At AskRocco, operated by Ajungo Holdings LLC, we understand the importance of your advertising data and the trust you place in us. This policy is designed to provide complete transparency into how we collect, process, and protect your information, and to make clear that your data is used solely to improve your advertising performance. Nothing else.

Section 1: Data Collection and Purpose

1.1  Ad Platform Data

When you connect your Meta Ads account to AskRocco, we collect historical ad data going back up to two years across your entire account. This includes, but is not limited to:

• Campaign performance metrics
• Ad spend data
• Click-through rates
• Conversion data
• Audience targeting information
• Creative-level performance metrics (e.g. CTR, frequency, and engagement by individual ad)

Purpose: This data allows us to provide accurate, personalized recommendations and optimize your campaigns over time. Longer historical windows produce sharper analysis.

1.2  Tech Provider Status

AskRocco operates as a Technology Provider under Meta's Platform Terms. This means AskRocco accesses Meta Platform Data on behalf of you, the client, and solely for your benefit and at your direction. We do not use your Meta Platform Data for our own independent purposes or for the benefit of any other client.

AskRocco accesses your Meta Ads data exclusively through the official Meta Business API under permissions you explicitly grant via OAuth. We do not access any Meta data beyond the advertising scopes you authorize, and our use of Meta platform data complies fully with Meta's Platform Terms (last updated February 3, 2026) and Developer Policies.

Important: AskRocco never accesses your personal Facebook or Instagram profile data. Our API access is scoped strictly to your ad account performance data and nothing beyond it.

1.3  Conversation History

We store the conversation history between you and Rocco within the App. This includes queries, responses, and any information shared during interactions.

Purpose: Storing this history allows Rocco to provide a more personalized experience, improve the accuracy of AI responses, and give you continuity across sessions.

1.4  Organization Information

To enable team access, we collect basic organizational metadata including user IDs, emails, and roles associated with connected ad accounts.

Purpose: This information is used solely to manage access permissions and ensure only authorized team members can view and interact with your advertising data. Each client's data is maintained separately and is never commingled with data from other accounts.

1.5  Usage Data

We collect data on how you interact with AskRocco, including features used and frequency of use.

Purpose: This helps us understand how the product is being used, identify areas for improvement, communicate with you regarding your usage, develop features that better serve your needs.

Section 2: Prohibited Uses of Platform Data

In compliance with third party platform terms, AskRocco does not, and you may not instruct AskRocco to, use platform data for any of the following purposes:

• To discriminate or encourage discrimination against people based on personal attributes including race, ethnicity, color, national origin, religion, age, sex, sexual orientation, gender identity, family status, disability, or medical condition
• To make eligibility determinations about people, including for housing, employment, insurance, education, credit, or government benefits
• To perform, facilitate, or provide tools for surveillance of any kind
• To sell, license, or purchase Platform Data
• To build or augment user profiles without valid user consent
• To attempt to re-identify, de-anonymize, or reverse-engineer any anonymized or aggregated Platform Data
• For any purpose other than optimizing and managing your own Meta Ads campaigns through AskRocco

Section 3: Data Processing and Usage

3.1  Personalization and Optimization

Your data is processed to provide personalized insights, recommendations, and AI-powered responses tailored to your specific advertising account. This processing is automatic and designed to help you make faster, more informed decisions about your campaigns.

3.2  Performance Improvement

We analyze aggregated, anonymized data to identify trends and improve our services. This analysis is performed at a macro level and does not involve examining individual account details.

3.3  Feature Development

Usage data and feedback guide the development of new features and improvements, ensuring AskRocco continues to meet the evolving needs of digital marketers and agencies.

Section 4: Data Protection and Security

4.1  Access Controls

We implement strict access controls and authentication procedures for our staff. Only authorized personnel with a legitimate need to access your data are granted permission. We do not separately request or collect Meta user login credentials.

4.2  Regular Audits

We conduct regular security audits and vulnerability assessments to ensure the ongoing protection of your data.

4.3  Data Isolation

Your data is logically isolated from other clients' data to prevent any potential data leakage or cross-contamination between accounts. This isolation is a requirement under Meta's Platform Terms for Technology Providers.

4.4  Meta Audit Rights

As a Technology Provider operating under Meta's Platform Terms, AskRocco may be subject to review, monitoring, or audit by Meta or its designated third-party auditors to verify compliance with Meta's Platform Terms and data security requirements. By using AskRocco, you acknowledge that such reviews may occur and that AskRocco is obligated to cooperate with them.

Section 5: Data Retention and Deletion

5.1  Retention Period

We retain your data for as long as your account is active or as needed to provide our services. Specifically:

• Ad performance data is retained for up to 24 months from the date of collection
• Conversation history is retained for up to 12 months
• Organization and access data is retained for the duration of your active subscription

5.2  Mandatory Deletion Triggers

In compliance with Meta's Platform Terms, we will delete your Meta Platform Data promptly in any of the following circumstances:

• You request deletion of your account or your data
• Retaining the data is no longer necessary for a legitimate business purpose consistent with these policies
• You cease using AskRocco or your account is terminated
• Meta requests deletion of Platform Data for the protection of users
• Required by applicable law or regulation

To request deletion, contact us at privacy@askrocco.ai. We will also provide users with an in-app mechanism to request data modification or deletion.

Some anonymized, aggregated data may be retained for analytical purposes, but this data cannot be traced back to your individual account in any way.

Section 6: Third-Party Access and Sharing

6.1  No Data Selling

We do not sell, license, or share your Meta Platform Data, company name, user information, or individual ad account data with third parties under any circumstances. This prohibition is absolute and extends to any form of monetization of Platform Data.

6.2  Service Providers

We may share limited Platform Data with our service providers (such as cloud hosting or infrastructure providers) solely to the extent necessary for them to provide services to us on your behalf. Any such service provider is contractually prohibited from using your data for their own purposes or for any purpose inconsistent with Meta's Platform Terms.

6.3  Aggregated Insights

We may use anonymized, aggregated data for internal analysis and service improvement. This data is stripped of all identifying information and cannot be traced back to individual users, companies, or accounts.

6.4  Legal Requirements

We may disclose data if required to do so by applicable law, court order, or governmental authority. We will retain proof of any such legal requirement and, where permitted, notify you before complying.

Section 7: Transparency and Your Rights

7.1  Data Access

You have the right to request access to the data we hold about your account.

7.2  Data Correction

If you believe any data we hold is inaccurate, you can request corrections at any time by contacting our team.

Section 8: International Data Transfers

As we operate primarily within the United States, your data may be stored and processed in the United States. For users whose data originates in the European Economic Area (EEA) or the United Kingdom, such transfers are subject to applicable data transfer frameworks including the EU Standard Contractual Clauses and the UK International Data Transfer Addendum, consistent with Meta's Platform Terms. We ensure that appropriate safeguards are in place to protect your information in all cases.

Section 9: Continuous Improvement

We are committed to continuously improving our data handling practices. We regularly review and update this policy to ensure alignment with industry best practices, evolving data protection regulations, and Meta's Platform Terms.

When material changes are made to this policy, we will notify active users via email or in-app notification prior to the changes taking effect.

Section 10: Contact and Support

If you have any questions, concerns, or requests regarding this Data Handling Policy or your data, please contact our data protection team:

Ajungo Holdings LLC

216 Midland Ave, Ste. 2

Wayne, PA 19087

United States

Email: privacy@askrocco.ai

By using AskRocco, you acknowledge that you have read, understood, and agree to this Data Handling Policy. We are committed to maintaining your trust by protecting your data and using it responsibly.