This Policy explains what data the Nitka service collects, why, to whom it is transferred, how long it is stored and how to delete it. By using the Service, you confirm that you have read this Policy. If you do not agree with it, do not use the Service.
1. Who we are
1.1. The Nitka service (the nitka.tools website and the app.nitka.tools web application, the "Service") is provided by Individual Entrepreneur Oleh Dmytrovych Batozhnyi, taxpayer ID (RNOKPP) 3364011937, entry in the Unified State Register No. 2010350000000796880 of 03.06.2025, address: 61204, Kharkiv, Peremohy Ave., 62D, apt. 144, Ukraine ("Nitka", "we").
1.2. For any questions regarding personal data, write to info@nitka.tools. We confirm receipt of your request within 7 business days.
1.3. This Policy has been prepared in accordance with the Law of Ukraine "On Personal Data Protection", for users from the EU/EEA taking into account Regulation (EU) 2016/679 (GDPR), and in line with the Meta Platform Terms and Meta Developer Policies.
2. What the Service does
2.1. Nitka connects to the user's Facebook business Page and Instagram professional account via official Meta APIs. In the Service, the user sees conversations with customers, assigns them statuses (e.g., "Lead", "Sale") and fills in an order card.
2.2. A status change automatically sends the corresponding event to the user's Meta Pixel via the Conversions API (CAPI). This lets the user's ad campaigns optimize for real leads and sales from conversations. The Service also loads spend and performance data from the user's ad account to show an ad-to-sale report.
3. Nitka's two roles regarding data
| Whose data | Who decides why it is processed | Nitka's role |
|---|---|---|
| Data of Service users (account owner, managers) | Nitka | Controller |
| Data of the user's customers — people who message the business on Instagram or Messenger | The Service user (the business) | Processor: processes the data only on the user's instructions |
3.1. If you messaged a business that uses Nitka and want to know about your data or have it deleted, please contact that business first. We also accept such requests directly (Section 9).
4. Data we collect
4.1. User account data: name, email, phone number (if provided), company name, password in hashed form or a Facebook login identifier.
4.2. Data received from Meta after connection (only with your permission):
- IDs and names of the Facebook Pages and Instagram accounts you granted access to
- access tokens (stored encrypted)
- IDs of the Meta Pixel, ad account and Business Manager; ad account data (read-only): names and IDs of campaigns, ad sets and ads, spend, impressions, clicks, conversions and other performance metrics; Nitka does not change campaigns or budgets
- Page conversation messages: text, attachments, date and time
data of conversation participants that Meta sends with a message: Page-scoped identifier (PSID / IGSID), name, username, profile photo, and the ID of the ad or post where the conversation started (if Meta provides it).
The list of permissions requested by the Service is shown in the Meta dialog when you connect. You can revoke them at any time in your Facebook and Instagram settings.
4.3. Data entered by the user: conversation statuses, order cards (e.g., amount, product, customer's phone, email, city), notes, tags.
4.4. Payment data: plan, amounts, dates and status of payments, order number, masked card number, and for invoice payments — payer details (name or full name, EDRPOU code / RNOKPP, address, email for documents). Invoices and acts may be sent via the Vchasno electronic document service. Bank card data is processed by the payment service WayForPay; Nitka does not receive or store it.
4.5. Technical data: IP address, browser and device type, login dates and times, activity logs in the Service, cookies (see the Cookie Policy: nitka.tools/cookies/).
4.6. Communications: support emails, messages in Nitka's chats and social media.
5. Purposes and legal bases of processing
| Purpose | Data | Legal basis |
|---|---|---|
| Registration, login, dashboard operation | 4.1, 4.5 | Performance of the contract (Offer) |
| Displaying conversations and statuses, ad-to-sale report | 4.2, 4.3 | Performance of the contract; user's instructions |
| Sending events to the user's Meta Pixel via CAPI | 4.2, 4.3 | User's instructions |
| Payments, accounting, tax reporting | 4.1, 4.4 | Performance of the contract; legal obligations |
| Security, abuse prevention | 4.5 | Legitimate interest |
| User support | 4.1, 4.6 | Performance of the contract |
| Anonymized niche statistics (Section 6) | 4.2 (ad account data), 4.3 in anonymized form | Legitimate interest |
| Service emails and Nitka news | 4.1 | Performance of the contract; for news — consent, which can be withdrawn |
6. Anonymized niche statistics
6.1. Nitka publishes public statistics by niche — for example, the average number of conversations and the share of leads and sales. For this we use only aggregated metrics: numbers of conversations and statuses, as well as aggregated advertising metrics (average cost per lead or sale, cost per conversation, conversion from conversation to lead and sale, etc.) calculated from ad account data and statuses — without message text, names, contacts or identifiers.
6.2. The statistics cannot identify a specific Service user or their customers. Names of companies, Pages, accounts, ad accounts and campaigns, as well as the spend or results of an individual Project, are not published. Niche metrics are published only when the niche contains more than 5 Projects.
7. How we use Meta data
7.1. Data received through the Meta platform is used only to provide Service features to the user who connected it.
7.2. We do not sell data, do not transfer it to ad networks, data brokers or other third parties for their own purposes, and do not use it for ad targeting, except for sending events to the user's own Pixel on the user's instructions.
7.3. One user's data is not used to provide services to another user, except for anonymized statistics (Section 6).
7.4. Messages to customers are sent only on behalf of the user's Page and by the user's action, in compliance with Meta's messaging policies.
8. Who we share data with
| Recipient | What they receive | Purpose |
|---|---|---|
| Meta Platforms (Facebook, Instagram) | Conversion events, conversation identifiers, messages sent by the user | Integration and CAPI |
| WayForPay | Amount, payment purpose, payer's email | Accepting payments |
| Vchasno Service LLC (Vchasno service) | Payer details, invoices and acts | Electronic document exchange (at the Customer's request) |
| Cloud infrastructure provider | All Service data in encrypted storage | Hosting of servers and databases |
| SendPulse | Email, name | Service emails, news and promotions |
| Website analytics and advertising services: Google Tag Manager, Google Analytics 4, Microsoft Clarity, VWO, Meta Pixel, LinkedIn Insight Tag, X Pixel and others (list in the Cookie Policy) | Technical data, cookies | Website analytics, A/B testing, measuring Nitka's advertising |
8.1. Data is shared only with providers without whom the Service cannot operate, and only to the extent necessary for their function:
8.2. We may disclose data at the lawful request of a court or an authorized public authority. Unless prohibited by law, we will notify the user of such a request.
8.3. Service data is stored in secure cloud infrastructure whose data centers may be located outside Ukraine. Some providers (Meta, Google, Microsoft, LinkedIn, X, VWO, SendPulse) are located outside Ukraine, so the data they receive may be transferred abroad. We share only the minimum necessary data with them, and analytics and advertising tags on the website run only after your consent in the cookie banner.
9. Your rights
9.1. You have the right to:
- know what data we process about you and receive a copy
- correct inaccurate data
- have data deleted (Section 10 and the page nitka.tools/user-data-deletion/)
- restrict or object to processing
- withdraw consent to news and promotional emails, given via a checkbox at registration — in your profile settings or via the link in every email (service emails about payments and access are sent regardless)
- receive your data in a machine-readable format (CSV) for portability
lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or, in the EU, with the supervisory authority of your country.
9.2. Send requests to info@nitka.tools from the email linked to your account. We confirm receipt within 7 business days and fulfil the request within 30 business days.
10. Retention and deletion
| Data | Retention period |
|---|---|
| Account | While the account is active |
| Meta access tokens | Deleted immediately after disconnecting a Page or deleting the account |
| Conversations, statuses, order cards | While the subscription is active + 90 days after the Project is suspended (with an email warning before deletion) |
| Payment and accounting documents | Period required by tax law (at least 1,095 days) |
| Technical logs | Up to 90 days |
| Backups | Overwritten within 30 days |
10.1. After a deletion request, we delete data within 30 business days, except data we are legally required to keep.
10.2. If you remove the Nitka app in your Facebook or Instagram settings, Nitka will lose access to new data. To delete data already stored, send an email to info@nitka.tools following the instructions at nitka.tools/user-data-deletion/.
11. Security
11.1. We protect data with organizational and technical measures: traffic encryption (HTTPS/TLS), encryption of access tokens at rest, access separation between accounts, least-privilege access for the team, and backups. More details at nitka.tools/security/.
11.2. If an incident affecting your data occurs, we will notify you by email within 72 hours of discovery and, where required, the relevant authorities.
12. User's obligations regarding their customers' data
12.1. The user, as the controller of their customers' data, is responsible for:
- having a legal basis to transfer customer data to the Service and to the Meta Pixel
- publishing their own privacy policy informing customers about the processing of their data, including the transfer of events to Meta
complying with Meta's terms for messaging and use of the Conversions API.
13. Children
13.1. The Service is not intended for persons under 18. We do not knowingly collect children's data as Service users.
14. Changes to this Policy
14.1. We may update this Policy. A new version takes effect upon publication at nitka.tools/privacy-policy/. We will notify you of material changes by email or in the dashboard at least 7 days in advance.
14.2. This Policy is drawn up in Ukrainian; the English version is a translation. In case of discrepancies, the Ukrainian version prevails.
Contacts
Individual Entrepreneur Oleh Dmytrovych Batozhnyi · info@nitka.tools · phone: [phone number] · nitka.tools