Advertising Tools Privacy Policy

Last updated: 15 October 2026

This policy explains how Lodinos Pty Ltd, trading as TwinklingTree (“TwinklingTree”, “we”, “us”), handles data in our internal advertising tools. It covers:

  • Creative OS and the Performance Creative System, where our team prepares, approves and queues our ads;
  • the uploader, our service for sending approved ads to Meta;
  • our internal reporting dashboards, scripts and team chat bots that report on our ads; and
  • the Meta app “Performance Marketing Software” (Meta App ID 987749283702043), through which these tools connect to Meta’s Marketing API.

It does not cover our online store. For that, please see our Privacy Policy.

Who uses these tools

Only authorised TwinklingTree staff and contractors use these tools, to manage TwinklingTree’s own advertising. They are not offered to the public or to other businesses. Our Meta app does not use Facebook Login, and members of the public cannot sign in to our tools or connect their accounts to them.

What data we process

  • Our own advertising data from Meta: details of TwinklingTree’s ad accounts, campaigns, ad sets and ads; our ad creatives (images, videos, text, headlines and links); the identifiers of the Facebook Page and Instagram account we advertise from; ad review results; and performance statistics such as spend, impressions, clicks and conversions, including aggregated audience breakdowns (for example, by age range and gender).
  • People in our ads: our ad creatives can show models and creators we work with, and can quote customer reviews with the reviewer’s first name and last initial.
  • Information about our team: the names, work email addresses and roles of the people who use the tools, and a record of what they do in them (for example, who approved or launched an ad, and when).
  • Technical data: login session cookies, and server logs (such as IP address, browser type and time of access) that keep the tools working and secure.

Apart from the people in our own ads, we do not use these tools to collect, request or store personal information about individual Facebook or Instagram users. The audience statistics we receive from Meta are aggregated and do not identify anyone.

How we collect and hold it

We collect this data from Meta through its Marketing API, from the ads, files and copy our team creates, and from our team as they use the tools. We hold it in our tools’ databases and file storage, which are run by the service providers described below.

Meta permissions we use

Our Meta app uses these permissions, only for TwinklingTree’s own ad accounts, Facebook Page and Instagram account:

  • ads_management: to create our ads, ad sets and creatives. Ads our tools create start paused, and run only after a person, or an approval rule a person has set, switches them on.
  • ads_read: to read our ads’ settings, review status and results.
  • business_management: to see which ad accounts, Pages and Instagram accounts our business owns, and the access our tools have to them.
  • pages_show_list: to list the Facebook Pages our business manages, so each ad runs from the right one.
  • pages_read_engagement: to read the details of our own Page that our ads use.
  • pages_manage_ads: to create ads that run from our own Page.

How we use it

  • To prepare, check, upload, launch, pause and report on TwinklingTree’s own ads.
  • To check our ads against Meta’s Advertising Standards and the law before they run.
  • To keep an audit trail and keep our accounts secure.

We do not sell this data, and we use it only to run and measure TwinklingTree’s own advertising.

Service providers and sharing

We share this data only with service providers that run our tools for us: cloud hosting, database and file storage providers, workplace messaging, and AI services that analyse our own ads and their results, and help draft our ad copy. Each acts only on our instructions, under a written agreement, and may not use the data for its own purposes. We also share data where the law requires it. We do not share data from Meta’s platform with anyone else.

Where data is stored

Our service providers may store and process this data outside Australia, mainly in the United States. Staff and contractors who use the tools work from Australia and the Philippines.

How we protect it

  • Access is limited to authorised staff and contractors, each with their own login.
  • We keep the access tokens and app secret our tools use confidential, available only to the staff and systems that need them.
  • Ads are created by our staff in Meta Ads Manager or, once it is live, by our uploader, which uses a dedicated Meta system user with only the permissions it needs and logs every request it sends.

How long we keep it

We keep advertising records for as long as we need them to run and account for our advertising, and to meet our legal and tax obligations. We delete data from Meta’s platform when it is no longer needed, when Meta asks us to, when we receive a valid request, or when we stop using our Meta app.

Your rights and how to request deletion

If you think these tools hold personal information about you, you can ask us to access, correct or delete it. Email support@twinklingtree.com with the subject “Advertising tools data request”, and tell us what you would like us to do. We will respond within 30 days, and delete the data unless the law requires us to keep it.

Report a security problem

If you find a security vulnerability in our tools or our Meta app, please email support@twinklingtree.com with the subject “Security report”. We will look into every report promptly and fix any problem we confirm.

Complaints

If you have a concern about how we handle personal information, please email us first at support@twinklingtree.com. We will look into it and reply within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed.

Contact

Lodinos Pty Ltd, trading as TwinklingTree: Privacy Officer
223 Liverpool Street, Darlinghurst NSW 2011, Australia
support@twinklingtree.com

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