Privacy Policy

1.The controller

• Controller: Kiss Industries
• Legal form: Einzelfirma
• Registered office: Sundgauerstrasse 5, CH-4055 Basel, Switzerland
• UID (Swiss business identification number): CHE-356.644.168
• Registering authority: the business identification number register (UID Register) kept by the Swiss Federal Statistical Office
• Website: postemi.com and posty.hu
• Contact for data protection matters: [email protected]

1.1. EU representative (Article 27 GDPR)

Data subjects in the EU and EU supervisory authorities may, in addition to or instead of the controller, contact the following representative in Hungary on matters relating to data processing:

• AGRO-TÚR Mezőgazdasági Termelő, Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (AGRO-TÚR Kft.)
• Registered office and postal address: 5400 Mezőtúr, Felsőrészinyomás 105., Hungary
• Company registration number: 16-09-001984
• Tax number: 10688003-2-16

In this capacity AGRO-TÚR Kft. is a point of contact. It does not become a controller, processor or data protection officer of Postemi; Kiss Industries remains responsible for the lawfulness of processing and for handling data subject requests.

2.Data processed and purposes of processing

2.1. Account data

At registration and while you use the account, we process your name, email address, password (only in encrypted, irreversible form), your account settings, the time of registration, the version of the legal documents you accepted, and (if you use team features) the names and email addresses of invited team members. Purpose: providing the Service, identifying the account and keeping in contact. Retention period: up to 30 days after the account is deleted; when the subscription ends, we keep the account content in restricted form for up to 180 days so that the account can be reactivated, and then delete it. The system checks and reports the expiry of the 180 day period daily, but the final deletion is currently not automatic: a member of our staff carries it out after checking the report, in a supervised process. Deletion from our live systems happens immediately, and from backups, because backups are kept for 30 days, within 30 days at the latest (see Section 7).

If you invite a team member, we keep a record of the invitation: the invitee's email address, the role offered, the workspace, who sent the invitation, when, how long it is valid, and whether it was accepted or revoked. This is needed so that the invitation can be revoked and the history of access to the workspace can be checked later, and so that we can send a reminder about an invitation that has not been accepted. Legal basis: Article 6(1)(b) GDPR, performance of the contract with the inviting workspace, and Article 6(1)(f), legitimate interest in being able to check access. Retention period: up to 90 days from the acceptance, revocation or expiry of the invitation; the system does not delete a pending invitation. If you do not want to join, simply ignore the email: the invitation expires on its own.

2.2. Connected social accounts

When you connect a social account (for example a Facebook Page, an Instagram account, a TikTok or LinkedIn account, or a YouTube channel) to Postemi, we store the access token issued by the platform and the basic data of the social account (name, identifier, profile picture). For integrations that use direct authentication, such as Bluesky, we may also process an app password created specifically for this purpose; we do not ask for your normal account password. Access and refresh tokens are stored in the database with application level AES-256-GCM encryption, and other integration credentials (for example the app password) are also stored encrypted; a one time migration of records stored before encryption was introduced is in progress. We use this data solely to publish posts in your name, on your instruction, and to retrieve analytics data. If you remove a social account from Postemi, we delete the associated access and refresh token. We also delete them if the permission granted on the platform ends or becomes permanently invalid. If the connection is interrupted only for a temporary technical reason, we may keep the credentials so that the connection can be restored. This restorability rule does not apply to data belonging to a permission revoked on YouTube; the separate deletion rules in Section 2.2.1 below apply to that data.

2.2.1. YouTube API Services

Postemi uses YouTube API Services to provide its YouTube features. A YouTube channel is connected through the Google OAuth 2.0 authorization flow; Postemi does not ask for or learn the password of your Google or YouTube account. Postemi accesses data only within the scope of the permissions you have approved.

• Connection and identification data: basic profile data of the Google account (identifier, name and profile picture), the permissions granted, the OAuth access and refresh token, and the identifier, name and profile picture of the selected YouTube channel.
• Publishing data: the video and optional thumbnail you upload, and the title, description, tags, visibility setting, made for kids designation and scheduled publication time you specify.
• Analytics data: performance data that YouTube makes available for the channel and the videos you manage, for example views, likes, comments, watch time, average view duration and subscriber changes. Postemi does not write this data to its database: we request it from YouTube when you open the analytics view and keep it for at most one hour in a temporary cache, so that it does not have to be requested again on every screen refresh. After one hour the data disappears on its own.

We use this data solely to identify the selected channel, to carry out the video upload or scheduled publication you requested, to set the optional thumbnail, and to display the analytics of your own channel and videos. Postemi does not sell data obtained through YouTube API Services, does not use it for advertising profiling, and does not make it available to other users, except to the workspace members to whom you have given access to the workspace concerned. The publishing operation and its settings are always initiated by you or by a workspace member you have authorized.

We do not use user data obtained through the YouTube Data API and the YouTube Analytics API, or from Google APIs in general, to develop, improve or train any artificial intelligence or machine learning model, and we do not transfer it for that purpose. We also do not use this data for targeted or personalized advertising, for determining creditworthiness, or for building databases. In any case, Postemi's own text and image generation AI feature is switched off (see Section 2.8). Postemi's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The full text of the policy is available at Google API Services User Data Policy. We transfer Google user data only to the processors needed to provide the prominent user facing features described in this Section, as set out in Section 5 of this policy; they may not use the data for their own purposes.

There are two ways in which data of the connected social accounts and your posts can leave Postemi, and you must switch on each of them yourself. One is the webhook: if you specify your own web address in the workspace, after a post is published Postemi sends to that address the post's identifier, full text, time of publication, status and the link to the published post (for YouTube, the video title), as well as the identifier, name, profile picture and type of the social account used for publishing and the platform identifier. The other is the public REST API and the MCP server: with an API key you issue, the data of your social accounts, your posts and platform analytics, including data from the YouTube Analytics API, can be retrieved within the permissions of the key. You create the key in the settings, you set its permissions and which social accounts it applies to, and you can revoke it at any time; you can likewise delete the webhook at any time. In these cases the data goes to the recipient you have chosen, for whom Postemi is not responsible. We do not sell this data and do not give it to any third party for that party's own purposes; it reaches the recipient you designate through the two routes above only on the basis of your express setting.

Google processes your data in accordance with its own Privacy Policy. The YouTube Terms of Service also apply to the use of the YouTube features.

You can remove the YouTube channel in Postemi at any time, on the Accounts screen. We then delete the Google OAuth access and refresh token stored with us, and future scheduled YouTube publications cannot be carried out. If this was the last connected YouTube channel of that Google account in the workspace, Postemi also revokes the permission with Google itself through Google's revocation endpoint. The same happens if the permission ends on its own or becomes permanently invalid: we delete the associated tokens. Independently of this, you can revoke Postemi's access to Google data at any time directly on the Google Account permissions page.

We delete the OAuth tokens and the data obtained from the YouTube API that belong to a revoked or ended permission from our active systems without undue delay, and at the latest within 7 days of the revocation. For YouTube channels that remain connected, we request the profile data obtained from the YouTube API (the channel name and profile picture) from YouTube again every 7 days; if the refresh persistently fails because the permission has ended, this data is deleted automatically after 25 days at the latest. Deleted data may remain in the separate, encrypted backups until the end of the normal backup cycle of up to 30 days; we do not restore it from there to active use. A video already published on YouTube remains on YouTube after the channel is disconnected and can be deleted there. The data deletion guide describes the detailed steps.

2.2.2. Privacy policies of the connectable platforms

When you connect a social media account or publish content, the selected platform also processes the data transmitted to it under its own terms and privacy policy. The official privacy policies of the platforms supported by Postemi:

• Meta Privacy Policy (Facebook, Instagram and Threads)
• TikTok Privacy Policy
• LinkedIn Privacy Policy
• X Privacy Policy
• Google Privacy Policy (YouTube and Google Business Profile)
• Pinterest Privacy Policy
• Bluesky Privacy Policy
• Discord Privacy Policy
• Telegram Privacy Policy
• Slack Privacy Policy

We recommend that you also read these policies before connecting an account. Postemi does not control the platforms' own policies or their processing of data.

2.3. Post content and media files

We store the text, images and videos of the posts written, scheduled or published in Postemi, and the files uploaded to the media library, in order to provide the Service. You own this content; we process it solely to make publishing and editing possible. After the subscription ends, we keep it for up to 180 days so that the account can be reactivated; we delete it when the account is finally deleted or at the end of the retention period, in the supervised process described in Section 2.1. Copies in backups cease to exist when the 30 day retention period of the backup expires.

2.4. Shared previews and comments

If you create a share link, a preview of the selected post becomes available, through a link containing an unlisted, hard to guess identifier, to the people you share the link with. The link does not appear in the public search of the Service, and we also technically ask search engines not to index it. However, anyone holding the link can forward it, so share only content that the recipients may see.

We store the content of comments on the preview, the identifier of the commenter's account and the timestamps. On the preview, numbered, pseudonymized labels are shown instead of the commenters' names. Currently only a signed in user can comment; viewing the preview does not require signing in.

2.5. Billing data

For a subscription, we process the billing name, address and (for a company) the tax number. Bank card data is handled not by us but by the payment provider Stripe; Postemi never sees or stores your card number. We keep invoices and billing data for 8 years under Hungarian Act C of 2000 on Accounting.

2.6. Technical and log data

To operate the Service securely, we process the time of sign ins, the IP address and data about the browser used. Purpose: troubleshooting and preventing abuse. Retention period: up to 12 months.

Within this, we make a separate entry for every successful sign in: the time of the sign in, the IP address, the browser identifier (user agent) and which sign in method you used. No such entry is made for failed attempts. This is needed so that we can tell a sign in from your usual device apart from one coming from an unknown device, and alert you if someone signs in to your account from a device we have not seen before; for sign in with an email code, this is the most important protection against your mailbox being compromised. Legal basis: Article 6(1)(f) GDPR, legitimate interest in the security of your account and of the Service. Retention period: up to 180 days, after which the entries are deleted automatically by a process that runs daily. We do not perform geolocation, and we do not pass your IP address to any external provider for this purpose.

We also keep a record of which reminder or information email we sent, when and to which address. Its only purpose is to make sure you do not receive the same email twice. We do not store content, only the type of email, the recipient's email address and the time. Retention period: up to 400 days.

2.7. Customer service requests

If you use the help request form, we process the name and email address you provide, the topic you choose and the text of your message, and to filter out abuse we also store the IP address of the submission and your browser identifier. No account is needed.

The following happens with the request. Based on the email address, we check whether an account belongs to it and, if so, attach some account data to the request (the date of registration, the subscription plan and its status, the trial, whether there is lifetime access and whether there has been a cancellation, the number of connected social accounts and workspaces, and the highest role) so that we can reply in substance. The names of your social accounts, the name of your workspace and the content of your posts are not included. We then send the message, together with the name, email address, topic and the account data above, to an OpenAI language model for automatic classification, which returns a category, urgency, summary and suggested reply. The request, supplemented in this way, then reaches customer service by email through the Resend service. The reply is always written and sent by a human; no automated decision is made on the basis of the model's classification.

We delete the request from the customer service database 30 days after receipt. The copy created in the email correspondence may be kept until the matter is closed or for as long as a legal claim exists. If you have an account and delete it, the related requests are deleted with it. If you do not want your message to go through automatic classification, write directly to [email protected].

2.8. Artificial intelligence features

Postemi currently does not offer its own text or image generation AI feature. The AI copywriter, the AI image generator and the AI agent are switched off, and their endpoints do not work. The post text typed into the editor and the images uploaded to the media library are therefore not sent to an AI provider to create content from them or on your behalf. There are two features that nevertheless call an external AI provider, OpenAI, and there is a third case in which you yourself connect your own AI agent to Postemi. The three paragraphs below describe these three.

Automatic posting from a source (autopost). This feature is available in the paid plans (Pro, Creator, Team) and starts only if you yourself create an autopost rule and specify the source: an RSS feed or a web address. If you switch on text or image generation in the rule, Postemi sends the text read from the source (the content of the RSS item, or the text of the specified page) to OpenAI and receives back the suggested text of the post or the generated image. Only this source text reaches OpenAI: the names of your social accounts, your account and billing data, and your other posts do not. You can switch off or delete the autopost rule at any time, and generation can be switched off separately for each rule. Postemi stores the generated image without re-encoding the bytes of the original file, so the machine readable provenance marking embedded by the provider (C2PA Content Credentials, SynthID) is not lost. Also pay attention to labeling AI generated content when publishing; see Section 13 of the Terms of Service.

Classification of customer service messages. A message received through the help request form is sent to an OpenAI language model for automatic classification. What reaches it: the text of the message, the name and email address provided, the topic chosen, and, if an account belongs to the email address, some of its status and count data (the date of registration, the subscription plan and its status, the trial, whether there is lifetime access and whether there has been a cancellation, the number of connected social accounts and workspaces, and your highest role). The names of your social accounts, the name of your workspace and the content of your posts are not included. No automated decision is made on the basis of the classification; the reply is written by a human. Section 2.7 describes the details and how you can opt out of this.

Your own AI agent (MCP and public API). The platform also operates an MCP server and a public REST API, to which you can connect your own AI agent, for example ChatGPT, Claude or Codex. This is your decision and your setting: you have to create the connection, and issue the API key yourself on the Developers tab of the settings. Once you have done so, the agent retrieves the data stored in Postemi to the extent of the permission it has been given, and what it retrieves reaches the AI provider that operates the agent. In this relationship, that AI provider is your processor, not ours: the legal relationship with it is governed by its terms, and Postemi cannot restrict what it does with the data. Postemi does not initiate this transfer and does not use it for its own purposes.

• Through the MCP server the following is available: the name of the workspace, the server clock and the configured time zone; the name, @handle, profile picture, platform and status of the connected social accounts; the names of client groups; and the list of scheduled and already published posts, that is, time, status, the beginning of the post text, the link to the published post and the error message. The agent can also create, edit and delete posts. Image generation is not available through MCP.
• Through the public REST API the same is available, and, depending on the permissions of the key you issued, the platform analytics of your social accounts, including data from the YouTube Analytics API, and the statistics of individual posts. When issuing the key, you decide which permissions (for example reading analytics) and which social accounts you allow it, and you can revoke the key at any time.

For OpenAI's business API service, inputs and outputs are not used for model training by default. Postemi itself does not develop, improve or train any AI or machine learning model with your user data, and does not transfer it for that purpose. This expressly applies to data obtained from Google APIs, including the YouTube Data API and the YouTube Analytics API. If your own AI agent retrieves data through MCP or the API, it does so on your instruction; in that case the processing by the agent's provider applies.

2.9. Waitlist and marketing messages

When you sign up for the waitlist, we process your email address and the time of sign up so that we can send you an invitation. At registration, when confirming the email code, or later in the Profile settings, you can ask for product news and tips with a separate, voluntary checkbox that is unchecked by default. We record the time, source and version of the consent as evidence. Product news is sent through the newsletter provider Beehiiv: if you consent, your email address and the consent data also reach Beehiiv. You can withdraw your consent at any time in the Profile settings, or unsubscribe using the unsubscribe link at the bottom of the newsletters sent by Beehiiv. If we let you in from the waitlist, we also record when we did so, so that you do not receive an invitation twice. The Service's own system messages, for example the sign in code, password reset, billing and security notifications, relate to the performance of the contract or to a legal obligation, so they do not contain an unsubscribe link and cannot be switched off in the account settings; they stop when the account ends. Notifications about the success or failure of posts and reminders, by contrast, can be switched off in the Profile settings. An unused waitlist entry is kept for up to 24 months.

2.10. Withdrawal statements

We process the name, email address, order reference, contract date, statement, IP address and browser identifier given through the online withdrawal page in order to identify the request, fulfill it and be able to prove it legally. The statement receives a unique reference number; we keep the evidence until the limitation period of the related claims expires. Deleting your account does not affect this statement: we keep it as legal evidence until the end of the limitation period above even if you have deleted your account in the meantime.

2.11. Source of the data, whether providing it is required, and automated decision making

As a rule, we receive the data directly from you. The connected platforms transmit channel, profile, post and analytics data within the scope of the permissions approved. If you are invited as a team member, the source of your name and email address is the inviting organization. Stripe/Link informs us about the status of the payment and the data of the payment receipt.

The data marked as needed for creating the account, signing in securely, connecting the selected channel and performing the subscription is required for contractual or technical reasons; without it the feature concerned cannot be provided. Marketing consent and accepting non essential cookies are voluntary, and refusing them has no disadvantage.

Postemi does not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you, and does not carry out profiling for such purposes. The customer service artificial intelligence only produces a classification and a suggested reply; the reply is sent by a human.

Retention periods at a glance

This table summarizes the retention periods set out in Sections 2.1 to 2.10. If there is any difference, the text of those Sections applies.

3.Controller and processor roles

Kiss Industries acts as an independent controller with respect to the account, the contract, payment status, security logs, consents, customer service and the platform's own product analytics.

If a business customer processes its own or its client's social content, media files, AI inputs, shared previews or comments on them in Postemi, the purpose of the processing is determined by the customer; for these operations Kiss Industries is usually a processor. The terms of such processing are set out in the Data Processing Agreement (Article 28 GDPR), which forms part of the Terms of Service. Such a customer is responsible for the appropriate legal basis and for informing data subjects. In private consumer use there is no such underlying business controller, so Kiss Industries is the controller of the data needed to perform the contract. A social platform may act as an independent controller under its own terms with respect to the content transmitted to it.

4.Legal bases for processing

• Performance of a contract (Article 6(1)(b) GDPR): processing of account data, tokens of connected channels, post content and media files.
• Compliance with a legal obligation (Article 6(1)(c) GDPR): retention of billing data.
• Legitimate interest (Article 6(1)(f) GDPR): processing technical log data for the security of the Service, answering requests from people who contact us without an account and the related abuse filtering (Section 2.7), and proving legal claims. For a request from an existing subscriber, the legal basis is performance of the contract.
• Consent (Article 6(1)(a) GDPR): marketing communications, and non essential statistics and marketing cookies. You can withdraw your consent at any time.

5.Processors and recipients

We use the following processors to provide the Service:

We transfer your personal data to a third country only with appropriate safeguards (for example EU standard contractual clauses, the Data Privacy Framework). We do not sell your data and do not pass it to third parties for their own marketing purposes. The email addresses of people who have subscribed to product news are received only by Beehiiv, acting on our instructions, and solely for sending the newsletter.

6.Cookies

On your first visit we ask you to choose. Necessary cookies always work; analytics and marketing measurement scripts load only after your voluntary consent. "Accept all" and "Necessary only" are offered at the same level, and in the detailed settings you can decide by category.

• Cookies necessary for operation (set by us): maintaining the signed in session (auth), remembering the selected workspace (showorg), and preserving the state of the interface, for example the collapsed sidebar or the chosen calendar view. Without them, signing in and using the Service do not work.
• Bot filtering (Cloudflare Turnstile): the check on public forms may place a cookie or a similar identifier in your browser to filter out abuse.
• Partner referral and campaign source (set by us): if you arrive through a partner referral link (?ref=…), we store the signed identifier of the referral to settle the commission (posty_ref, up to 60 days). In addition, in the browser's local storage we remember the address of the first page opened, the referring page and the campaign parameter (landingUrl, referrer, utm). These entries are created for partner settlement and for looking up the circumstances in which the contract was concluded. They are created only after marketing consent: without it, neither the posty_ref cookie nor the local storage entries are created. We do not use them for ad targeting and do not pass them to third parties.
• Analytics (DataFast): visits, campaign source and product usage. Starts only after analytics consent.
• Marketing (Google/Google Tag Manager): conversion and campaign measurement. Starts only after marketing consent.

Your choice is stored by the necessary cookie posty_cookie_consent. You can change it at any time with the "Cookie settings" button at the bottom of the page; withdrawal immediately stops the loading of the tools concerned for the future. You can also delete cookies already placed in your browser separately.

7.Data security

We process your data over an encrypted connection (HTTPS), store passwords in irreversible form and store social account tokens with application level encryption (AES-256-GCM). Only those staff members and systems that need access to perform their tasks have it. In the event of a personal data breach we act in accordance with the GDPR, and if it poses a high risk to you, we also notify you directly.

A backup of the database and of the uploaded media files is made daily. The backup is encrypted on our own server before upload and kept in encrypted form in Hetzner Storage Box storage within the European Union; backups are deleted after 30 days. Therefore, if you delete your data or your account, the deletion happens immediately in our live systems, and copies in backups cease to exist within 30 days at the latest.

8.Your rights

Under the GDPR you have the right at any time:

• to request information and access to the data we process about you (Article 15 GDPR);
• to request the rectification of inaccurate data (Article 16);
• to request the erasure of your data ("right to be forgotten", Article 17);
• to request the restriction of processing (Article 18);
• to request the portability of your data in a machine readable format (Article 20);
• to object to processing based on legitimate interest (Article 21);
• to object at any time, without giving reasons, to processing for direct marketing purposes; after such an objection we no longer process your data for that purpose;
• to withdraw your consent at any time, without affecting the lawfulness of processing before the withdrawal.

You can submit your request to [email protected], and you can also start the deletion of your account in the Profile settings of the app. The Data Deletion Guide helps you step by step with deleting your account and the data of connected channels. We reply without undue delay, as a rule within one month; for complex or multiple requests this may be extended by a further two months, of which we inform you within one month.

We carry out deletion in our live systems immediately; copies in backups cease to exist when the 30 day retention period of the backups expires, within 30 days at the latest (see Section 7). Data that must be retained by law, for example accounting records (Section 2.5), and evidence needed to enforce legal claims, for example the withdrawal statement (Section 2.10), remain until the end of the retention period that applies to them despite the deletion request.

9.Minors

Postemi is a service for business purposes and may only be used by persons who are at least 18 years old. We do not knowingly collect account data from minors. If we become aware that a minor has created an account without authorization, we delete the data.

10.Remedies

If you feel that our processing infringes your rights, it is best to tell us first; we will try to resolve it quickly. You may also lodge a complaint with a supervisory authority:

• Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (FDPIC/EDÖB, Swiss Federal Data Protection and Information Commissioner): edoeb.admin.ch
• Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH, Hungarian National Authority for Data Protection and Freedom of Information)
• Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
• Postal address: 1363 Budapest, Pf. 9., Hungary
• Email: [email protected]
• Website: naih.hu

You may also go to court: at your choice, you may bring the action before the regional court (törvényszék) for your place of residence or stay.

11.Changes to this policy

We may update this policy from time to time (for example when a new processor is engaged). We notify you of material changes by email or within the application. The version in force at any time is available at postemi.com/privacy. The conditions for using the Service are set out in the Terms of Service.