Privacy policy

• Ember is a business tool. Agencies and advertisers connect their Meta ad accounts so Ember can report on them, recommend budget and pause decisions, and carry out the changes they approve.
• Customers can also track their funnels with Ember. That includes their leads’ contact details, bookings and sales, which we process for the customer as its processor.
• We never sell personal data or Meta Platform Data, never share it with data brokers, and never use it to train AI models. The AI providers we use may not train on it either.
• Access tokens and leads’ contact details are encrypted with AES-256-GCM.
• You can remove a Meta connection in Ember at any time, and ask us to delete all of your data. See the data deletion instructions.

Ember is operated by Talented LLC, a company in the United States. This policy covers the Ember web app, its sign-in pages, its MCP server for AI assistants, and the tracking script customers add to their own websites.

“Customer” means the agency or advertiser that uses Ember; “you” means a person who signs in to Ember or whose information we otherwise process. Our terms of service govern use of Ember, and our data processing agreement covers the data we process for customers.

From people who sign in

• Account details: your name and email address, and your password if you set one, stored only as a salted hash. Signing in with a one-time code we email to you works too; codes are stored hashed and expire after 10 minutes, and password reset links work once and expire after an hour.
• Session details: the IP address and browser of each signed-in session, to keep you signed in and protect your account.
• AI assistant connections: if you connect an assistant through MCP, its registration, the permissions you granted and the tokens it was issued.
• What you do in Ember: decisions you approve or reject, settings, launch plans, creative drafts, and the images you upload.
• Whatever you include when you email us.

From Meta

When you connect Meta, we receive an access token and the advertising data described in data from Meta.

From customers’ funnels

When a customer adds our tracking script to its website, or connects a booking tool, CRM or webhook, we collect these categories of data about its visitors and leads. New sources add to these categories, not new kinds of data:

• Contact details: email address and phone number. The script reads them from a submitted form only when the customer turns on identity capture. Booking tools, GoHighLevel and webhooks always send the booked or converted person’s email address or phone number, even with identity capture off.
• Booking details: when a call was booked and for when, the calendar, and whether the person showed, did not show, canceled, qualified or did not qualify.
• Purchase value: the revenue or deal value of a sale and its currency.
• Form answers: answers to the questions the customer chooses to track, and the properties of custom events the customer’s website sends (up to 20 short values each).
• Ad and campaign data: UTM parameters, the Meta campaign, ad set and ad IDs in the link, and Meta’s click and browser IDs (fbclid, _fbc and _fbp).
• Visit details: random visitor and session IDs, pages viewed, the referring site’s domain, form starts and submissions, the text of buttons and links clicked, scroll depth, time on page, video progress, booking calendars opened, the browser, the country, and a keyed hash of the IP address. The IP address itself is never stored.

The script adds the visitor ID to Calendly and Cal.com booking links so the booking comes back matched to the visit. It does not record keystrokes, and it reads no other form fields.

From other tools a customer connects

• Slack: the webhook and the Slack user IDs allowed to approve changes from Slack.
• GoHighLevel: the token, and the contacts, pipeline stages, appointments and deal values of the connected location.

From landing page checks

When a customer asks, Ember opens the customer’s landing pages in an automated browser to map the funnel, and keeps screenshots and notes of those pages. It submits forms only when the customer turns on test submissions for that check, and then only with obviously fake details.

To keep Ember running

Error logs, and a log of Meta API calls (time, call type, ad account, duration and Meta’s rate-limit usage). Neither contains access tokens.

We use information only to:

• provide Ember to the customer it belongs to: reports, evaluations, recommended decisions, and the changes the customer approves;
• match the customer’s leads, bookings and sales to the customer’s own Meta ads, and show the customer its lead list;
• send the alerts, reports and approval requests the customer turns on, to the customer’s Slack;
• send sign-in codes, password reset links and service messages by email;
• secure Ember, filter bot traffic, and fix problems;
• answer support and privacy requests; and
• meet legal obligations and enforce our terms.

We do not use customer data for advertising, and we never use one customer’s data for another customer.

This section covers the Meta Platform Data Ember receives through the Meta Marketing API and Graph API when a customer connects Meta with Facebook Login for Business or a system user token.

What we access

• The access token, and the permissions it carries: ads_read, ads_management, business_management, pages_show_list and pages_read_engagement. The token is encrypted before it is stored and is never shown again or written to logs.
• The connected Meta user’s or system user’s ID and name, and the businesses, ad accounts and Facebook Pages the token can reach.
• Campaigns, ad sets and ads in the connected ad accounts: names, IDs, statuses, budgets, bid and optimization settings, targeting, schedules and URL parameters.
• Ad creatives: copy, headlines, links, images, videos and previews, and the Page and Instagram account an ad runs from. We may transcribe the audio of video ads.
• Performance insights such as spend, impressions, reach, clicks and conversions. Meta provides these as totals, not data about individual people.
• Account configuration: pixels and datasets, custom conversions, the names and sizes of custom and lookalike audiences (never their members), and the ad account’s change history.

We do not receive the profiles, friends, messages or posts of Facebook or Instagram users, or information about the people who see or click the customer’s ads.

How we use it

• Only to report on, evaluate and optimize the connected advertiser’s own Meta campaigns, for that customer and the people it authorizes.
• Changes are made only when someone on the customer’s team turns on changes for that ad account and approves the specific change. Ember checks the live value again before applying it and records the result.
• Each ad account’s data is shown only to people who reach that account through a connection of their own.

What we never do with it

• Sell, license or purchase Meta Platform Data.
• Share it with data brokers or advertising networks.
• Use it to discriminate, or to decide anyone’s eligibility for housing, employment, insurance, credit or immigration.
• Use it for surveillance, or give it to law enforcement except as required by law.
• Build profiles of individual people, re-identify them, or retarget them.
• Combine it across advertisers, or use it to train or improve AI models.

We follow the Meta Platform Terms and Developer Policies. Removing the connection deletes the access token and stops all access; see data deletion.

Ember’s decisions, campaign reviews, creative drafts, video transcripts, funnel maps and landing page checks use AI models from Anthropic and OpenAI, reached through Vercel’s AI Gateway. For these features we send the relevant campaign settings, performance figures, ad copy, creative media and landing page content. Visitors’ email addresses and phone numbers are removed from funnel recordings first.

• Every request goes only to providers that have agreed with Vercel not to train on it. Requests other than transcription also go only to providers that keep no prompts or responses. Vercel may serve these models from Amazon Web Services, Google Cloud or Microsoft Azure under the same terms.
• Video ads are transcribed by OpenAI, which keeps the audio for up to 30 days to detect abuse, and then deletes it.
• If you connect an AI assistant to Ember, Ember sends it the data you ask for, which can include your leads’ contact details. That assistant’s provider handles the data under your agreement with it.
• AI output is a recommendation. It never changes an ad account on its own.

We do not sell personal information or share it for cross-context behavioral advertising.

Subprocessors

These companies process data for us, under contracts that limit them to providing their service. The full list, with what each does, is on our subprocessors page: Vercel, Neon, Anthropic, OpenAI, Amazon Web Services, Google Cloud, Microsoft Azure, Brevo, Resend, Slack and IPinfo. Our Slack receives only error alerts for our own team.

At the customer’s direction

• Meta, when the customer approves a change or a launch, and to read the customer’s data.
• The customer’s Slack, GoHighLevel, Calendly, Cal.com, AI assistants and other tools it connects.

Other cases

• When the law requires it, or to protect the rights, property or safety of our users, the public or us.
• In a merger, acquisition or sale of assets, subject to this policy and with notice to customers.

For the data a customer’s funnels collect, the customer is the controller (the “business” under California law) and Talented is its processor (“service provider”). We process it only on the customer’s instructions and only to provide Ember to that customer, under our data processing agreement. Each customer is responsible for its own privacy notice and for any consent its visitors’ laws require.

If you visited a customer’s website or booked a call with it, contact that business about your data. We will help it answer, and delete your data when it asks.

Ember does not send funnel data to Meta’s Conversions API or any other ad platform. We will update this policy before it does.

• In Ember: only the cookies that keep you signed in and protect your session. No advertising or analytics cookies.
• On customers’ websites with the tracking script: _ember_vid (a random visitor ID, up to 400 days), _ember_sid (the current visit, 30 minutes) and _fbc (Meta’s click ID from the ad link, 90 days), all set on the customer’s own domain. Visitors can clear or block them in their browser.

Jobs that run at least daily delete each kind of data once its time is up:

• Sign-in codes, password reset links, sessions and AI assistant tokens: within a day of expiring.
• Meta access tokens: until the connection is removed or your data is deleted.
• Cached Meta reports and decisions: up to 3 days.
• Video ad transcripts: 90 days.
• Landing page checks, with their screenshots and notes: 90 days.
• Visits and events from the tracking script: 400 days.
• IP network lookups and error logs: 30 days.
• Meta API call logs: 14 days.
• Password hashes: until you change your password or your data is deleted.
• Everything else, including leads, bookings, sales, decision history and settings: until the customer or you ask us to delete it.

Deleted data leaves our database provider’s recovery history within 30 days. We keep information longer only when the law requires it.

Removing a Meta connection in Ember deletes its access token at once. To have all of your data deleted, email privacy@scout-talented.com. The data deletion page lists exactly what is deleted and how to remove Ember’s access in Meta.

• All traffic to Ember uses HTTPS.
• Access tokens, webhook secrets and leads’ email addresses and phone numbers are encrypted with AES-256-GCM, with keys kept outside the database. Matching uses keyed hashes.
• Tokens are never returned to the browser or logged.
• People see only the ad accounts they reach, and only people with change access can approve changes.
• Uploaded files and screenshots are kept in private storage.

If we learn of a security incident affecting your data, we will notify affected customers without undue delay, and Meta and regulators as their terms and the law require. To report a vulnerability, email support@scout-talented.com.

Ember is operated from and hosted in the United States, and sign-in emails are sent from the European Union. When we transfer personal data from the EEA, the UK or Switzerland, we rely on the European Commission’s Standard Contractual Clauses (with the UK addendum) or another lawful transfer mechanism.

Depending on where you live, you may have the right to know what personal data we hold about you, get a copy, correct it, delete it, restrict or object to how we use it, and withdraw consent. Email privacy@scout-talented.com. We will confirm the request from your account’s email address and answer within 30 days (45 days where the law allows). We will not treat you differently for using these rights.

If your data came from a customer’s website or funnel, we pass your request to that customer, which decides how to answer it.

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• In the past 12 months we collected identifiers (name, email address, phone number, IP address, online identifiers), commercial information (advertising performance, bookings and purchase values), internet activity (pages viewed and interactions on customers’ websites), approximate location (country), and professional information (the business you work for). The sources, purposes and recipients are described above.
• We do not sell personal information or share it for cross-context behavioral advertising, and have not done so in the past 12 months.
• We do not use sensitive personal information to infer characteristics about you.
• You may ask to know, delete or correct your personal information, and you may use an authorized agent, whose authority we will verify.

For the accounts of people who sign in, Talented LLC is the controller. Our legal bases are performing our contract with the customer, our legitimate interests in running and securing Ember, consent where we ask for it, and complying with the law. For funnel data we are the customer’s processor. You may complain to your local data protection authority, though we would like the chance to help first.

Ember is a tool for businesses and is not directed to children. We do not knowingly collect personal data from anyone under 16 (or under 13 in the United States). If you believe a child has given us personal data, email us and we will delete it.

We update this policy when Ember or the law changes. The date at the top shows the latest version. If a change is material, we tell customers by email or in Ember before it takes effect.

Talented LLC is responsible for your data in Ember. Privacy questions, requests and complaints: privacy@scout-talented.com. Everything else: support@scout-talented.com.