Privacy policy

1. Controller and contact

The data controller is Manuel Jesús Ramos Jiménez, an individual using the Disskero brand. Disskero is not a company or a separate legal entity. There is no registration service for external customers.

Contact for privacy, enquiries and rights requests: audio@disskero.com.

• Full operator identification · Legal notice

2. Current processing

• Connect and maintain the operator’s own professional account through official Instagram Login; verify identity, permissions and validity and refresh the token when appropriate.
• Read the account’s own posts and retain independent campaign configurations: name, keywords, messages, buttons, conditions and original resource links.
• Receive, validate and record official comments, messages and button presses, linking them to the media, participant and campaign for which the association can be established. The system supports public replies, private replies, button messages, official follow-status checks and resource delivery, whose operation has been verified in controlled real tests.
• Protect the dashboard, prevent duplicates and reingestion after erasure, handle rights requests and diagnose errors using minimal data. Campaigns and sends are subject to separate activation and authorization controls.
• View CONTACTOS within the private dashboard, using authentic activity references and campaign filters. A person with no known username is shown with a neutral label, not an invented name.

3. Data and sources

Instagram data comes from Meta’s official APIs and webhooks, the owner’s authorization and interactions on Instagram. The administrator enters campaign configurations.

• The operator’s own professional account: official identifiers, username, display name, professional account type, avatar URL when available and granted permissions. These are not participants’ photographs or profile data obtained for CONTACTOS.
• Connection credentials: encrypted OAuth token, issue and expiry dates and verification status. AutoChat does not request or store the Instagram password.
• Accepted comments: comment and media identifiers, text, author identifier when supplied by Meta, date and technical references for validation, deduplication and campaign association.
• Campaign configurations and history; sanitized technical states and errors for OAuth, maintenance and subscription.
• Administrative access and hosting: the provider may process technical connection and security data, such as IP address, date and user agent, under its service.
• Automation interactions: official identifiers and pseudonymous links between comments and messaging, dates, event type, button presses and opaque button references, established campaign associations, message identifiers and Meta acceptance status, follow status when checked, and the first unique attributable final-link click per participant and campaign. Operational and statistical references are retained, rather than an archive of private conversation text.
• Participant username, optionally when its retention is enabled: the latest valid from.username value supplied by Meta in an authentic, verified comment, its observation date and source. It would identify the contact for human recognition within the private dashboard and link their interactions to campaigns. Profiles are not queried and historical usernames are not recovered in bulk; participants’ full names, emails, telephone numbers or photographs are not added to CONTACTOS.

The receiver does not store the complete webhook payload, authorization headers or secrets in application logs. Pseudonymous identifiers and hashes are not necessarily anonymous. Unnecessary sensitive or third-party data should not be included in comments or configurations.

Contact identity is linked through stable identifiers and established associations, never by matching a display name. A username may be missing or change; it would be updated only on a genuinely new, later official observation, without retaining a list of previous usernames. A neutral label represents a contact without a username. Participant username collection is not published or enabled as of this policy’s date.

4. Automations, messages and clicks

The automation engine is deployed and operational in production. Replies, messages, buttons, follow checks and delivery depend on the campaigns enabled by the operator and on Meta’s permissions and messaging windows. Availability of these features does not mean that all campaigns are active or that every comment causes a send. Optional username collection in CONTACTOS is a separate processing operation that is not yet enabled.

Processing for each campaign must be limited to the requested interaction or resource. Minimal references support the workflow and its statistics. A message accepted by Meta does not establish delivery, receipt or reading on the device. An attributable click does not establish a download, purchase or that the opening was human.

DM text is not used to create a conversation archive. Measurement links are opaque and use no first-party cookies; identifiable previews are excluded. A forwarded link or unidentified scanner may attribute an opening to the original recipient. Recording a contact does not authorize bulk messages or additional advertising.

5. Legal basis

Limited handling of expressly requested interactions, review of their execution and security rely on the controller’s legitimate interests (GDPR Article 6(1)(f)), assessed against purpose, necessity, reasonable expectations, minimization and the ability to object. Special categories of data are not requested and individuals are not commercially assessed or subject to decisions with legal or similarly significant effects.

For auxiliary identification in CONTACTOS, the specific interest is to recognize requested interactions intelligibly and reduce confusion when reviewing them or handling rights. Only the latest username received through the official channel is envisaged, with operator-only access and short retention, without profile lookups or new advertising uses. This purpose has been assessed against alternatives and the risks of linkage and outdated data; lawfulness is not inferred merely from a username being public.

Handling rights requests and data-protection obligations relies on Article 6(1)(c). Commenting or following does not establish a contractual relationship. A public comment does not authorize advertising campaigns or unrelated subsequent uses.

You may object to processing based on legitimate interests by writing to audio@disskero.com. The affected processing will cease unless compelling legitimate grounds overriding your interests, rights and freedoms are demonstrated, or it is needed to establish, exercise or defend legal claims. Additional commercial communications require their own legal authorization; Meta’s technical capability alone does not provide it.

Commenting on a Reel, following the account or pressing a button does not mean accepting this policy or consenting to other purposes. Legitimate interests do not in themselves require individual consent, but do not replace information duties. Before optional username retention is enabled, the applicable information must be provided to the people concerned through a mechanism appropriate to the context. Publishing this policy does not by itself establish that this obligation has been met.

6. Providers, recipients and transfers

Meta operates Instagram under its own terms and privacy policy; AutoChat uses its official APIs exclusively. Cloudflare supplies hosting, execution, D1, queues and access control; its data processing agreement covers data processed on the operator’s behalf.

Exclusive EU residency is not guaranteed. Cloudflare’s DPA provides for the Data Privacy Framework and standard contractual clauses as applicable. Information and relevant safeguards may be requested from the controller.

Ordinary dashboard access is restricted to the operator. Data is not sold and customer accounts are not connected. Disclosure may be required by law. Providers may process their own service and security data under their respective policies.

• Instagram privacy policy
• Cloudflare data processing agreement

7. Retention

The criterion is to retain only what is needed for the interaction, security and rights handling. The code provides scheduled pruning and a private administrative operation: comment text and direct identifiers are minimized from 30 days, technical receipts removed from 30 days, reception records from 90 days and individual metrics from 366 days, subject to the applicable exceptions for in-progress records or references still needed in each case. These are operational thresholds, not statutory periods or immediate erasure of every table or recovery copy.

CONTACTOS lists people with authentic recorded activity within the last 30 days. This window is a display filter, not a deletion instruction. Derived activity references are pruned from 90 days onward, without thereby extending the retention periods of original records, metrics or deduplication markers.

For the planned optional username processing, the username, its search form, observation date and source will be limited to 30 days from the latest genuinely new official observation. A technical retransmission or later activity without a username will not renew that period. The processing will require an expired username to be excluded from reads and searches and physically removed in the next successfully completed daily CONTACTOS maintenance cycle; physical deletion at the exact instant of expiry is not promised. These controls must be operational before collection is enabled, which remains unpublished. Recovery copies retain their recovery windows.

Minimal pseudonymous campaign membership and identity-scope aliases remain while needed to prevent another initial reply or handle rights, without thereby retaining a username indefinitely. Existing complete-erasure markers are restricted and prevent reingestion; they are reviewed when their purpose ceases or the account closes. They contain no comment text and are not treated as anonymous. Complete erasure and an objection limited to a username have different scopes.

Campaign configurations and history support management and recovery; logical deletion is not physical erasure. Any third-party data exceptionally entered in a configuration requires selective review and erasure without destroying unrelated campaigns. The token remains encrypted while connected; disconnecting does not remove all history.

Rights requests are documented only as needed to handle them and demonstrate compliance or a specific obligation. Recovery copies and provider logs follow their actual retention windows; immediate disappearance is not promised. Erasures must be reapplied before reactivating a restored system. You may request review or erasure without waiting for these criteria.

8. Security

The dashboard uses Cloudflare Access and server-side checks; tokens remain encrypted and outside browser JavaScript. POST events require valid HMAC-SHA256 signatures, size limits and account validation; persistence prevents duplicates.

These measures reduce risk but do not guarantee absolute security. Passwords or tokens are not requested to handle rights requests.

9. Rights and complaints

Subject to legal conditions, you may request access, rectification, erasure, restriction, objection and, where applicable, portability. If processing relies on consent, you may withdraw it without affecting earlier lawfulness. You may also request information about applicable transfer safeguards.

Requests should be sent to the approved privacy contact and include only what is necessary to locate the data and reasonably verify the requester. The deletion instructions describe the proposed process.

You may request correction or removal of an inaccurate or outdated username, as well as applicable erasure or objection, by writing to audio@disskero.com. Identity is verified using proportionate means and reliable references, never a display name alone, and the scope is established without extending a username-only request to all processing. Optional collection will not be enabled without a safeguard to honor those requests and prevent improper reintroduction of the username. Handling is manual; an automated partial exclusion is not presented as already available.

The usual legal response period is one month from receipt. It may be extended by two further months because of complexity or the number of requests, with notice and reasons within the first month. You may complain to the Spanish Data Protection Agency.

• Data deletion instructions
• Spanish Data Protection Agency

10. This site and policy changes

This legal site contains only static content: it contains no forms, tracking scripts, analytics or first-party tracking cookies. Hosting may process technical data needed to serve and protect the pages.

Information updated on 11 November 2026. Material changes to purposes or processing require this information to be reviewed before they are applied. Full operator identification is provided in the legal notice.