Privacy Policy

Last updated: 15 September 2026

This Privacy Policy explains how Elofey (the "Service", "we", "us"), operated by LLC "ARPHAREY", collects, uses, stores and protects personal data when you use elofey.com and our social media management and automation services, including Instagram comment automation and messaging features.

1. Data controller

The data controller is:

• Limited Liability Company "ARPHAREY" (LLC "Arpharey"; Kyrgyz: ОсОО «АРФАРЕЙ»)
• Registered address: 8 Pionerskaya St., Romanovka, Sokuluk District, Chuy Region, 724807, Kyrgyz Republic
• Taxpayer number (TIN): 01706202210346
• Email: admin@elofey.com
• Phone: +996 555 154 174; alternate: +373 69 147 445

2. Data we collect

• Account data: name, email address, username, password (hashed), timezone, billing details related to your subscription.
• Connected social accounts: for Instagram and other connected platforms we store access tokens (encrypted), profile identifiers, usernames and granted permissions, as required to provide the Service.
• Content processed for automation: comments on your connected Instagram professional account's posts, direct messages exchanged through connected accounts, automation rules, templates and their execution logs — solely to provide the features you configure.
• Usage and technical data: log records, IP address, browser type, device information and cookies (see our Cookie Policy).

3. How we use data

• To provide, operate and maintain the Service, including publishing, scheduling, comment automation and messaging features you enable.
• To authenticate you, process payments and provide customer support.
• To secure the Service, prevent abuse and comply with legal obligations.
• To send service-related communications. Marketing communications are sent only with your consent and can be opted out of at any time.

4. Legal bases

We process personal data in accordance with applicable data protection legislation (including the Law of the Kyrgyz Republic on personal data and, where applicable, the GDPR), on the following bases: performance of a contract (providing the Service), legitimate interests (security, improvement, support), compliance with legal obligations, and consent where explicitly requested (for example, marketing emails).

5. Platforms and sharing

• We use official Meta Platforms APIs (Instagram). Your use of those features is also governed by Meta's terms and policies. We access only the data covered by the permissions you grant and use it only to provide the Service.
• We do not sell personal data. Data is shared only with subprocessors required to run the Service (hosting, email delivery, payment processing) under appropriate safeguards, and with authorities where required by law.
• Automation actions (public replies, private replies, messages) are performed only under the rules you configure and within the limits of the applicable platform policies.

6. Retention

• Account data is kept while your account is active.
• Raw platform webhook payloads are retained for up to 7 days for diagnostics.
• Conversation and automation log data is retained for up to 90 days unless you configure a different period or delete it earlier.
• When you disconnect a social account, its access tokens are deleted and related automated processing stops. When you delete your account, associated personal data is deleted or anonymised; residual copies in encrypted backups expire within 30 days.

7. International transfers

Where personal data is transferred across borders (for example, API calls to Meta Platforms), we apply appropriate safeguards required by applicable law.

8. Your rights

Subject to applicable law, you have the right to access, rectify, erase, restrict or object to processing of your personal data, the right to data portability, and the right to withdraw consent at any time. To exercise these rights, contact us at admin@elofey.com or +996 555 154 174. See also our Data Deletion Instructions. You may also lodge a complaint with the competent data protection authority.

9. Security

We apply technical and organisational measures including encryption of access tokens at rest, TLS in transit, isolated processing environments, least-privilege access and audit logging. No method of transmission or storage is 100% secure; we work to protect your data and continuously improve our safeguards.

10. Children

The Service is not directed at children under 16, and we do not knowingly collect their personal data.

11. Changes

We may update this Policy. Material changes will be announced on this page with an updated revision date.

12. Contact

LLC "ARPHAREY" — 8 Pionerskaya St., Romanovka, Sokuluk District, Chuy Region, 724807, Kyrgyz Republic. Email: admin@elofey.com. Phone: +996 555 154 174; alternate: +373 69 147 445.