Privacy Policy

Who we are

CueDM is operated by ATTECHY LTD, a company registered in England and Wales (company number 16498242) whose registered office is at 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom. For the data of people who sign up and use CueDM, we are the controller. For the data of your Instagram audience and your bio page visitors, you are the controller and we process it on your behalf, as described below. Privacy questions and requests go to support@cuedm.com.

Data about you, our customer

• Account: your email address, and your name and photo if you add them. We sign you in with a link sent by email, so we never hold a password.
• Workspace: its name, members and their roles, invitations, and an audit log of changes such as who connected or disconnected an account.
• Billing: your plan, billing interval, subscription status and the Stripe customer and subscription ids. Card details go to Stripe and never reach our servers.
• Usage: product events and session recordings from the signed-in app through PostHog, and error reports when something breaks.
• Where you came from: the campaign tags or referring site of your first visit and the page you landed on, if you arrived by a link that carried them and allowed the cookie, and your answer to “How did you hear about CueDM?” if you gave one.
• Anything you send to support@cuedm.com.

Instagram data we process for you

When you connect an Instagram professional account through Instagram’s own login screen, we store its id, username, profile details and an access token, which is encrypted at rest. We never ask for your Instagram password, scrape Instagram or drive it through a browser. To run your automations we then receive and store:

• Comments, story replies, story mentions, live comments and DMs that Instagram sends us for your account, with the sender’s Instagram-scoped id and username.
• A delivery log for each trigger: who it was, what they wrote, the keyword matched, and whether the DM was sent, skipped or failed.
• Contacts: each person who triggered an automation, with their username and any name, email, phone, tags or notes you or a form add, and counts of their interactions.
• Clicks on tracked links in your DMs, with a salted hash of the IP address, the browser’s user agent and the referrer.

The inbox reads conversations from Instagram when you open it; we do not keep a copy of your DM threads beyond what the delivery log records. We use this data only to provide CueDM to you, not for advertising and not to build profiles of your audience for anyone else.

Facebook Pages and Threads: publishing

You can also connect Facebook Pages and Threads profiles so CueDM can schedule and publish posts to them. Facebook Pages connect through Facebook’s own login screen, which lists the Pages you manage; we connect the ones you can post to. Threads connects through Threads’ own login screen. We never ask for your Facebook or Threads password.

• What we store. For each Page: its id, name, picture and a Page access token. For each Threads profile: its id, username, name, picture and an access token. Tokens are encrypted at rest. We do not keep your personal Facebook profile or friends list.
• What we do with it. We publish the posts you write or schedule to the Pages and profiles you chose, and read back each post’s link and, for a Facebook Page, its latest posts so we never publish the same post twice. The photos and videos you upload for a post are stored in our storage so that Facebook and Threads can fetch them. We use this only to provide CueDM to you.
• Permissions we ask for. Facebook: see your Pages (pages_show_list), publish to them (pages_manage_posts) and read their posts (pages_read_engagement) and add a comment you wrote as the Page, such as a first comment (pages_manage_engagement). Threads: read your profile (threads_basic) and publish (threads_content_publish).
• Ending access. Disconnecting a Page or profile in CueDM deletes its stored token at once. You can also remove CueDM in Facebook (Settings, then Business Integrations) or in Threads (Settings, then Account, then Website permissions). Posts already published stay on Facebook and Threads: delete them there.

The Page and profile details, and the posts you scheduled or published through them, stay in your workspace until you delete the workspace or ask us to delete them; see Data deletion.

Bio page visitors

When someone visits a bio page hosted on CueDM, the page’s owner is the controller of their data and we are the processor. We collect:

• Visits, counted by our own copy of Umami without cookies: the page, referrer, country, device type and browser. The IP address is used to count unique visitors and is not stored.
• Taps on the page’s links, with a salted hash of the IP address.
• What a visitor types into a form on the page: their email address, answers to the owner’s questions and, where they tick it, their consent to further email, with the wording they agreed to. Every email sent from a form carries a link to unsubscribe.

If you gave your details on someone’s bio page, ask that page’s owner first. If you cannot reach them, write to us and we will help.

AI apps you connect

You can connect an AI app such as Claude, ChatGPT or Cursor to your workspace. You sign in, pick the workspace and choose whether the app may only read or may also make changes. After that:

• The app can read what its tools return: your connected Instagram accounts, recent posts and captions, automations and their results, and your agents’ knowledge sources. With changes allowed, it can create and edit automations, turn them on or off, and add knowledge.
• We keep a record of the connection (the app’s name, who connected it and when it was last used) and which changes it made, so you can see them in the workspace.
• We do not receive your conversations with the app, only the tool calls it makes. What the app does with the data it reads is governed by its own provider’s privacy policy.
• Access lasts until you disconnect the app in Settings → Integrations → Connected AI apps, or it goes unused for 60 days.

CueDM Partners

Every CueDM user has a referral link, and people with an audience can apply to earn commission. If you take part:

• Your link. We log visits through it (a salted hash of the IP address, the browser, the referring site and the page landed on) and which accounts sign up and pay through it. A friend who arrives through your link sees your first name with their discount.
• What you see about referrals. Counts only: visits, sign-ups, paying customers and what you earned on each invoice. We never show you who they are.
• Applying to earn commission. We collect your full legal name, date of birth and country, or, if you join as a business, its registered name, country, company and VAT numbers, and the name and date of birth of the person running the partnership. We also keep the links to your audience, your note, and when you accepted the Partner Program Terms.
• Sanctions screening. UK law forbids paying anyone on the UK Sanctions List, so we check your name (and your business’s) against the list published by the UK Foreign, Commonwealth & Development Office when you apply, if your details change, and whenever the list is updated. Your date of birth is used only to tell you apart from a listed person with a similar name; it is encrypted and seen only by the people at CueDM who review applications. If a check suggests a real match, the law may require us to stop payments and report it to HM Treasury’s Office of Financial Sanctions Implementation.
• Getting paid. We keep your payout email (encrypted), every commission and payout, and the Wise transfer references. To pay you, we give Wise your name, payout email, country and the amount. Wise then asks you for your bank details directly; we never see them. Wise handles them under its own privacy policy.
• If you were referred. We record which partner’s link you signed up through and when you first paid, so your discount applies and the partner is credited. They never learn who you are.

Why we use it, and on what legal basis

• To provide the service you signed up for: sign-in, running automations, sending DMs, hosting bio pages, billing. Basis: performance of our contract with you.
• To keep the service secure and working: preventing duplicate sends, rate limiting, fixing errors, stopping abuse. Basis: our legitimate interests.
• To understand how the app is used and improve it, through product analytics and session recordings. Basis: our legitimate interests.
• To send you emails about your account: sign-in links, alerts about your connected accounts, billing notices and a weekly digest. Basis: contract, and legitimate interests for the digest, which you can turn off.
• To run CueDM Partners: tracking referrals, applying discounts, calculating and paying commission. Basis: performance of our contract with you, the Partner Program Terms.
• To screen partners against the UK Sanctions List, including using a date of birth to rule out people with similar names. Basis: legal obligation.
• To keep financial records and answer lawful requests. Basis: legal obligation.

For your audience’s data and your bio page visitors’ data, you decide the purpose and the legal basis, and we act only on your instructions.

Where data is kept, and who processes it

CueDM runs on one server we manage at Hetzner in Falkenstein, Germany. The database (PostgreSQL), the job queue (Redis) and our copy of Umami all run on that server. These providers process data for us:

• Hetzner Online (Germany): hosting.
• Cloudflare: DNS for cuedm.com, forwarding of mail to support@cuedm.com, and storage of hourly database backups (R2).
• Stripe: payments. Paid plans are sold through Onelink, run by Stripe through its affiliate Sold through Link, LLC, as merchant of record. It handles payment details, tax and invoices under the Onelink privacy policy.
• Resend: sending sign-in links, notifications and support replies.
• Wise: paying commission to CueDM partners. Wise collects a partner’s bank details itself and acts as its own controller for them.
• Sentry: error reports from our servers and the signed-in app.
• PostHog (EU cloud): product analytics and session recordings in the signed-in app only.
• Meta: Instagram, Facebook Page and Threads data flows between CueDM and Meta’s Instagram, Graph and Threads APIs, which is how the service works. Meta’s own terms and policies apply to what it holds.

International transfers

Our servers are in the EU, which the UK recognises as adequate. Some of the providers above are based in, or may access data from, the United States. Where personal data leaves the UK or EEA, we rely on an adequacy decision (including the UK Extension to the EU-US Data Privacy Framework where the provider is certified) or on standard contractual clauses with the UK addendum.

Cookies

Bio pages set no cookies. Neither site carries advertising scripts, and visits to both are counted by our own copy of Umami without cookies. If you arrive on the marketing site from a link that names a source, a small box asks whether we may keep one cookie:

• A source cookie, set only if you choose Allow and kept for 90 days, holding the campaign tags in the link you followed or the site that sent you, and the page you landed on. Nothing in it identifies you. If you sign up, it is saved with your account so we know which channels bring customers. Basis: your consent.
• If you arrived through a CueDM partner’s link, a cookie holding that partner’s code, set only if you choose Allow and kept for 90 days, so the referral counts if you come back later. Without it, the code is carried only in the page address for that visit. Basis: your consent.
• A cookie remembering your answer, Allow or No thanks, for six months, so we do not ask again. Change it any time with “Cookie choice” at the bottom of every page; choosing No thanks deletes the source and partner cookies.

In the signed-in app we use:

• A session cookie that keeps you signed in.
• A signed-in hint, so the marketing site can show “Open app” instead of “Sign in”, and a short-lived cookie holding the email you are signing in with.
• Preference cookies for the workspace and Instagram account you last chose, and whether the sidebar is open.
• PostHog’s cookie and local storage, which tie product events and session recordings in the app to one visit. Recordings mask every text field and the audience data on screen, such as commenters’ handles and message text.

How long we keep it

• Raw webhook payloads from Instagram: 90 days. Operational logs and outgoing webhook deliveries: 30 days. Both are deleted automatically every day.
• Delivery logs, contacts, link clicks and bio page data: for as long as the Instagram account or bio page stays in your workspace. Deleting the workspace deletes them at once. Disconnecting an Instagram account deletes its access token at once and its automations, delivery log and Instagram contacts 30 days later, so a reconnect within that time restores them; you can also delete them straight away from the account’s settings. Bio page signups belong to the bio page and are not affected.
• Your account: until you ask us to delete it. See Data deletion.
• Backups: hourly database copies are kept for 7 days on the server and 30 days in Cloudflare R2, so deleted data is gone from every backup within 30 days.
• Billing records: as long as UK tax and company law requires, usually six years.
• CueDM Partners: commission, payout and screening records for six years after the last payout, as financial and sanctions records. A declined applicant’s date of birth is deleted as soon as the application is declined; the rest of the application is kept so we can answer if you apply again, and deleted when you ask. Visits through partner links are kept with the partner’s numbers.

Your rights

Under UK and EU data protection law you can ask for a copy of your data, have it corrected or deleted, restrict or object to how we use it, and receive it in a portable format. Where we rely on consent, you can withdraw it at any time. Email support@cuedm.com from the address on your account; we may ask you to confirm it is you, and we reply within one month. If your request is about a CueDM customer’s audience or bio page, we pass it to that customer and help them answer it.

You can also complain to the UK Information Commissioner’s Office (ico.org.uk) or to your local data protection authority, though we would like the chance to put it right first.

Security

Instagram, Facebook Page and Threads access tokens and provider credentials are encrypted before they are stored. All traffic is over HTTPS, the database and queue are reachable only from inside our server, and access to the server is limited to the people who run CueDM.

Children

CueDM is a business tool and is not meant for anyone under 18. We do not knowingly collect data from children. If you think a child has signed up, tell us and we will delete the account.

Changes to this policy

When we change this policy we update the date at the top. If a change matters to how your data is used, we will also email the address on your account before it takes effect.