1. Purpose and scope of this User Data Deletion Policy
This User Data Deletion Policy (the “Deletion Policy”) describes how ENSO MKTG LLC, a company registered in the United States and operator of the Portal Orange platform (collectively, “Portal Orange”, “we”, or “the Platform”), handles requests for the deletion of personal data related to the use of our applications and connections with third-party social networks, including platforms belonging to Meta (Facebook and Instagram), TikTok, and other social networks that we may integrate in the future.
This Deletion Policy applies specifically to:
- The data that Portal Orange stores and processes when a user connects their social media accounts or assets (for example, Facebook pages, Instagram accounts, or other third-party networks) with the Platform through the “Connect Social Media” module, accessible from the Connections section within the application (https://app.portalorange.com/connections or another equivalent URL).
- The personal data linked to the user’s account on Portal Orange when they request the closure of their account or the deletion of their data.
This Deletion Policy complements, and does not replace, our Privacy Policy and our Terms and Conditions of Use. In the event of a conflict, those documents will prevail to the extent that they are more specific or required by applicable law.
It is important to keep in mind that:
- Portal Orange can only delete the data that is under our control and hosted in our systems.
- Information that remains stored by third-party social networks (for example, in the user’s own Facebook, Instagram, TikTok, or other platform accounts) will be governed by the data deletion policies and mechanisms of each platform, which are independent of Portal Orange.
By using Portal Orange and connecting their social networks, the user accepts the terms of this Deletion Policy, without prejudice to the rights they have under applicable data protection legislation.
2. Types of data covered by deletion in social media connections
When a user connects social media accounts or assets (for example, a Facebook page, an Instagram account, or a TikTok account) with Portal Orange through the “Connect Social Media” module, Portal Orange may process and store, among others, the following types of data (“Social Media Data”):
2.1. Connection data with social media accounts and assets
For the sole purpose of enabling the scheduling, management, and publishing of content from Portal Orange to Facebook, Instagram, and TikTok, we may store:
- Technical identifiers of the connected assets, such as:
- Facebook page ID.
- Instagram account ID (including professional or creator accounts).
- TikTok account identifier.
- Basic information associated with those assets, such as:
- Display name of the page or account.
- Username and, where applicable, profile image provided by the API.
- Information about the permissions granted to Portal Orange through each social network.
- Access tokens needed to operate the integration (for example, page access tokens, user access tokens, or long-lived tokens), as well as the creation, renewal, or expiration date of those tokens. In the case of TikTok, authorization expires after a maximum of 365 days from when it was granted, after which the user must reconnect the account.
This data is used exclusively to authenticate the connection between Portal Orange and the corresponding social network’s services, and to allow the user to manage their content from the Platform.
2.2. Content data linked to social media accounts*
When using Portal Orange to create, schedule, review, publish, or record the result of content intended for Facebook, Instagram, or TikTok, we may process and store:
- Post texts (copy), scripts, descriptions, and titles.
- Media files and their references (images, videos, or other formats supported by the Platform).
- Operational information about the posts, such as:
- Scheduling date and time.
- Social network and account each piece of content is directed to.
- Status of the content within Portal Orange (for example, draft, in review, scheduled, published, failed, etc.).
- Technical and error records related to the actions carried out through the social networks’ APIs (for example, error messages returned by the platform, status codes, or publishing attempts).
To the extent that Portal Orange implements statistics or analytics features, performance metrics associated with published content (for example, number of interactions, reach, clicks, or similar) may also be processed, always in accordance with the features offered by the Platform and by each social network.
2.3. Portal Orange account data related to the connected social networks
Additionally, in order to link the Social Media Data with the corresponding user, Portal Orange processes certain data from the user’s account, such as:
- Name and email address used on Portal Orange.
- Information about the brands, spaces, and roles that the user administers within the Platform.
- Billing information necessary for the management of the subscription, where applicable.
Portal Orange does not store full payment card data. Payment processing is carried out through specialized payment service providers (such as, for example, Stripe), which act with their own security measures and in accordance with their own data protection regulations.
2.4. Backups and records
For reasons of security, business continuity, and the prevention of fraud or abuse, Portal Orange may keep:
- Backups of its database, which may include Social Media Data and account data already deleted from the active systems.
- Technical records (logs) necessary to ensure the secure and correct operation of the Platform.
Data deleted in accordance with this Policy will be removed from the active systems and, where applicable, will be permanently deleted from backups within a maximum period of 90 days, in accordance with our internal backup cycles.
3. Scenarios and procedure for deleting data linked to connected social networks *
Portal Orange contemplates different scenarios in which the total or partial deletion of data related to the integration with third-party social networks (Facebook, Instagram, and TikTok) may occur. The following describes what happens in each case and what steps the user must follow.
3.1. Voluntary disconnection from Portal Orange
The user can disconnect their social media accounts (for example, a Facebook page, an Instagram account, or a TikTok account) at any time from the Connections module within the Platform (https://app.portalorange.com/connections or another equivalent URL), using the “Disconnect” button.
When the user disconnects a social media account from Portal Orange:
- The following are deleted from our systems:
- The access tokens associated with that asset.
- The technical identifiers necessary to operate the connection (for example, page ID or connected account ID) to the extent that they are no longer necessary for the legitimate purposes described in our Privacy Policy.
- The ability to create, schedule, or publish new content to that account from Portal Orange is disabled.
- Content already created or scheduled in Portal Orange that was linked to that asset may:
- Remain recorded within the Platform as part of the user’s work history (copy, files, internal statuses, etc.), but
- Will no longer be re-attempted for publishing once the connection is disconnected or without valid permissions.
Disconnecting from Portal Orange does not automatically delete posts that have already been published on Facebook, Instagram, or TikTok. The management of those posts must be carried out directly from the corresponding social network.
3.2. Revocation of permissions or removal of the app from the social network
If the user revokes the permissions of the Portal Orange application from the settings of Facebook, Instagram, or TikTok, or removes the application on those platforms, the social network may invalidate the access tokens provided.
In these cases, once Portal Orange detects the revocation (for example, through authentication errors returned by the social network’s APIs):
- The connection with the affected asset is internally deactivated.
- The associated access tokens are deleted or invalidated, and the processing of new data from that social network for that account ceases.
- Content already existing in Portal Orange is kept solely for history and internal management purposes, unless the user expressly requests its deletion in accordance with the following section.
- Posts already made on Facebook, Instagram, or TikTok will remain on those platforms and must be managed directly by the user from their accounts on those social networks.
3.3. Express requests for the deletion of social media data in Portal Orange
The user may expressly request the deletion of the data related to the connected social networks that Portal Orange keeps in its systems. To do so, they must send an email to:
indicating, at least:
- The email address associated with their Portal Orange account.
- The brand, space, or social media accounts for which they are requesting the deletion of data.
- A brief description of whether the request refers only to the disconnection of assets, the deletion of linked content, or the complete closure of the Portal Orange account.
After verifying the identity of the requester, Portal Orange will proceed, as appropriate, to:
- Delete the access tokens and the technical connection identifiers associated with the indicated social media accounts.
- Delete, anonymize, or dissociate the content and internal records linked exclusively to those assets, to the extent that they do not need to be kept for legal obligations, billing purposes, security, fraud prevention, or the defense of possible claims.
Portal Orange will respond to and execute the deletion request within a maximum period of 30 calendar days from its valid receipt, without prejudice to the fact that, in complex cases, that period may be extended when permitted by applicable law, informing the user in a timely manner.
3.4. Closure and complete deletion of the Portal Orange account
The user may also request the closure and complete deletion of their Portal Orange account, which includes the processing of data linked to integrations with social networks. This request must also be made through the email:
Once the user’s identity has been verified, Portal Orange will:
- Proceed to close the account and delete or anonymize the personal data associated with it in the active systems, including social media connection data and access to the brands and spaces managed by that user, unless there are legal bases for its retention (for example, tax or accounting obligations).
- Be able to keep certain minimal and anonymized information, when necessary to:
- Comply with legal retention obligations.
- Manage possible claims, fraud, or security incidents.
- Maintain aggregated statistics that do not allow the identification of the user.
Closing the Portal Orange account does not automatically delete the posts that the user has made on Facebook, Instagram, or other third-party platforms, which must be managed directly from those social networks.
3.5. Scope of deletion and backups
In all the above scenarios, the deletion of data is initially carried out in Portal Orange’s active systems. The deleted data may temporarily remain in automated backups, but:
- It will be kept only for the time strictly necessary to comply with backup and business continuity cycles.
- It will be permanently deleted from backups within a maximum period of 90 days from its deletion in the active systems, unless applicable regulations require its retention for a longer period.
4. Users’ data protection rights
Without prejudice to the specific mechanisms described in this Deletion Policy, Portal Orange users retain, to the extent recognized by applicable law, the following rights over their personal data:
- Right of access: to know what personal data we process and to obtain a copy of it.
- Right of rectification: to request the correction of inaccurate or incomplete data.
- Right of erasure (“right to be forgotten”): to request the deletion of data when it is no longer necessary for the purposes for which it was collected, when consent is withdrawn (if applicable), or when permitted by regulations.
- Right to restriction of processing: to request that the processing of data be restricted in certain cases.
- Right to object: to object to the processing of data when it is based on legitimate interests, unless there are compelling reasons to continue the processing.
- Right to data portability: to receive personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller, when technically possible and permitted by regulations.
To exercise any of these rights, the user can contact us at:
indicating their full name, the email associated with their Portal Orange account, and the right they wish to exercise. In some cases we may require additional information to verify the identity of the requester before handling the request.
Portal Orange will handle data protection rights requests within a maximum period of 30 calendar days from their valid receipt, and this period may be extended when the complexity of the case or the volume of requests so requires, in accordance with applicable law.
When the user is in jurisdictions with specific data protection regulations (for example, the European Union or certain local laws in Latin America or the United States), they may also have additional rights or avenues for complaint before the competent authorities, which is described in greater detail in our Privacy Policy.
5. Relationship between Portal Orange and third-party platforms
Portal Orange acts as an intermediary platform that allows the user to manage content and connections with third-party social networks, but does not directly control the systems or databases of those platforms.
In particular:
- The data stored by Meta (Facebook, Instagram), TikTok, or other social networks on their own servers is governed exclusively by their privacy policies and their data deletion mechanisms, which are independent of Portal Orange.
- The deletion of data described in this Policy refers only to the data processed by Portal Orange in its own systems, in the context of the integration with those third-party services.
- Posts, comments, messages, or other content that the user has generated directly on Meta, TikTok, or other social media platforms are not automatically deleted when the user disconnects an asset, deletes their Portal Orange account, or requests the deletion of data on our Platform. The management of this content must be carried out directly from each social network.
Portal Orange is not responsible for the changes that Meta, TikTok, or other third parties may introduce in their own policies, APIs, or data deletion flows. However, we are committed to adapting our integrations and this Deletion Policy to the extent reasonably possible to comply with the requirements that those platforms establish for connected applications.
6. Updates to this Deletion Policy
Portal Orange may modify or update this Deletion Policy at any time, especially when:
- New features are introduced on the Platform or new integrations with third-party social networks.
- The applicable legal or regulatory requirements change.
- Third-party platforms (including Meta and TikTok) update their policies or conditions for connected applications.
When relevant changes occur, Portal Orange will:
- Publish the updated version on the corresponding website (for example, https://www.portalorange.com/datos-de-usuarios/), indicating the date of last update.
- Be able to inform users through reasonable means within the Platform itself or by email, when the change is significant and so required by regulations or good practice.
Continued use of Portal Orange and its integrations with social networks after the publication of a new version of this Deletion Policy will imply its acceptance, without prejudice to the user’s ability to exercise their data protection rights and, where appropriate, to choose to disconnect assets or request the deletion of their data as provided herein.
