Privacy Policy

This Privacy Policy explains what information we collect, how we use it, who we may share it with, and your rights regarding your data.

To request data deletion or revoke integrations, see our Data Deletion Instructions at /data-deletion.

Orion Agency is a platform for managing and analyzing digital marketing campaigns on Meta (Facebook and Instagram), operated from Novo Hamburgo, Rio Grande do Sul, Brasil.

Our services include:

• Creating and managing campaigns, ad sets, and ads on Meta
• Analyzing and monitoring campaign metrics
• Building audiences and personas
• Generating reports and dashboards
• AI-powered learnings, suggestions, and insights
• Automation and optimization features (Agency Cortex and research scientists)
• Server-side conversion events to Meta (Conversions API)

For the purposes of this Policy:

• Personal Data: any information relating to an identified or identifiable natural person
• Processing: any operation performed on personal data
• Data Subject: the natural person to whom the data refers
• Controller: entity responsible for processing decisions
• Processor: entity that processes data on behalf of the controller
• Partner Platforms: services integrated with Orion Agency and authorized by you, such as Meta

We collect data in the categories below, depending on how you use the platform.

We may collect:

• Full name
• Email address
• Password (stored encrypted) — or, with social login, the profile name and email provided by Meta or Google
• Company or workspace name
• Billing information and subscription identifiers
• Tax information, when applicable to your plan
• Language, theme, and account preferences

We may collect:

• IP address
• Browser, operating system, and device
• Language and time zone
• Access date and time and usage logs
• Pages visited and in-platform events

When you connect your Meta account, we access only the information you authorize during login/OAuth, through Meta's official APIs. We may access:

• Ad accounts and Business Manager
• Campaigns, ad sets, and ads
• Audiences
• Associated Facebook Pages and Instagram accounts
• WhatsApp Business assets, when you connect them
• Pixels and conversion events
• Metrics (spend, reach, impressions, clicks, CTR, CPC, CPA, ROAS) and metadata provided by Meta
• Access tokens (OAuth), granted scopes, and Meta account identifiers

When you accept optional advertising technologies, we may send server-side conversion events to Meta through the Conversions API (CAPI). These events may indicate registration and progress through our sales funnel, such as a qualified lead, scheduled meeting, proposal, or purchase.

To match an event with a Meta account, we may send cryptographically hashed (SHA-256) email and phone, an internal identifier, IP address, browser information, and attribution identifiers such as fbp, fbc, and fbclid when available. Hashing reduces exposure during transmission, but the information remains personal data under this Policy.

Meta uses this information for event matching, measurement, attribution, and optimization of our campaigns. We do not use this flow to sell data or build audiences for third parties. Events are deduplicated through an event identifier (event_id).

Collected data may be used to:

• Provide platform access and identify users
• Manage subscriptions and process payments
• Create, sync, display, and analyze campaigns and metrics
• Generate reports, dashboards, alerts, and recommendations
• Operate automation, Agency Cortex, and research scientists
• Measure, attribute, and optimize our Meta campaigns when you accept optional advertising technologies
• Detect fraud and monitor security
• Improve our services and handle support requests
• Comply with legal obligations

Orion Agency uses AI models — Google Gemini and Anthropic Claude — to generate learnings, suggestions, recommendations, insights, copy, and automated analyses.

Results are for informational purposes only. You acknowledge that:

• Recommendations do not constitute professional consulting
• There is no guarantee of financial results or sales growth
• Final decisions remain your responsibility
• We do not send Meta access tokens to AI models — context is built on the server from synced data

For competitor and trend analysis, we may query public sources (such as the Meta Ad Library and search results) using only niche-related search terms — no personal data.

This data is public and used only to generate market insights.

If you enable report delivery via WhatsApp, we use the WhatsApp Business Cloud API (Meta) to send messages to recipients you configure.

You are responsible for having a legal basis and the recipients' consent for such delivery.

We process personal data based on the following legal grounds:

• Contract performance — when necessary to provide contracted services
• Legal obligation — when required by law or competent authority
• Legitimate interests — for legitimate and proportionate purposes such as improving the platform, preventing fraud, and ensuring security, after assessing necessity, data-subject expectations, and applicable safeguards
• Regular exercise of rights — for defense in judicial, administrative, or arbitration proceedings
• Consent — for optional analytics and advertising cookies and technologies, including sending our funnel events to Meta for campaign measurement, attribution, and optimization

We do not sell personal data. We may share information with:

• Infrastructure: Vercel, Supabase (PostgreSQL), and Cloudflare
• Artificial intelligence: Google (Gemini) and Anthropic (Claude)
• Advertising platform: Meta (ads APIs, Conversions API, and WhatsApp Business)
• Payment processing: Asaas (Brazil) and Stripe (international)
• Communication: transactional email providers
• Authorities — when required by law or court order

Some of our providers are located outside Brazil.

By using Orion Agency, you acknowledge that certain information may be processed on servers in other countries.

We will adopt reasonable measures to ensure adequate protection levels as required by LGPD.

Data may be retained while your account is active, during the contract term, as required to comply with legal obligations, or for the regular exercise of rights.

After that period, data may be deleted, anonymized, or aggregated for statistical purposes.

To request deletion, email support@orionagency.com.br or follow the instructions at /data-deletion. You can also revoke the app's access directly on Meta.

We adopt technical and organizational measures to protect information, including:

• HTTPS/TLS
• Encryption of passwords and sensitive data
• Hashing (SHA-256) of identifiers sent to the Conversions API
• Workspace access controls
• Audit logs and periodic backups
• Monitoring and protection against unauthorized access

Despite our efforts, no system is completely risk-free. We will notify relevant incidents as required by LGPD.

We use cookies and similar technologies in the categories below. Essential cookies may operate regardless of your choice because they are required for security, authentication, and service operation. Optional technologies remain disabled until you accept them in the banner.

• Essential: required for authentication, session, security, and platform operation
• Preferences: language, theme, and interface settings
• Analytics: platform performance and usage measurement, when accepted
• Advertising: Meta Pixel, attribution identifiers, and the Conversions API, used for event matching, measurement, attribution, and campaign optimization, when accepted

Closing or ignoring the banner means no choice has been recorded and does not constitute acceptance or rejection. Optional technologies remain disabled in this state. You may accept or reject through the banner. To change a saved choice, clear this site's data in your browser so the banner is displayed again. Rejection does not prevent use of the platform's essential features.

Under LGPD, you may request confirmation of processing, access, correction, anonymization, blocking, deletion, portability, consent withdrawal, and information about sharing.

You may also object to processing based on legitimate interests and ask us to review our assessment. Withdrawing consent stops new optional transmissions without affecting processing previously carried out on a valid basis.

Send requests to support@orionagency.com.br. We will respond within a reasonable time.

You may also file a complaint with Brazil's National Data Protection Authority (ANPD).

• Confirmation and access to data
• Correction of inaccurate or outdated data
• Anonymization, blocking, or deletion
• Portability
• Consent withdrawal
• Information about sharing

When using Meta integrations (Facebook, Instagram, Ads, Conversions API, and WhatsApp Business), you are also subject to Meta's policies.

We request only the permissions needed to operate the features you authorize. We do not sell user or campaign data, nor use Meta data for purposes not described in this Policy.

You can disconnect Meta at any time in Settings → Integrations, or revoke the app at https://www.facebook.com/settings?tab=applications. Revoking stops new access, and you may request deletion of already-synced data.

We recommend reading Meta's Privacy Policy (https://www.facebook.com/privacy/policy/) and the Platform Terms for Developers (https://developers.facebook.com/terms/).

Orion Agency uses subprocessors to operate the services. They currently include:

• Vercel, Supabase, and Cloudflare (infrastructure and hosting)
• Google (Gemini) and Anthropic (Claude) — artificial intelligence
• Meta (ads APIs, Conversions API, and WhatsApp Business)
• Asaas and Stripe (payments)
• Transactional email providers

This list may be updated periodically as infrastructure evolves.

This Policy may be modified at any time to reflect legal changes, new features, or operational improvements.

The latest version will always be available on this page, with the update date shown at the top.

Continued use after changes constitutes acknowledgment of the new conditions.

Questions about privacy, data protection, or exercising your rights may be sent through Orion Agency's official channel:

Contact: support@orionagency.com.br

Location: Novo Hamburgo, Rio Grande do Sul, Brasil