This policy explains how Pheme Growth Ltd ("Pheme Growth", "we", "us"), a marketing agency based in Larnaca, Cyprus, collects and uses personal data. It covers this website and the tools we use to manage social media and advertising for our clients, including our app on the Meta platform (Facebook and Instagram).
Who is responsible
Pheme Growth Ltd, Larnaca, Cyprus. Contact: david@phemegrowth.com or george@phemegrowth.com.
When we manage a client's Facebook Page or Instagram account, the client is the controller of the data on its own Page. We process that data on the client's behalf and on its instructions.
This website
- The site has no contact forms, no analytics and no advertising cookies.
- When you contact us by WhatsApp or email, we receive the details you send (name, phone or email, your message) and use them only to answer you.
- The fonts on this site are loaded from Google Fonts, so your browser connects to Google's servers, which see your IP address. See Google's privacy policy.
Data we handle for our clients
- Comments on the Facebook and Instagram posts and ads of the Pages we manage: the commenter's name or username, the comment and its time.
- Messages sent to those Facebook Pages and Instagram accounts: the sender's Page-scoped ID, name or username, the message and its time.
- Leads from our clients' advertising: the details people submit in lead forms (for example name, phone, email and answers), which are passed to the client.
How we use it
- To reply to comments and messages on behalf of our clients, to hide spam or abusive comments, and to pass enquiries to the right person at the client.
- To deliver and measure our clients' advertising and to pass leads to them.
- To answer your own enquiries to Pheme Growth.
A person at Pheme Growth reviews every reply before it is sent. We do not sell personal data, we do not use it for our own advertising, and we do not combine it across clients.
Legal basis
We process this data to perform our contracts with our clients, in our clients' legitimate interest in answering the people who contact them, and to answer your own enquiries. Where the law requires consent, we rely on it.
Who we share it with
Only with the client whose Page or ad the data relates to, with Meta Platforms (which provides Facebook and Instagram), and with the service providers we use to run our tools (hosting and software), who are bound to keep it confidential. We share it with no one else unless the law requires it.
How long we keep it
Comments and messages stay on Facebook and Instagram under Meta's own policies. The copies our tools keep for daily reports are deleted after 90 days. Lead details are kept for as long as our client needs them for the enquiry, and no longer than 24 months. Emails and WhatsApp messages to us are kept for as long as we work together, or as long as the law requires.
Your rights
Under the GDPR you can ask for access to your data, correction, deletion, restriction or a copy, and you can object to processing. Write to david@phemegrowth.com. You can also complain to the Office of the Commissioner for Personal Data Protection in Cyprus (dataprotection.gov.cy).
Data deletion
To have the data we hold about you deleted, including anything received through our Meta app, email david@phemegrowth.com with the subject "Data deletion" and the name or username you used on Facebook or Instagram. We delete it within 30 days and confirm by email. You can also remove our app's access at any time in your Facebook settings, under "Apps and websites".
Changes
We will update this page if anything changes. The date at the top shows the latest version.