Privacy Policy

1. Introduction

Direct Socials, a trade name of Digital Growth Masters B.V., based in Loenen, the Netherlands, places great value on the protection of your personal data. In this privacy policy, we explain which personal data we collect, why we do so, how we use it, and with whom we share it. We also inform you about your rights and how you can exercise them.

This privacy policy applies to all services offered by Direct Socials, including our Instagram growth service and related services. By using our services, you consent to the processing of your personal data as described in this policy.

2. Data Controller

The data controller for the processing of personal data is:

3. What Personal Data Do We Collect?

Direct Socials collects and processes the following categories of personal data:

3.1 Account Information

• Name and contact details (email address, phone number)
• Company name (if applicable)
• Billing information
• Instagram username
• Instagram login credentials or access tokens (encrypted storage)

3.2 Usage Data

• IP address
• Browser type and version
• Pages visited and features used
• Date and time of visit
• Referring website

3.3 Instagram Data

• Profile information from your Instagram account
• Statistics about followers, likes and interactions
• Content published or scheduled through our service
• Audience settings and targeting parameters

3.4 Payment Information

• Payment method information (processed by our payment provider)
• Transaction data
• Billing history

3.5 Communication Data

• Correspondence via email, chat or other channels
• Feedback and reviews
• Support tickets

4. Purpose and Legal Basis of Processing

We process your personal data for the following purposes and on the following legal bases:

5. With Whom Do We Share Your Data?

Direct Socials only shares your personal data when necessary for service delivery or legally required. We share your data with:

5.1 Service Providers (Processors)

• Hosting providers: For hosting our website and application
• Payment providers: For processing payments (such as Plug & Pay)
• Email services: For sending emails and newsletters
• Analytics services: For website analytics (anonymized where possible)

All these parties are bound by processor agreements and may only process your data according to our instructions and for the agreed purposes.

5.2 Instagram / Meta

To deliver our service, we use the Instagram API and perform actions on Instagram on your behalf. Although we do not have a direct partnership with Instagram, certain data is exchanged through their platform.

5.3 Legal Obligations

We may share your data with authorities if legally required or if necessary for:

• Complying with judicial orders
• Protecting our rights and property
• Preventing fraud or abuse
• Ensuring user safety

5.4 Business Transfers

In the event of a merger, acquisition or sale of business units, your personal data may be transferred to the new owner, provided they adhere to this privacy policy or an equivalent policy.

6. International Data Transfers

We strive to process and store all your personal data within the European Economic Area (EEA). If it is necessary to process data outside the EEA, we ensure appropriate safeguards in accordance with the GDPR, such as:

• Standard Contractual Clauses (SCCs) from the European Commission
• Adequacy decision from the European Commission
• Privacy Shield certification (where applicable)

7. Retention Periods

We do not retain your personal data longer than necessary for the purposes for which they were collected, or as long as legally required:

• Account information: During the account lifetime plus 1 year after termination
• Billing information: 7 years (statutory retention requirement)
• Correspondence: Up to 2 years after last contact
• Usage data: Up to 13 months
• Marketing consent: Until withdrawal of consent or 2 years after last interaction

After the retention period, your data will be deleted or anonymized, unless a longer retention obligation applies.

8. Security of Your Data

Direct Socials takes the security of your personal data very seriously. We have implemented appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration or disclosure:

• Encryption of sensitive data (such as passwords and access tokens)
• SSL/TLS encryption for all communications
• Regular security audits and penetration tests
• Access control and authentication for employees
• Firewalls and secure servers
• Regular backups
• Confidentiality obligations for staff

Despite these measures, we cannot guarantee the absolute security of your data. We advise you to handle your login credentials carefully and not share them with others.

9. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

How can you exercise your rights?

To exercise your rights, you can submit a request via:

We will assess your request within one month and inform you of the outcome. In complex cases, we may extend this period by a maximum of two months.

To prevent abuse, we may ask you to verify your identity before we comply with your request.

10. Cookies and Tracking

Direct Socials uses cookies and similar technologies to improve our website and services. A cookie is a small text file that is stored on your device when you visit our website.

Types of cookies we use:

• Necessary cookies: These cookies are essential for the operation of the website and cannot be disabled (for example, for login functionality and security)
• Functional cookies: These cookies remember your preferences and settings
• Analytics cookies: These cookies help us understand how visitors use our website (we use anonymized data where possible)
• Marketing cookies: These cookies are used to display relevant advertisements (only with your consent)

Managing cookies

You can manage cookies through your browser settings. Note: disabling certain cookies may limit the functionality of our website.

For more information about managing cookies, consult your browser's help function or visit www.allaboutcookies.org.

11. Minors

Our services are not intended for persons under 16 years of age. We do not knowingly collect personal data from minors. If you suspect that we have accidentally collected data from a minor, please contact us at info@directsocials.nl so we can delete this data.

12. Changes to This Privacy Policy

We may update this privacy policy from time to time to comply with new legislation, new services or changes in our business operations. We recommend that you review this policy regularly.

In case of significant changes, we will notify you via email or a notice on our website. The most current version of this privacy policy can always be found on our website. The date of the last change is indicated at the top of this document.

13. Complaints and Supervisory Authority

If you are not satisfied with the way we handle your personal data, we would like to hear from you. Please contact us first at info@directsocials.nl so we can work together on a solution.

You also have the right to file a complaint with the Dutch Data Protection Authority, the Dutch supervisory authority for privacy protection:

14. Contact

Do you have questions about this privacy policy or about how we process your personal data? Please contact us:

We strive to respond to your inquiry within 48 hours.