Integrity AI Pty Ltd (ABN 71 682 960 970, ACN 682 960 970) ("we", "us", "our") operates The Tiny but Mighty Marketing Club, a SaaS platform that uses artificial intelligence to create and publish social media content on behalf of users (the "Platform"). In providing the Platform, we access and process personal information through integrations with Meta platforms (including Facebook and Instagram), TikTok, and LinkedIn.
This Data Deletion Policy explains how we handle requests to delete personal information, how we fulfil our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and how we comply with the data deletion requirements of Meta's Platform Terms, TikTok's Developer Terms of Service, and LinkedIn's Developer Terms of Service.
This Policy should be read alongside our Privacy Policy.
Scope
This Policy applies to all personal information we hold about:
- registered users of the Platform ("Users");
- individuals whose personal information is processed through the Platform in connection with social media account management; and
- any other individuals whose personal information we collect in the course of providing the Platform.
This Policy applies to personal information held in any form, including data stored in our systems, databases, backups, logs, and data held by third-party sub-processors on our behalf.
Types of data we hold
In providing the Platform, we may hold the following categories of personal information:
- Account data: name, email address, business name, and account credentials;
- Social media access data: OAuth tokens, page IDs, account identifiers and permissions that a User expressly authorises us to access when the User connects their Facebook, Instagram, TikTok or LinkedIn account to the Platform. By connecting an account, the User authorises us to receive, store and use that access data only as necessary to provide the Platform, including to create, schedule and publish content on the User's behalf;
- Content data: social media posts, captions, images, videos, and scheduling instructions created or uploaded by Users;
- Usage data: log files, IP addresses, session data, and analytics relating to Platform use;
- AI-generated content data: inputs provided to the AI model (including Anthropic Claude) and outputs generated on behalf of Users; and
- Third-party platform data: any personal information received from Meta, TikTok or LinkedIn APIs in connection with a User's connected accounts, including audience data, engagement metrics, and profile information, to the extent permitted by the relevant platform's terms.
Legal basis for deletion obligations
- Under APP 11.2 of the Privacy Act 1988 (Cth), we are required to take reasonable steps to destroy or de-identify personal information we hold once it is no longer needed for any purpose for which it may be used or disclosed under the APPs.
- Under Meta's Platform Terms, we are required to delete all personal information received from Meta's APIs if a User requests deletion, unless retention is required by law, regulation, or a separate agreement with Meta.
- Under TikTok's Developer Terms of Service and Data Sharing Agreement, we are required to delete User data obtained through TikTok's APIs upon a User's request and to provide a mechanism by which Users can request such deletion.
- Where we act as a data processor on behalf of a User (for example, where a User is a business that has provided us with their customers' data), we will also comply with any deletion instructions from that User in our capacity as processor.
User deletion requests
How to submit a request. Users may submit a data deletion request by:
- emailing us at hello@tbmmc.com.au; or
- writing to us at PO Box 5369, West End, QLD 4101, Australia.
Verification. We may ask you to verify your identity before processing a deletion request. This is to protect against unauthorised deletion of another person's data.
Response timeframe. We will acknowledge your request within 5 business days and complete the deletion (or provide a written explanation of any exception) within 30 days of receiving a verified request.
Scope of deletion. Upon receiving a verified deletion request, we will delete or de-identify:
- your account data and profile information;
- social media access tokens and API credentials associated with your account;
- content data and AI-generated content stored on our systems;
- usage logs and analytics data to the extent technically practicable; and
- any personal information received from Meta, LinkedIn, or TikTok APIs in connection with your account, in accordance with the deletion obligations under those platforms' terms.
Third-party sub-processors. Where your personal information has been shared with sub-processors (including Anthropic for AI processing, cloud hosting providers, and analytics services), we will take reasonable steps to instruct those sub-processors to delete your data in accordance with our agreements with them.
Meta platform data deletion
If you disconnect your Meta account (Facebook or Instagram) from the Platform, or if you submit a deletion request through Meta's platform, we will delete all personal information received from Meta's APIs in connection with your account within 30 days.
We do not retain Meta user data beyond what is necessary to provide the Platform, and we do not use Meta user data for purposes other than those permitted under Meta's Platform Terms.
TikTok platform data deletion
If you disconnect your TikTok account from the Platform, or if you submit a deletion request, we will delete all personal information received from TikTok's APIs in connection with your account within 30 days.
We comply with TikTok's Developer Terms of Service and Data Sharing Agreement with respect to the deletion of User data, including:
- deleting TikTok user data upon a User's verified request;
- not retaining TikTok user data beyond the period necessary to provide the Platform; and
- not using TikTok user data for purposes other than those expressly permitted under TikTok's developer terms.
Users may also request deletion of their TikTok-connected data directly through TikTok's platform settings. We will honour any deletion instructions received from TikTok in connection with such requests.
LinkedIn platform data deletion
If you disconnect your LinkedIn account from the Platform, or if you submit a deletion request, we will delete all personal information received from LinkedIn's APIs in connection with your account within 30 days.
We comply with LinkedIn's Developer Terms of Service and Data Sharing Agreement with respect to the deletion of User data, including:
- deleting LinkedIn user data upon a User's verified request;
- not retaining LinkedIn user data beyond the period necessary to provide the Platform; and
- not using LinkedIn user data for purposes other than those expressly permitted under LinkedIn's developer terms.
Users may also request deletion of their LinkedIn-connected data directly through LinkedIn's platform settings. We will honour any deletion instructions received from LinkedIn in connection with such requests.
Retention exceptions
We may retain personal information notwithstanding a deletion request where:
- retention is required by an Australian law, court order, or tribunal order;
- retention is required to resolve a dispute, enforce our terms of service, or defend a legal claim;
- the information is contained in a Commonwealth record (as defined in the Privacy Act 1988 (Cth));
- retention is required under a separate agreement with Meta, LinkedIn, or TikTok; or
- the information has been de-identified such that it can no longer be associated with any individual.
Where we rely on an exception to decline a deletion request, we will notify you in writing within 30 days of receiving your request, stating the grounds for retention and the expected retention period.
Backups and archived data
Personal information may be retained in encrypted backup systems for up to 90 days after a deletion request is processed. Backup data is not accessible in the ordinary course of business and will be overwritten or deleted in accordance with our standard backup rotation schedule.
We will take reasonable steps to ensure that deleted data is not restored from backup into active systems following a verified deletion request.
AI processing and Anthropic Claude
Our Platform uses Anthropic Claude to generate social media content on behalf of Users. Inputs provided to the AI model may include content instructions, brand guidelines, and other information supplied by Users.
We do not intentionally include personal information in AI model inputs beyond what is necessary to generate the requested content. Users should avoid submitting sensitive personal information as AI inputs.
Anthropic processes data in accordance with its own privacy and data handling policies. We do not control Anthropic's data retention practices for model inputs. Users who have concerns about AI-processed data should review Anthropic's privacy policy directly.
Upon a deletion request, we will delete all stored AI inputs and outputs associated with your account from our systems. We will also request deletion from Anthropic to the extent permitted under our agreement with Anthropic.
Data sovereignty and cross-border transfers
We are committed to data sovereignty principles. Where practicable, personal information is stored and processed in Australia.
Where personal information is transferred to or processed in a country outside Australia (including in connection with Meta, LinkedIn, TikTok, or Anthropic infrastructure), we take reasonable steps to ensure that the overseas recipient handles the information in a manner consistent with the APPs, in accordance with APP 8.
Deletion requests will apply to personal information held in all jurisdictions in which we or our sub-processors store your data.
Contact and complaints
For questions about this Policy or to submit a deletion request, contact our Privacy Officer:
Corrie Dark
Integrity AI Pty Ltd
Email: corrie@integrityai.com.au
Post: PO Box 5369, West End, QLD 4101, Australia
If you are not satisfied with our response to a deletion request, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by calling 1300 363 992.
Policy review
We will review this Policy at least annually and whenever there is a material change to our data handling practices, the platforms we integrate with, or applicable law.
The current version of this Policy is available at tbmmc.com.au/data-deletion-policy.
Australian owned and made.