Privacy Policy

Privacy Policy

Privacy Policy

Privacy Policy

Involo Teknoloji ve Pazarlama Çözümleri A.Ş. customer privacy notice
Involo Teknoloji ve Pazarlama Çözümleri A.Ş. customer privacy notice
Involo Teknoloji ve Pazarlama Çözümleri A.Ş. customer privacy notice
Involo Teknoloji ve Pazarlama Çözümleri A.Ş. customer privacy notice
Contact details
Contact details
Contact details
Contact details
What information we collect, use, and why
What information we collect, use, and why
What information we collect, use, and why
What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

  • Names and contact details

  • Involo Account information

  • Information relating to loyalty programmes

  • Website user information (including user journeys and cookie tracking)

  • Photographs or video recordings

  • Profile Information: Profile URL Number of followers Number of accounts followed Change in follower count over the last 30 days Number of new followers Number of unfollowers or deactivated accounts Number of profile visits

  • Media Information Number of media items Media IDs Media captions Media product type (e.g., post, story, IGTV, Reels) Media format\/type (e.g., album, video, etc.) Date\/time of publication Media URL stored on Instagram servers IDs of tagged accounts in media List of comments on the media

  • Engagement Data Number of likes on posts, Reels, and videos Number of comments on posts, Reels, and videos Number of shares of posts, stories, Reels, videos, and live videos Number of saves of posts, Reels, and videos Replies to stories (text replies, quick reactions) Total interactions on highlighted content Adjusted interaction counts (e.g., unlikes, unsaved content, deleted comments deducted)

  • View and Reach Data Total number of views of media content Number of plays or impressions (Reels, posts, stories) Number of unique accounts that viewed content at least once (reach) Total watch time of Reels videos Average watch time of Reels videos Number of replays of Clip videos

  • Follower Behavior Daily changes in follower count Number of followers online during a given period Number of accounts interacting with content (including through ads)

  • Demographic Data Demographic attributes of followers (country, city, gender) Demographic distribution of the reached audience

  • Profile Actions Number of clicks on business address, search, email, and message buttons Total number of profile actions taken through content Total number of actions from stories (exits, forwards, backwards, next story)


We collect or use the following information for the operation of customer accounts and guarantees:

  • Names and contact details

  • Involo Account information, including registration details

  • Information used for security purposes

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details

  • Marketing preferences

  • Recorded images, such as photos or videos

  • Website and app user journey information

We collect or use the following information for research or archiving purposes:

  • Names and contact details

  • Website and app user journey information

  • Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

  • Name

  • Contact information

  • Safeguarding information

We collect or use the following personal information for dealing with queries, complaints or claims:

  • Names and contact details

  • Account information

Lawful bases and data protection rights
Lawful bases and data protection rights
Lawful bases and data protection rights
Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data
Our lawful bases for the collection and use of your data
Our lawful bases for the collection and use of your data
Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide services and goods are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Service and Content Improvement: Monitoring engagement (likes, comments, saves, shares) to assess which content is most relevant for the audience. Using view and reach data to improve the quality and effectiveness of media content. 

  • Operational Analytics: Using aggregated statistics to prepare internal performance reports. Supporting decision-making processes with data-driven insights without profiling individuals in a way that significantly impacts them.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

  • Service and Content Improvement: Monitoring engagement (likes, comments, saves, shares) to assess which content is most relevant for the audience. Using viewership and reach data to improve the quality and effectiveness of media content.

  • Measuring the impact of advertisements, campaigns, and collaborations. Identifying which content formats (Reels, Stories, Posts) attract the most engagement for optimizing marketing strategy.

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for research or archiving purposes are:

  • Public task – we have to collect or use your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as ours. All of your data protection rights may apply, except the right to erasure and the right to portability.

Our lawful bases for collecting or using personal information for legal requirements are:

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

  • Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.


Note: We do not carry out automated decision-making processes that produce legal effects or similarly significant impacts on individuals within the meaning of Article 22 UK GDPR. Data analysis, including the use of artificial intelligence, is limited to generating aggregated insights and reports, without making binding decisions about individuals.

Where we get personal information from
Where we get personal information from
Where we get personal information from
Where we get personal information from
  • Directly from you

  • Providers of marketing lists and other personal information

  • Suppliers and service providers

  • Third parties:

  • We may obtain certain analytics and engagement data from third-party data providers, specifically Meta Platforms, Inc. (Facebook and Instagram). These entities act as independent data controllers and provide access to such data through their APIs. We process this data solely for the purposes and under the conditions set out in this Privacy Notice.”

  • In addition, we may also receive data from Bright Data Ltd. (“Bright Data”), which likewise acts as an independent data controller and makes certain data available through its platform. Such data is processed exclusively in line with the purposes and conditions defined in this Privacy Notice.

How long we keep information
How long we keep information
How long we keep information
How long we keep information

Category

Data Types

Retention Schedules

Profile Information

Profile URL, number of followers, number of accounts followed, change in follower count (last 30 days), new followers, unfollowers/deactivated accounts, profile visits

10 years

Media Information

Media count, media IDs, media captions, media product type (post, story, IGTV, Reels), media format/type (album, video, etc.), publication time, media URL (Instagram servers), tagged account IDs, list of comments

10 years

Engagement Data

Likes on posts/Reels/videos, comments on posts/Reels/videos, shares of posts/stories/Reels/videos/live videos, saves of posts/Reels/videos, replies to stories (text/quick reactions), total interactions on highlighted content, adjusted interaction counts (e.g., unlikes, unsaves, deleted comments)

10 years

Viewership and Reach Data

Total views of media, plays/impressions (Reels, posts, stories), unique accounts that viewed content at least once (reach), total watch time of Reels, average watch time of Reels, replay count of Clip videos

10 years

Follower Behavior

Daily changes in follower count, number of online followers during a given period, number of accounts interacting with content (including ads)

10 years

Demographic Data

Demographic attributes of followers (country, city, gender), demographic distribution of reached audience

10 years

Profile Actions

Clicks on business address/search/email/message buttons, total profile actions via content, total story actions (exit, forward, back, next story)

10 years

How to complain
How to complain
How to complain
How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated
Last updated
Last updated
Last updated

24 September 2025