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Contents

  1. 1. Who we are
  2. 2. Data we collect
  3. 3. Google API services data
  4. 4. Meta Platforms data (Facebook Login)
  5. 5. Why we process your data
  6. 6. Subprocessors and recipients
  7. 7. International data transfers
  8. 8. How long we keep your data
  9. 9. Your rights under GDPR
  10. 10. Cookies and tracking
  11. 11. SMS and messaging communications
  12. 12. How we protect your data
  13. 13. Changes to this policy
  14. 14. Contact and complaints
Privacy

Privacy Policy

Effective date: 7 September 2026

This Privacy Policy explains how The Brand Doers Media SRL ("LEADARO", "we", "us") collects, uses, stores and shares personal data when you use the LEADARO platform, our website at www.leadaro.ai, or any service that links to this policy. It is written to be readable by humans first; the legal basis and processing detail required by the General Data Protection Regulation (GDPR) sit beneath each section.

1. Who we are

The data controller for the LEADARO platform account data and for our website visitors is:

  • The Brand Doers Media SRL
  • Romanian Trade Register: J40/4451/2019 — VAT ID: RO40413030
  • Registered office: Aleea Adjud nr. 2, bl. F1, ap. 20, Bucharest, Romania
  • Contact email for privacy matters: office@thebrandoers.com

When you operate a LEADARO workspace, you are the data controller for the data you bring into the platform (your leads, conversations, bookings, integration credentials). LEADARO is the processor of that data on your behalf. A Data Processing Agreement ("DPA") is available on request.

2. Data we collect

We collect three categories of personal data:

  • Account data — your email, name, workspace name, role within the workspace, language preference, and authentication metadata. Provided by you when you sign up or are invited.
  • Workspace business data — the lead names, phone numbers, email addresses, conversation transcripts (WhatsApp, SMS, voice, chatbot, email), bookings, notes and pipeline state that you or your team enter into the platform, plus what is sent into the platform by your connected channels (Google Ads, Meta Ads, Twilio, etc.). This data belongs to your workspace; we only process it to operate the service.
  • Integration credentials — refresh tokens and configuration metadata for the third-party services you connect (Google Ads, Meta, WhatsApp Cloud, Postmark, MedSoft, etc.). Refresh tokens are encrypted with AES-256-GCM before being written to the database. Decrypted tokens never leave the server tier and are never sent to the browser.
  • Technical data — IP address, user-agent string, request timestamps and correlation identifiers. Collected automatically when you use the platform; used for security, abuse prevention, and operational debugging.

3. Google API services data

LEADARO's use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

When you connect a Google Ads account to your workspace, LEADARO requests the following Google OAuth scope:

  • https://www.googleapis.com/auth/adwords — access to your Google Ads account for lead form retrieval, campaign performance read, and conversion upload operations you authorize.

What we do with data received from Google APIs:

  • Import lead form submissions (lead_form_submission_data) you receive on connected campaigns, so that those leads land in your LEADARO inbox alongside leads from other channels.
  • Read campaign performance and lead-source attribution to power your reporting views.
  • Upload conversion events when you mark a LEADARO lead as converted, so that Google Ads can optimize bidding against real outcomes.
  • Manage campaigns only when you explicitly ask for it within the platform.

What we do NOT do with data received from Google APIs:

  • We do not transfer Google API data to third parties except as needed to provide and improve the user-facing features you've requested (and only to subprocessors listed below).
  • We do not use Google API data for serving advertisements of our own.
  • We do not allow humans to read Google API data except (a) with your prior explicit consent, (b) to comply with applicable law, (c) for security purposes, or (d) when the data has been aggregated and anonymized.
  • We do not use Google API data to develop, improve, or train generalized machine learning or AI models.

You can revoke LEADARO's access to your Google Ads account at any time from the Integrations page in your workspace settings, or directly from your Google Account permissions page. For the full per-scope disclosure, see our Google API disclosure page.

YouTube API Services data

When you connect a YouTube channel to your workspace, LEADARO requests the following Google OAuth scope:

  • https://www.googleapis.com/auth/youtube.upload — lets us upload to your YouTube channel the videos you approve within the platform.

What we do with data received from YouTube API Services:

  • We upload to your YouTube channel (videos.insert) only the videos you or your team have explicitly approved in the platform, together with their title and description and, when you choose one, their cover image (thumbnails.set, set on the video we have just uploaded).
  • After the upload completes we keep only the video ID returned by videos.insert, so the platform can show you the link. We do not read anything back from your channel: the integration makes no videos.list or other read call (write-only since 20 August 2026).

What we do NOT do with data received from YouTube API Services:

  • We do not read, modify, or delete any other content or data on your YouTube channel.
  • No upload happens without a human approval documented in the platform.
  • We do not use YouTube API Services data for advertising of our own or to train AI models.

LEADARO's use of information received from YouTube API Services complies with the YouTube API Services Terms of Service and the Google Privacy Policy.

You can revoke LEADARO's access to your YouTube channel at any time, in two ways: (1) using the Disconnect control in the dashboard where you connected the channel — this revokes the access at Google and deletes the stored token from LEADARO, not merely disables it locally; or (2) directly from your Google Account permissions page. Both have the same effect: LEADARO can no longer upload anything to your channel.

4. Meta Platforms data (Facebook Login)

When you connect Facebook, Instagram, Lead Ads or WhatsApp to your workspace, LEADARO uses Facebook Login for Business and asks Meta for the permissions listed below. LEADARO acts as a technology provider: it operates on your Pages, Instagram accounts, ad accounts and WhatsApp Business accounts only on your instructions, to deliver the features you enable. Data received from Meta is handled under the Meta Platform Terms and Developer Policies.

What we request and why:

  • Account identity (public_profile) — to identify the Meta account that authorizes the connection to your workspace.
  • Pages (pages_show_list, pages_read_engagement, pages_manage_metadata, pages_read_user_content, pages_manage_posts, pages_manage_engagement) — to list the Pages you manage, subscribe them to lead and message webhooks and, when you use the publishing tools, publish the posts and stories you approve, add the first comment you write for them, and read and reply to the comments on them.
  • Messaging (pages_messaging, instagram_basic, instagram_manage_messages, instagram_manage_comments) — to receive the messages and comments people send to your Page or Instagram account and to send the replies you or your virtual assistant write, including the first comment you write for a post you publish on Instagram.
  • Instagram publishing (instagram_content_publish) — to publish the content you approve to your Instagram professional account when you use the publishing tools.
  • Lead Ads (leads_retrieval, pages_manage_ads) — to retrieve the submissions of your lead forms as they arrive, so those leads land in your LEADARO inbox.
  • Ads and business assets (ads_management, ads_read, business_management) — to read the ad accounts and business assets you own, so the platform can attribute leads and send the conversion events you enable.
  • WhatsApp (whatsapp_business_management, whatsapp_business_messaging) — to register your WhatsApp Business number and send and receive WhatsApp messages on it.

What we do with data received from Meta:

  • Lead form submissions, messages and comments become records in your workspace (leads and conversations), processed only to operate the service for you.
  • Access tokens are encrypted at rest (AES-256-GCM), used only from our servers and never sent to the browser.
  • The engagement and advertising metrics you enable feed your own reporting views.

What we do NOT do with data received from Meta:

  • We do not sell Meta data, use it for advertising of our own, or use it to train AI models.
  • We do not read, post or message on your behalf outside the actions you configured in the platform.
  • We do not share Meta data with other workspaces or with third parties, except the subprocessors listed below that are needed to run the service.

You can revoke LEADARO's access at any time: from Integrations → Meta → Disconnect in your workspace (this deletes the stored tokens and the asset catalog), or from your Facebook account under Settings → Apps and websites. When you remove the app or request data deletion from Facebook, Meta calls our deauthorization and data-deletion endpoints and we disconnect everything tied to your account immediately; Facebook shows you a confirmation code and a link to our status page. Details are in the account and data deletion policy.

5. Why we process your data

We process personal data on the following GDPR legal bases:

  • Contract performance (Art. 6(1)(b) GDPR) — to provide the LEADARO platform under the agreement we have with your workspace. Account data and workspace business data are processed primarily on this basis.
  • Legitimate interest (Art. 6(1)(f) GDPR) — to operate, secure and improve the platform: technical logs, abuse prevention, system reliability, and aggregated usage analytics. We balance this interest against your rights and will not rely on it when your rights override.
  • Legal obligation (Art. 6(1)(c) GDPR) — to meet tax, accounting and other obligations under Romanian and EU law (for example, invoice retention).
  • Consent (Art. 6(1)(a) GDPR) — where applicable, for example before sending marketing emails to website contact-form submitters.

6. Subprocessors and recipients

We use the following subprocessors to operate LEADARO. Each is bound by a Data Processing Agreement and processes data only on documented instructions.

  • Supabase (database, authentication, storage) — Ireland (EU). Privacy policy.
  • Vercel (hosting, edge runtime, log drain) — United States, with EU edge routing. Privacy policy.
  • Postmark (transactional email) — European Economic Area routing. Privacy policy.
  • Better Stack (log management and alerting) — European data center. Privacy policy.
  • Anthropic PBC (Claude LLM inference for AI Brain features) — United States. Privacy policy. Data sent to Anthropic is processed under their DPA and is not used to train models.
  • OpenAI (GPT LLM inference for AI Brain features) — United States. Privacy policy. Data sent to OpenAI is processed under their DPA and is not used to train models.
  • Google LLC (voice AI — Gemini) — United States. Privacy policy.
  • Twilio (PSTN voice trunk and SMS in supported markets) — United States, with EU regional storage where available. Privacy policy.
  • Meta Platforms Ireland Ltd. (WhatsApp Cloud, Messenger, Instagram DM via Meta Cloud API) — Ireland (EU). Privacy policy.
  • Google Ireland Ltd. (Google Ads API for connected workspaces) — Ireland (EU). Privacy policy.
  • Google LLC / Google Ireland Ltd. (YouTube Data API for connected YouTube channels) — United States / Ireland (EU). Privacy policy.
  • Stripe Payments Europe Ltd. (billing, when commercial terms apply) — Ireland (EU). Privacy policy.

7. International data transfers

LEADARO's primary database and authentication tier run in the European Union. Some subprocessors (Vercel, Anthropic, OpenAI, Google, Twilio) operate from the United States. Where personal data is transferred outside the EEA, we rely on:

  • European Commission Standard Contractual Clauses (SCCs) signed with the subprocessor;
  • Supplementary measures including encryption in transit (TLS 1.2+) and at rest, plus minimization of data shared to what each subprocessor needs to operate;
  • Where applicable, the EU-US Data Privacy Framework for certified US providers.

8. How long we keep your data

  • Account data — for the lifetime of your account; deleted within 30 days of account closure unless we have a legal obligation to retain it longer.
  • Workspace business data (leads, conversations, bookings) — retained for the lifetime of the workspace (we do not auto-purge on a fixed schedule). Workspace owners may request deletion of specific records or the entire workspace data set in writing at any time; deletion completes within 30 days of the request.
  • Integration credentials — until the workspace owner disconnects the integration. Disconnecting clears tokens and configuration metadata.
  • Technical and security logs — 90 days, then aggregated or deleted.
  • Invoices and tax records — 10 years, as required by Romanian fiscal law.

9. Your rights under GDPR

You have the right to:

  • Access the personal data we hold about you.
  • Rectification of inaccurate personal data.
  • Erasure ("right to be forgotten") of your personal data, subject to legal-obligation exceptions.
  • Restriction of processing in certain circumstances.
  • Data portability — receive your data in a structured, commonly used, machine-readable format.
  • Object to processing based on legitimate interests.
  • Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, email office@thebrandoers.com from the address on file. We respond within 30 days. If you believe we have not handled your request appropriately, you have the right to lodge a complaint with the Romanian Data Protection Authority (ANSPDCP) at www.dataprotection.ro or with the supervisory authority in your EU country of residence.

10. Cookies and tracking

LEADARO uses only strictly necessary cookies on the public website (session identification, CSRF protection, locale preference). We do not run advertising cookies, third-party analytics cookies, or cross-site tracking on the public site. Inside the authenticated workspace, additional first-party cookies are used for Supabase session management.

11. SMS and messaging communications

In markets where SMS is available (currently the United States), a business that uses LEADARO may send text messages to its leads and customers through our telephony subprocessor, Twilio, from a phone number provisioned and verified for that business. Messages go only to people who gave that business their consent to be contacted at that number — for example by submitting a form on its website, starting a conversation, or booking an appointment. The business is the Data Controller for those messages; LEADARO is its processor.

  • What you may receive — appointment confirmations and reminders, replies to a conversation you started, follow-ups on a request you made and, only where you separately agreed to it, offers from that business. Message frequency varies with your interaction; a typical appointment cycle is 2–4 messages.
  • Opting out — reply STOP to any message to stop receiving texts from that business. You will get one final confirmation and nothing more. Reply HELP for help, or contact the business directly. Opt-outs are enforced at the telephony-provider level, so a number that replied STOP cannot be messaged again by that business through LEADARO unless it opts back in.
  • Costs — message and data rates may apply according to your mobile plan. Carriers are not liable for delayed or undelivered messages.
  • No sharing for marketing — mobile numbers and SMS consent collected through LEADARO are never sold, rented or shared with third parties or affiliates for their own marketing purposes. They are shared only with the subprocessors needed to deliver the message (Twilio) and with the business you consented to.

In Romania and in other markets where SMS is not enabled, the same rules apply to WhatsApp conversations: you can end the conversation or ask not to be contacted at any time, and the request is honored immediately.

12. How we protect your data

Encryption at rest for credentials (AES-256-GCM), TLS 1.2+ in transit, Row-Level Security policies enforced at the database tier, multi-tenant isolation verified at three layers (route handler membership check, RLS policy, per-workspace credentials), EU data residency by default, 24/7 alerting on operational logs. See our Security page for the full overview.

13. Changes to this policy

We may update this Privacy Policy as the platform evolves or as the law requires. Material changes are announced by email to workspace owners at least 14 days before they take effect. The effective date at the top of this page reflects the latest revision.

14. Contact and complaints

For any privacy question, data-subject request, or complaint, email office@thebrandoers.com. We acknowledge within 5 business days and respond substantively within 30 days. You can also write to us at The Brand Doers Media SRL, Aleea Adjud nr. 2, bl. F1, ap. 20, Bucharest, Romania.

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