AdFlow is a software-as-a-service platform developed and operated by Agent Growth Hub Inc., a corporation incorporated under the laws of Ontario, Canada.
In this Privacy Policy, "AdFlow," "we," "us," and "our" refer to Agent Growth Hub Inc. and its AdFlow platform, accessible at ads-manager.agentgrowthhub.ai.
Agent Growth Hub Inc. is the data controller for personal data processed through the AdFlow platform. For the purposes of Canadian law (PIPEDA), Agent Growth Hub Inc. is the organization responsible for personal information under its control.
Contact Information:
Agent Growth Hub Inc.
Toronto, Ontario, Canada
Email: privacy@agentgrowthhub.ai
This Privacy Policy applies to:
This policy does not apply to:
Important — Your Responsibilities as a Subscriber: When you use AdFlow to collect leads through Meta Instant Forms, you are acting as the data controller for those leads. The lead respondents are your prospective clients. You are responsible for complying with applicable privacy laws in your jurisdiction regarding how you collect, use, and store that personal information. AdFlow processes that data as your data processor.
When you create an AdFlow account, we collect:
To connect your Meta advertising account to AdFlow, we collect and store:
These credentials are stored encrypted in our database and are used exclusively to operate AdFlow's features on your behalf. They are never shared with any third party except as required to operate the platform as described in Section 7.
Through your connected Meta account, AdFlow retrieves and stores:
When you use the AdFlow Leads Dashboard, we retrieve and store lead submission data from your Meta Instant Forms, including:
This data is stored in our database associated with your tenant account and is accessible only to you. It is never used for any purpose other than displaying it to you within your AdFlow dashboard.
When you use AdFlow's Copy Builder or AI Optimizer features, we send campaign brief text and campaign performance data to our AI processing providers (Anthropic). We do not send lead respondent personal information (names, emails, phone numbers) to any AI provider.
We automatically collect certain technical data when you use AdFlow:
If you contact us by email or through support channels, we retain records of that correspondence including your name, email address, and the content of your communications.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Providing and operating the AdFlow platform | Account data, Meta credentials, advertising data | Contract performance |
| Displaying your campaign analytics and performance data | Meta advertising data, insights | Contract performance |
| Displaying lead submissions in your Leads Dashboard | Lead submission data | Contract performance |
| Generating AI-powered ad copy via Copy Builder | Campaign brief text, performance metrics | Contract performance |
| Generating AI optimization recommendations | Campaign performance data (no personal lead data) | Contract performance |
| Creating and managing Meta campaigns and lead forms on your behalf | Meta credentials, campaign configuration data | Contract performance |
| Generating ad creatives via AI image/video tools | Image generation prompts | Contract performance |
| Account authentication and security | Email, password hash, session data | Contract performance / Legitimate interest |
| Billing and subscription management | Account data, payment data (via Stripe) | Contract performance / Legal obligation |
| Customer support and communications | Account data, support correspondence | Legitimate interest |
| Platform security and fraud prevention | Technical/usage data | Legitimate interest |
| Legal compliance and regulatory obligations | Any relevant data | Legal obligation |
| Improving AdFlow's features and performance | Aggregated, anonymized usage data only | Legitimate interest |
We will never: sell your data, share it with advertisers, use it for behavioral advertising, use lead respondent personal information for any purpose other than displaying it to you, or use your Meta advertising data to benefit any party other than you.
AdFlow integrates with Meta's Marketing API and is subject to Meta's Platform Terms. This section specifically addresses how we handle data obtained from Meta's platform.
"Meta Platform Data" means any information, data, or other content that we obtain from Meta through the Platform or through our app, whether directly or indirectly, including data anonymized, aggregated, or derived from such data. This includes Meta user IDs, access tokens, ad account data, and lead submission data.
We use Meta Platform Data exclusively to:
We do not and will not use Meta Platform Data to:
Your Meta System User Access Token is stored encrypted in our database. It is transmitted only over HTTPS. It is used only to make API calls explicitly authorized by your use of AdFlow. If you terminate your AdFlow account, your access token is deleted from our systems within 30 days.
You may request deletion of all Meta Platform Data associated with your account at any time. See Section 10 for how to submit a deletion request. We will complete deletion within 30 days and confirm in writing.
By using AdFlow's lead retrieval features, you confirm that you have accepted Meta's Lead Ads Terms of Service for your connected Facebook Page. You are responsible for complying with those terms in your use of lead data retrieved through AdFlow.
For users in jurisdictions that require a legal basis for processing personal data (including the European Economic Area and the United Kingdom), we rely on the following legal bases:
We do not sell personal data. We share data only as necessary to operate AdFlow, as described below.
| Processor | Purpose | Data Shared | Location |
|---|---|---|---|
| Railway (Railway Corp.) | Cloud infrastructure, application hosting, and database hosting | All application data including account data, Meta credentials (encrypted), advertising data, and lead submissions | United States |
| Anthropic PBC | AI language model processing for Copy Builder and AI Optimizer features | Campaign brief text and campaign performance metrics only. No lead respondent personal data (names, emails, phones) is ever sent to Anthropic. | United States |
| Kie.ai | AI image and video generation for Creative Studio feature | Image generation prompts and uploaded images. No personal data or Meta Platform Data. | India |
| Stripe Inc. | Payment processing and subscription billing | Account email, billing information. Stripe processes payment card data directly — AdFlow never stores payment card numbers. | United States |
| Cloudflare R2 | Cloud object storage for generated ad creatives and uploaded media | Ad creative images and videos generated or uploaded by you. No personal data. | United States |
| Meta Platforms Inc. | Marketing API — AdFlow makes API calls to Meta on your behalf to retrieve and manage your advertising data | Your Meta access token and ad account credentials (used only to execute your requested actions) | United States |
We may disclose personal information if required by law or in good faith belief that such disclosure is necessary to:
We will notify affected users of any such disclosure to the extent permitted by law and will minimize the scope of any disclosure to the minimum information legally required.
In the event of a merger, acquisition, asset sale, or other corporate transaction involving Agent Growth Hub Inc., personal data may be transferred as part of that transaction. We will provide notice prior to any such transfer and will require the acquiring entity to honor this Privacy Policy or provide equivalent protections.
| Data Category | Retention Period | Basis |
|---|---|---|
| Account information (name, email) | Duration of account + 90 days after termination | Contract / Legal obligation |
| Meta access tokens and credentials | Duration of account + 30 days after termination | Contract performance |
| Campaign performance data and insights | Duration of account + 90 days after termination | Contract performance |
| Lead submission data (names, emails, phones) | Duration of account + 90 days after termination, OR upon your explicit deletion request (whichever is earlier) | Contract performance |
| Generated ad creatives (images/videos) | Duration of account + 30 days after termination | Contract performance |
| Billing and payment records | 7 years from transaction date | Legal obligation (tax law) |
| Support correspondence | 3 years from last interaction | Legitimate interest |
| Security and access logs | 12 months | Legitimate interest |
| Aggregated, anonymized analytics | Indefinitely (no personal data retained) | Legitimate interest |
Upon account termination, we will delete or anonymize all personal data within the timeframes above, except where longer retention is required by applicable law.
We implement industry-standard technical and organizational security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction.
No method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security. In the event of a data breach affecting your personal information, we will notify you as described in Section 15.
Depending on your jurisdiction, you may have the following rights regarding your personal data:
Submit all privacy requests to: privacy@agentgrowthhub.ai
Include in your request: your full name, the email address associated with your AdFlow account, and a description of your request. We will respond within 30 days for standard requests. Complex requests may require up to 60 days, and we will notify you if additional time is needed.
We may need to verify your identity before processing your request. We will not charge a fee for reasonable requests.
You may request full account deletion, which will result in the deletion of your account, Meta credentials, advertising data, and lead submissions (subject to our legal retention obligations for billing records). Email privacy@agentgrowthhub.ai to initiate account deletion.
Agent Growth Hub Inc. is a Canadian corporation and complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
Under PIPEDA, we are committed to the following ten privacy principles:
If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) or equivalent legislation may apply to our processing of your personal data.
Agent Growth Hub Inc. acts as the data controller for your account and profile data. For lead submission data retrieved from your Meta campaigns, Agent Growth Hub Inc. acts as your data processor — you are the data controller for your leads, and by using AdFlow you are directing us to process that data on your behalf.
Your personal data may be transferred to and processed in countries outside the EEA, including the United States and Canada. Canada has been recognized by the European Commission as providing an adequate level of data protection for commercial organizations subject to PIPEDA. For transfers to the United States (Railway, Anthropic, Stripe, Cloudflare), we rely on Standard Contractual Clauses or equivalent safeguards as required.
We have not designated a formal Data Protection Officer as we do not meet the thresholds requiring mandatory DPO appointment. Privacy inquiries should be directed to privacy@agentgrowthhub.ai.
EEA users have the right to lodge a complaint with their local supervisory authority. A list of EU data protection authorities is available at edpb.europa.eu. UK users may contact the Information Commissioner's Office at ico.org.uk.
AdFlow is a business-to-business SaaS platform intended exclusively for use by real estate professionals and business operators. AdFlow is not directed at individuals under the age of 18, and we do not knowingly collect personal information from minors.
If we become aware that we have inadvertently collected personal information from a minor, we will delete that information promptly. If you believe we may have collected information from a minor, please contact us at privacy@agentgrowthhub.ai.
AdFlow uses minimal cookies and tracking technologies necessary to operate the platform.
We use a session cookie (adflow_session) to maintain your authenticated session. This cookie is required for AdFlow to function and cannot be disabled while using the platform. It expires at the end of your session or when you sign out.
AdFlow does not use advertising cookies, tracking pixels, or behavioral targeting technologies. We do not share usage data with advertising networks.
We may use aggregated, anonymized server-side analytics to understand how AdFlow is used and to improve its features. This does not involve client-side tracking technologies beyond the essential session cookie.
In the event of a data breach that poses a real risk of significant harm to individuals, we will:
Breach notifications will be sent to the email address associated with your AdFlow account. It is your responsibility to keep your contact information current.
Agent Growth Hub Inc. is based in Canada. AdFlow's infrastructure operates primarily in the United States (Railway, Cloudflare R2, Stripe, Anthropic) and India (Kie.ai). By using AdFlow, you acknowledge that your data will be transferred to and processed in these jurisdictions.
We take steps to ensure that international transfers comply with applicable privacy law, including ensuring that our sub-processors maintain appropriate data protection standards. For EU/EEA users, see Section 12 for additional information on international transfer mechanisms.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
Your continued use of AdFlow after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the changes, you must discontinue use of AdFlow and may request account deletion as described in Section 10.4.
For material changes that involve new uses of personal data you have already provided, we will seek your affirmative consent where required by applicable law.
For any privacy-related questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us:
Agent Growth Hub Inc. — Privacy Office
Email: privacy@agentgrowthhub.ai
Subject line: "AdFlow Privacy Request — [Your Name]"
Response time: Within 30 days of receipt
For complaints regarding our PIPEDA compliance that we have not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca