client platform uses browser local storage to maintain your session, remember your display preferences, and temporarily cache performance data to reduce unnecessary network requests. This data is stored on your device only and is cleared when you log out or clear your browser data.

Cookie categories

  • Strictly necessary: Session data required to keep you logged in and operate the platform. Cannot be disabled.
  • Functional: Display preferences (e.g. theme) and cached analytics data to improve performance. Can be cleared manually via browser settings.
  • Third-party: The Meta Facebook SDK may set cookies during the Instagram/Facebook authorisation flow. These are governed by Meta's Privacy Policy.

We do not use advertising cookies, Google Analytics, or any behavioural tracking on our marketing website.

8. Data Retention

We retain personal data for as long as necessary to deliver our services and comply with legal obligations:

  • Active client data: Retained for the duration of the contract and 3 years after termination
  • Invoice and billing records: 7 years (New Zealand Inland Revenue requirement)
  • Enquiry form submissions: 12 months, then deleted unless a contract is formed
  • AI-assisted content history: Retained while you are an active client; deleted on written request
  • Social account connections: Deleted when you disconnect your account or terminate the contract

To request early deletion of your data, visit our Data Deletion page.

9. Your Rights

Under the New Zealand Privacy Act 2020 and, where applicable, the EU General Data Protection Regulation (GDPR), you have the right to:

  • Access a copy of the personal data we hold about you
  • Correct inaccurate or incomplete data
  • Delete your personal data (subject to legal retention requirements)
  • Portability: receive your data in a machine-readable format
  • Object to processing based on legitimate interests
  • Restrict processing of your data in certain circumstances
  • Withdraw consent at any time where processing is based on consent

To exercise any of these rights, email contact@devyagency.com or use our Data Deletion Request form. We will respond within 20 working days.

If you are unsatisfied with our response, you may contact the Office of the Privacy Commissioner (NZ) or your local data protection authority.

10. Data Security

We take reasonable technical and organisational measures to protect your personal data, including:

  • All data is transmitted over encrypted connections (HTTPS)
  • Passwords are never stored in plain text
  • All data is hosted with reputable cloud providers using encryption at rest
  • Credit card details are handled exclusively by our PCI-compliant payment processor and never touch our servers
  • Access credentials and API keys are stored securely and never exposed publicly

Despite these measures, no system is completely secure. In the event of a data breach that poses a risk to your rights, we will notify you and the relevant authority in accordance with applicable law.

11. Children's Privacy

Our services are intended for business use and are not directed at individuals under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us immediately at contact@devyagency.com.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify active clients of material changes by email. The "Last updated" date at the top reflects the most recent revision. Continued use of our services after changes take effect constitutes acceptance.

13. Contact Us

For any privacy-related questions, requests, or concerns:

Devy Agency
Auckland, New Zealand
Email: contact@devyagency.com
Instagram: @devyagencynz

For data deletion requests, visit our Data Deletion page.

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