Privacy Policy.

Last updated: 31 July 2025

EquaTalent FZ-LLC ("EquaTalent," "we," "us") provides Comment Shield, a software-as-a-service tool that connects to your Facebook Pages and Instagram Business Accounts to detect and remove spam comments in real time and to notify you of the actions taken. Protecting your privacy—and the privacy of people who interact with your social accounts—is central to our mission. This Privacy Policy explains how we collect, use, disclose and safeguard information when you use Comment Shield (collectively, the "Service").

1. Who is the Data Controller?

EquaTalent FZ-LLC
Dubai Internet City, in5 Tech Building
Dubai, United Arab Emirates
Email: tech@equatalent.com

2. Scope of this Policy

This Policy applies to personal data we process when you:

Authorise Comment Shield to access your Facebook Page(s) or Instagram Business Account(s) via Facebook Login (Meta OAuth);
Use our web dashboard or mobile widgets to view moderation activity; or
Communicate with us by email, support chat or social media.

3. Information We Collect

Category	Source	Typical fields
Account Data	You / Facebook Login	Name, profile picture, email, Facebook User ID/Page ID, Instagram Business Account ID, OAuth access tokens
Comment Data	Facebook & Instagram Graph API	Comment ID, parent Post ID, commenter User ID, comment text, timestamp, language code
Moderation Logs	Generated by our Service	Flag (spam/clean), deletion timestamp, notification status
Usage Data	Your browser/device	IP address, user-agent, pages visited, actions taken within dashboard

We do not request or receive your Facebook or Instagram password.

4. How & Why We Use Your Information

Purpose	Details	Legal Basis (GDPR)
Provide and secure the Service	Authenticate you via Facebook Login; fetch recent comments; run spam-detection algorithms; delete spam comments through the API; send in-app and email notifications	Performance of a contract; legitimate interests
Improve spam-detection models	Store de-identified comment snippets to retrain and evaluate classifiers	Legitimate interests
Analytics & troubleshooting	Aggregate usage statistics, crash reports and performance metrics	Legitimate interests
Marketing (optional)	Send product updates or offers	Consent
Legal compliance	Keep audit records of moderation actions required by law	Legal obligation

5. How We Share Information

We never sell personal data. We disclose it only:

Service Providers (cloud hosting, e-mail delivery, security monitoring) bound by data-processing agreements;
Meta Platforms, Inc. via the Graph API when issuing deletion commands or fetching complaint/appeal statuses;
Authorities or third parties where disclosure is required by law or to protect safety, rights or property; and
Corporate transactions (e.g. merger, acquisition), subject to confidentiality safeguards.

6. Facebook & Instagram Platform Data Handling

We access Meta Platform Data under the permissions pages_manage_metadata, pages_manage_engagement and instagram_manage_comments.

Use – strictly to detect, delete or hide spam comments and to display results to you.
Retention – raw comment text is cached for a maximum of 30 days. Moderation logs (comment ID and spam flag) are stored for up to 12 months for audit and model-training purposes.
Sharing – we do not share Meta Platform Data with any third party.
Deletion – you may revoke our access at any time via your Facebook settings > Business Integrations or request deletion (see Section 7).

We comply with the Meta Platform Terms and Developer Policies and never use Meta Platform Data to build user profiles for advertising.

7. Your Rights & Data-Deletion Requests

Depending on your jurisdiction you may have rights to access, correct, delete or restrict processing of your personal data.

7.1 Revoke Access / Delete Meta Data

Revoke Comment Shield in Facebook > Settings & Privacy > Security > Business Integrations; or
Request deletion by emailing tech@equatalent.com with the subject "Delete Comment Shield Data"; or
Use our self-service endpoint: https://equatalent.com/data-deletion?user_id={Your Facebook User ID}

We will erase associated Meta Platform Data within 30 days and confirm completion.

8. Data Retention

Comment text older than 30 days is purged.
Moderation logs are anonymised after 12 months.
Account Data is kept until you delete your Comment Shield account or revoke Facebook access, whichever comes first.

9. International Transfers

Our servers are located in the European Union (Frankfurt) and United States. Where we transfer data outside the EEA we rely on standard contractual clauses or adequacy decisions.

10. Security

We protect data using encryption (TLS 1.3), least-privilege access controls, periodic penetration tests and ISO 27001-certified cloud infrastructure. No system is perfectly secure, but we continuously work to keep your information safe.

11. Cookies & Similar Technologies

Our dashboard uses first-party cookies solely for session management. No advertising or cross-site tracking cookies are set.

12. Children’s Privacy

Comment Shield is not intended for children under 16. We do not knowingly collect data from minors. Please contact us if you believe we have inadvertently done so.

13. Changes to This Policy

We may update this Policy to reflect legal or technical changes. We will notify you by email or in-app banner at least 14 days before material changes take effect.

14. Contact Us

Questions or concerns? Contact our Data Protection Officer (DPO):

Email: tech@equatalent.com
Postal: EquaTalent FZ-LLC, Dubai Internet City, Building XYZ, Dubai, UAE