For Freestar Meta Marketing API Application

Last Updated: November 17, 2025

Introduction

Publisher First, Inc. dba Freestar (“Freestar”, “we”, “our”, “us”) provides this Privacy & Data Retention Policy to describe how advertising data accessed through Meta’s Marketing API is collected, used, stored, and retained by the Freestar Meta Marketing API application.

This internal application retrieves advertising creative content and campaign metadata from Freestar’s Meta advertising accounts. It is not consumer-facing and does not collect personal information from end users.

This policy applies exclusively to the Freestar Meta Marketing API application and is separate from:

  • Freestar Corporate Privacy Policy: https://freestar.com/privacy-policy/
  • Freestar Data Processing Agreement: https://freestar.com/data-processing-agreement/
  • Privacy policies governing Freestar-owned consumer-facing websites 

1. Purpose of the Application

The Freestar Meta Marketing API application is used solely by authorized Freestar personnel to retrieve, store, and manage advertising creative content and campaign metadata from Meta. This tool supports compliance, auditing, historical reference, and related-search-on-content requirements for Freestar’s advertising operations.

The application does not interact with end users.

2. Meta Permissions Used

ads_read

Used to access advertising creative content, campaign metadata, and performance insights required for compliance, auditing, and reporting.

ads_management

Used to access advertising account structure and ad status information necessary to determine lifecycle and retention requirements.

The application does not publish or modify ads.

 

3. Information Collected Through the Meta API

Advertising Creative Content

Primary text, Headlines, Descriptions, Image URLs, Video URLs, Call-to-action types, Dynamic creative variations

 

Campaign & Ad Set Metadata

Campaign and ad set names, Objectives and optimization goals, Budgets and billing events, Delivery status and timestamps, Scheduling information

 

Performance Insights

Spend, Impressions, Clicks, High-level performance analytics

 

Information Not Collected

The application does not collect: Personal information about end users, Device identifiers, Behavioral or browsing data, Cookie or tracking data, Personal data from Freestar-owned websites

 

4. Use of Advertising Data

Advertising data accessed through the Meta API is used to:

  • Retrieve and store current and historical ad creative content
  • Maintain compliance with platform and advertising requirements
  • Support auditing and historical reference needs
  • Maintain accurate records of advertising creative used on Freestar-owned properties

Advertising data is not used for targeting, profiling, or advertising purposes outside the stated functions. Advertising data is only used for the stated internal functions and is prohibited from being combined with any third-party or internal personal information/PII datasets in a manner that would lead to the identification of an end user. Use of this data is subject to and governed by the Meta Platform Terms and Developer Policies. 

5. Data Sharing

Freestar does not sell Meta advertising data.

Freestar shares advertising data only under the following circumstances:

  • When required by law, regulation, or legal process
  • With secure infrastructure or service providers supporting the storage and operational functionality of this internal Meta Marketing API application 
  • When required for compliance or security purposes

All service providers are bound by confidentiality and security obligations.

6. Data Retention

Active Ads

  • Retained for as long as the ad remains active (ACTIVE, PAUSED, PENDING_REVIEW)
  • Creative content refreshed daily 

Inactive Ads

  • Retained for 90 days after an ad becomes inactive (ARCHIVED, DELETED, DISAPPROVED). The 90 day retention clock commences on the date the ad status is recorded as moving into any of these inactive states.

Performance Insights

  • Retained for 90 days from collection

Backups

  • Retained for 30 days
  • Follow the same deletion protocols

Deletion Processes

  • Automated deletion for data exceeding retention windows
  • Manual deletion requests processed within 30 days
  • Deletions logged for audit purposes

Legal Hold

Data may be retained longer if subject to legal obligation.

7. Security and Access Controls

Freestar employs technical and organizational measures to protect advertising data, including:

  • Encryption in transit and at rest
  • Role-based access control
  • Logging and monitoring
  • Restricted access to authorized personnel only
  • Regular audits to verify accuracy and security

External contractors are not granted access unless explicitly authorized and bound to confidentiality.

8. Definitions

Advertising Data – Creative assets, campaign metadata, and performance insights retrieved from Meta’s API.

Active Ads – Ads with ACTIVE, PAUSED, or PENDING_REVIEW status.

Inactive Ads – Ads with ARCHIVED, DELETED, or DISAPPROVED status.

Performance Insights – Aggregated analytics describing advertising performance.

Freestar-Owned Websites – Any domain or property owned or operated by Freestar.

9. GDPR, CCPA, and Other Regulatory Considerations

The Freestar Meta Marketing API application retrieves only advertising creative content, campaign metadata, and aggregated performance insights. It does not collect or process personal data.

Freestar maintains organizational privacy, retention, and data governance practices consistent with applicable regulatory expectations for its broader business operations.

Freestar’s general Data Processing Agreement is publicly available at:

https://freestar.com/data-processing-agreement/

A separate DPA is not required for this Meta App because it does not process personal data.

10. Requests and Account Controls

Because the application retrieves data exclusively from Freestar’s own advertising accounts, Freestar manages:

  • Removal of stored advertising data
  • Revocation of Meta API credentials
  • Internal access modifications
  • Manual deletion or correction of stored advertising data

These actions are performed by authorized Freestar personnel as part of internal governance.

11. Policy Updates

This policy may be updated to reflect changes to legal requirements, Meta platform rules, or internal practices. The “Last Updated” date will be updated accordingly.

12. Contact Information

Data Privacy Officer

Publisher First, Inc. dba Freestar

20715 N. Pima Rd., Suite 108

Scottsdale, AZ 85255

Email: legal@freestar.com