Privacy Policy

1. Who We Are

Enzango Pty Ltd (trading as Transformo) is an Australian company providing an AI-powered marketing campaign and advertising management platform. Our registered address is:

2. Information We Collect

2.1 Information You Provide Directly

• Account registration details (name, email address, password)
• Business information (company name, industry, website URL)
• Billing and payment information (processed securely by our payment provider)
• Brand voice settings, campaign content, and marketing materials you upload or create
• Communications you send us (support requests, feedback, correspondence)
• Information about your ideal customer profiles (ICPs) and offers

2.2 Information Collected Automatically

• Log data (IP address, browser type, referring URLs, pages visited, timestamps)
• Device information (hardware model, operating system, unique device identifiers)
• Usage data (features used, clicks, session duration, errors)
• Cookies and similar tracking technologies (see Section 7)

2.3 Information from Third-Party Platforms

When you connect third-party advertising or social media accounts to Transformo, we may collect information from those platforms, subject to your authorisation and their own privacy policies. This includes:

• Meta (Facebook/Instagram): Ad account IDs, campaign data, ad performance metrics, audience data, ad creative assets, and other advertising data from your connected Facebook or Instagram ad accounts (see Section 6)
• Clerk (Authentication): Authentication tokens and session data

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, maintain, and improve the Services
• Create and manage your account and subscription
• Generate AI-powered marketing content, campaign copy, and advertising materials tailored to your business
• Connect to Meta's Marketing API to create, publish, manage, and optimise advertising campaigns on your behalf or on behalf of clients whose accounts you have authorised us to access
• Retrieve and analyse ad performance analytics and reporting data to assist you in optimising campaigns
• Process payments and manage billing
• Send transactional emails, product updates, and service notifications
• Respond to support requests and communicate with you
• Monitor usage to ensure platform security and prevent fraud or abuse
• Comply with legal obligations
• Improve and develop new features through aggregate, anonymised analytics

We will not use your data (or your clients' data retrieved via Meta's API) for any purpose other than providing and improving the Services, and we will not sell your personal information or advertising data to third parties.

4. Legal Basis for Processing

We process your personal information on the following grounds:

• Contract performance: Processing necessary to deliver the Services you have subscribed to
• Legitimate interests: Improving the platform, fraud prevention, security monitoring, and analytics (where not overridden by your rights)
• Consent: Where you have explicitly authorised us to access your Meta ad accounts or receive marketing communications
• Legal obligation: Where required by Australian law or regulation

5. Disclosure of Your Information

We do not sell your personal information. We may share information with:

• Service providers: Trusted third-party vendors who assist us in operating the platform (hosting, payment processing, authentication, email delivery, analytics). These providers are contractually bound to protect your data and may only use it to provide services to us.
• Meta Platforms, Inc.: When you use our Meta Marketing API integration, data is transmitted to and from Meta's systems in accordance with Meta's own Privacy Policy and Platform Terms.
• Legal and regulatory authorities: Where required by law, court order, or government authority, or to protect the rights, property, or safety of Transformo, our users, or the public.
• Business transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your personal information is transferred and becomes subject to a different privacy policy.

6. Meta (Facebook) Marketing API — Data Use & Compliance

Transformo integrates with the Meta Marketing API to provide advertising management functionality. The following explains specifically how we handle Meta platform data:

6.1 Ad Account Access

Users may connect their own Facebook and Instagram ad accounts to the platform, and may also grant Transformo access to client ad accounts for which they hold authorised access. By connecting an ad account, you represent and warrant that:

• You have full legal authority to grant Transformo access to that ad account, whether it is your own or a client's account you manage
• You have obtained all necessary consents from any third-party account holders (including your clients) prior to connecting their accounts
• You will not use the integration in violation of Meta's Platform Terms, Advertising Policies, or applicable law

6.2 What We Access via the Meta Marketing API

• Ad account IDs, names, and configuration settings
• Campaign, ad set, and ad data (names, targeting, budgets, schedules, creative)
• Ad performance analytics and reporting metrics (impressions, clicks, spend, conversions, ROAS, and other performance indicators)
• Audience information relevant to your campaigns

6.3 How We Use Meta Platform Data

• To create, publish, modify, pause, and manage advertising campaigns on your behalf or on behalf of clients whose accounts you manage
• To retrieve performance analytics and present reporting dashboards to assist in campaign optimisation
• To generate AI-powered recommendations and insights based on campaign data

We do not use Meta platform data to target advertising to users outside of your authorised campaigns, sell it to third parties, or use it for any purpose not directly related to providing and improving the Services to you.

6.4 Data Retention and Deletion — Meta Data

Meta platform data is retained only as long as necessary to provide the Services or as required by law. When you disconnect a Meta ad account or close your Transformo account, we will delete or anonymise associated Meta platform data within 90 days, unless retention is required by applicable law. You may request earlier deletion by contacting us at marlon@enzango.com.

6.5 Meta's Own Privacy Policy

Your use of Facebook and Instagram is governed by Meta's Privacy Policy. We encourage you to review Meta's policies independently. Transformo is not responsible for Meta's data practices.

7. Cookies and Tracking Technologies

7.1 Cookies We Use

We use cookies and similar tracking technologies on our public-facing website (transformo.com). These include:

• Essential cookies: Required for the website and authenticated platform to function correctly (e.g., session management, authentication)
• Analytics cookies: Help us understand how visitors interact with our website so we can improve it
• Marketing cookies: Used to measure the effectiveness of our advertising campaigns

7.2 Facebook Pixel

We use the Meta (Facebook) Pixel on our public marketing website at transformo.com. The Facebook Pixel is a piece of code that allows us to:

• Measure the effectiveness of our own advertising on Facebook and Instagram by tracking conversions and website actions
• Build and target custom audiences for our own marketing campaigns on Meta platforms
• Improve the relevance of ads we show to prospective customers

The Facebook Pixel is only present on our public-facing marketing website (transformo.com). It is not deployed within the authenticated Transformo application.

Data collected by the Facebook Pixel is subject to Meta's Privacy Policy. You can opt out of interest-based advertising on Facebook via your Facebook account settings or through industry opt-out tools.

7.3 Managing Cookies

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of our website. Most browsers allow you to refuse cookies or to be notified before a cookie is placed.

8. Data Security

We implement industry-standard technical and organisational security measures to protect your personal information against unauthorised access, loss, destruction, alteration, or disclosure. These measures include encryption of data in transit (TLS), access controls, and regular security reviews.

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and, where required, the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

9. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Services. We may also retain certain information as required by law, to resolve disputes, enforce our agreements, or for legitimate business purposes such as fraud prevention.

When you close your account, we will delete or anonymise your personal information within 90 days, except where retention is required by law. Backup copies may be retained for a shorter period during our standard backup cycles.

10. Your Privacy Rights

Under the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate or out-of-date personal information
• Request deletion of your personal information (subject to legal retention requirements)
• Opt out of direct marketing communications at any time
• Complain about our handling of your personal information to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

To exercise any of these rights, please contact us at marlon@enzango.com. We will respond within a reasonable time, and no later than 30 days.

11. International Data Transfers

Some of our service providers are located outside Australia. Where we transfer your personal information overseas (including to the United States where Meta and other service providers operate), we take reasonable steps to ensure the recipient handles it in accordance with the Australian Privacy Principles or a comparable privacy framework. By using our Services, you consent to such transfers.

12. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a person under 18 without parental consent, we will delete it promptly.

13. Third-Party Links

Our website and platform may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this page. For material changes, we will notify you by email or by a prominent notice within the platform. Your continued use of the Services after the effective date of the updated Policy constitutes your acceptance of the changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us: