Privacy Policy
This Privacy Policy describes how Comercii (“we,” “us,” or “our”) collects, uses, and protects your information when you use the Nhu Le creator CRM platform (the “Platform”), accessible at nhu-le.com.
1. Introduction
Comercii (https://comercii.com) operates the creator CRM platform powering Nhu Le's digital presence. The Platform enables Nhu Le to manage social media analytics, schedule content, track brand deal opportunities, and generate AI-assisted content across TikTok, YouTube, Instagram, and Facebook.
By using this Platform, you agree to the collection and use of information in accordance with this policy. If you do not agree, please discontinue use of the Platform.
For questions about this policy, contact us at ngocnhule96@gmail.com.
2. Information We Collect
a. Account Information
When you sign in to the Platform, we collect your name and email address via a passwordless magic link (powered by NextAuth). We do not store passwords.
b. Social Media Data via OAuth
When you connect social media accounts, we collect data through official OAuth integrations. Specifically:
- TikTok: Basic profile information (display name, avatar, follower count), video list (titles, view counts, like counts, comment counts, share counts, play counts), and engagement metrics — accessed via scopes
user.info.basicandvideo.list. - YouTube: Channel profile information, video analytics, view counts, subscriber counts, and engagement metrics via the YouTube Data API v3.
- Instagram / Facebook: Business profile information, post metrics (reach, impressions, engagement), follower demographics, and page insights via the Meta Graph API.
OAuth tokens are encrypted at rest. You may revoke access at any time through each platform's settings or through your account settings on this Platform.
c. Content You Create
We store content you create within the Platform, including draft captions, scheduled post content, content calendar entries, brand deal notes, and media kit assets. This content remains yours.
d. Usage Data
We collect information about how you interact with the Platform, including pages visited, features used, actions taken, timestamps, and general performance metrics. This helps us improve the Platform.
e. AI Interaction Data
When you use the AI content assistant, we transmit your prompts and relevant context to Anthropic's Claude API for content generation. See Section 5d for details on how Anthropic handles this data.
3. How We Use Your Information
We use the information we collect to:
- Provide and operate the creator CRM services
- Aggregate and display social media analytics across connected platforms
- Generate AI-powered content suggestions tailored to your audience and niche
- Send scheduled post notifications and transactional emails
- Track brand deal pipeline and collaboration history
- Maintain your content calendar and scheduling queue
- Improve the Platform's features and fix technical issues
- Comply with legal obligations
We do not sell, rent, or lease your personal information to third parties. We do not use your data for advertising purposes.
4. Data Storage & Security
Your data is stored in a PostgreSQL database hosted on Railway, a cloud infrastructure provider. All database connections use TLS/SSL encryption in transit.
OAuth access tokens and refresh tokens are encrypted at rest using industry-standard encryption before being stored in our database.
All communication between your browser and the Platform is protected via HTTPS (TLS). We use Vercel for hosting, which enforces HTTPS on all routes.
While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.
5. Third-Party Services
We integrate with the following third-party services to operate the Platform. Each service has its own privacy policy.
a. TikTok API
We integrate with the TikTok API to provide analytics and content management features. We access the following TikTok data:
- user.info.basic scope: Display name, avatar URL, follower count, following count, and likes count.
- video.list scope: Video IDs, titles, cover images, creation dates, view counts, like counts, comment counts, share counts, and play counts for videos published by the authenticated account.
Purpose: TikTok data is used exclusively to display analytics dashboards and assist with content management within the Platform. It is not sold, shared, or transferred to any third parties for any purpose.
How to revoke TikTok access: You can disconnect your TikTok account at any time by visiting your account settings within this Platform, or directly through TikTok by navigating to TikTok Settings → Security → Authorized Apps and removing this application. Revoking access will immediately prevent us from fetching new TikTok data; previously synced data will be deleted upon your request.
TikTok data is governed by TikTok's Privacy Policy.
b. YouTube Data API (Google)
We use the YouTube Data API v3 to retrieve channel analytics, video performance metrics, subscriber counts, and engagement data. This data is used only to display analytics within the Platform. Your use of YouTube features is also subject to Google's Privacy Policy.
c. Meta (Instagram & Facebook)
We integrate with the Meta Graph API to retrieve Instagram business profile data, post metrics, follower demographics, and Facebook page insights. This data is used only to display analytics within the Platform. Your data is subject to Meta's Privacy Policy.
d. Anthropic (Claude AI)
When you use the AI content assistant, your prompts and relevant context (such as your content pillars and audience description) are transmitted to Anthropic's API to generate content suggestions. Anthropic does not use API request data to train its models by default. No personal user data beyond what you explicitly include in a prompt is sent to Anthropic. See Anthropic's Privacy Policy.
e. Resend
We use Resend to deliver transactional emails such as magic link sign-in emails and notifications. Resend processes your email address to deliver these messages. See Resend's Privacy Policy.
f. Paddle
We use Paddle as our payment processor for Platform subscriptions. Paddle collects billing information (name, email, payment method) and acts as the Merchant of Record. We do not store your full payment card details. See Paddle's Privacy Policy.
g. Vercel
The Platform is hosted on Vercel. Vercel may process request logs and usage metadata as part of its hosting infrastructure. See Vercel's Privacy Policy.
6. TikTok Data
This section provides additional detail on TikTok data practices as required by the TikTok Developer Terms of Service.
- Data accessed: We access only data permitted by the
user.info.basicandvideo.listscopes. - Purpose limitation: TikTok data is used solely to display analytics and support content management features within this Platform. It is not used for any other purpose.
- No resale or sharing: TikTok data accessed through the API is never sold, licensed, shared, or otherwise transferred to any third party.
- Data minimization: We request only the minimum scopes required to deliver the Platform's features.
- Token storage: TikTok OAuth access tokens are encrypted at rest and never exposed client-side.
- Revocation: Users may revoke TikTok access at any time via account settings in this Platform or through TikTok's Authorized Apps settings. Upon revocation, tokens are immediately invalidated and deleted from our database.
- Deletion on request: Upon account deletion or explicit request, all TikTok data associated with your account will be permanently deleted within 30 days.
7. Data Retention
We retain your data for as long as your account remains active and for a reasonable period afterward to comply with legal obligations. Specifically:
- Account data is retained while your account is active and for up to 90 days after account closure.
- Social media analytics data (synced from connected platforms) is retained while your account is active.
- Content drafts and calendar entries are retained until you delete them or close your account.
- Payment records are retained for a minimum of 7 years as required by applicable tax law.
You may request deletion of your data at any time by contacting us at ngocnhule96@gmail.com.
8. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: Request a copy of the personal data we hold about you.
- Correction: Request that inaccurate or incomplete data be corrected.
- Deletion: Request that we delete your personal data (“right to be forgotten”).
- Data Portability: Request a machine-readable export of your data.
- Withdraw Consent: Withdraw consent for data processing at any time, including revoking OAuth access to connected social media accounts.
- Objection: Object to certain types of data processing.
To exercise any of these rights, contact us at ngocnhule96@gmail.com. We will respond within 30 days.
9. Cookies & Tracking
We use a minimal number of cookies required for the Platform to function:
- Session cookie: A secure, HTTP-only session cookie managed by NextAuth is used to maintain your authenticated session. This cookie is essential for the Platform to function and does not track your activity across other websites.
We do not use third-party tracking cookies, advertising pixels, or behavioral analytics SDKs. We do not participate in cross-site tracking.
10. Children's Privacy
This Platform is not intended for use by individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information promptly.
If you are a parent or guardian and believe your child has provided us with personal information, please contact us at ngocnhule96@gmail.com.
11. International Data Transfers
Comercii is operated from Canada. Your information may be processed and stored in Canada and the United States, where our infrastructure providers (Railway, Vercel) operate their data centers.
By using the Platform, you consent to the transfer of your information to Canada and the United States. We take appropriate steps to ensure that your data is treated securely in accordance with this Privacy Policy regardless of where it is processed.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, notify you by email.
Your continued use of the Platform after changes are posted constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.
13. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:
Comercii
Operating the Nhu Le Creator Platform
Website: https://comercii.com
Email: ngocnhule96@gmail.com
We aim to respond to all inquiries within 30 days.