Data controller
- Name
- Tuzson Barnabás
- Address
- 1125 Budapest, Dániel út 54–60., Hungary
This notice applies to the processing of personal data carried out when using KommentModerator, also known as Facebook Comment Moderator.
Purpose of the application
KommentModerator helps the data controller review and moderate comments published on Facebook Pages managed by the data controller.
In particular, the application provides the following functions:
- retrieving Facebook posts and comments through the Meta Graph API;
- reviewing and managing comments;
- keeping, hiding or deleting comments, and blocking the specific Facebook profile of a commenter.
The application does not use personal data for advertising, direct marketing or the sale of user profiles.
Data subjects
The processing may concern:
- administrators of Facebook Pages connected to the application;
- Facebook users who comment on posts or reply to comments on connected Facebook Pages;
- users who otherwise interact with connected Pages, where the Meta Graph API makes their data available to the application.
Personal data processed
Depending on the access provided by Meta, the application may process:
- a user identifier assigned to the Facebook Page or application;
- display name and profile picture;
- the text of a comment or reply;
- the identifiers of the comment and related post;
- the date and time of publication;
- the Facebook link to the comment or post;
- image, video and attachment data associated with a post or comment;
- whether a comment is hidden or can be deleted;
- the moderation decision made by the operator;
- technical logs relating to hiding, restoring, deleting or blocking.
The application processes only author information lawfully supplied by the Meta Graph API. It does not use web scraping or attempt to identify commenters from other sources.
Purposes and legal basis
The purposes of processing are:
- operating the Facebook Page safely and in an orderly manner;
- managing spam, harassment, threats and unlawful content;
- protecting the Page and its commenters;
- implementing and documenting moderation decisions;
- preventing technical errors, misuse and unauthorised access;
- handling data subject requests and legal claims.
The primary legal basis for processing is the data controller's legitimate interest under Article 6(1)(f) of the General Data Protection Regulation (GDPR). This legitimate interest is the moderation and security of the Facebook Page operated by the data controller and taking action against unlawful or harmful content.
Where processing is necessary to comply with a legal obligation, Article 6(1)(c) of the GDPR may apply.
Where a user has manifestly made special categories of personal data public in a public comment, technical processing may take place with regard to Article 9(2)(e) of the GDPR. The application does not create a separate user profile from such data.
The official text of the GDPR is available on EUR-Lex.
Data sources
Personal data is obtained from:
- Meta Platforms Ireland Limited and the Meta Graph API;
- comments or replies published by the data subject on Facebook;
- moderation actions performed by the data controller.
The application does not collect personal data from data brokers, public databases or social media profiles outside Facebook.
Processors and data transfers
Meta Platforms Ireland Limited
Meta provides access to the Facebook Page, posts, comments and permitted author information, and enables moderation actions to be performed.
Meta's own processing is governed by the Meta Privacy Policy.
In providing Meta services, some data may be processed outside the European Economic Area. Such transfers may be based on appropriate safeguards, including an adequacy decision or standard contractual clauses.
The data controller does not sell personal data or disclose it to advertisers.
Storage and security
KommentModerator operates as a local macOS application.
Downloaded data and moderation results are stored in a local database on the data controller's computer. The application does not operate a central cloud-based comment database.
The application stores Meta access tokens in macOS Keychain. It does not write tokens to the local database or application logs.
The application is accessible only on the local computer at 127.0.0.1. The data controller applies appropriate access controls, device security and logging measures.
No technical system can be considered entirely risk-free. The data controller therefore reviews access permissions and stored data regularly.
Retention periods
- Comments, author information and moderation decisions are retained in the local application for no longer than 30 days.
- Technical and security logs are retained for no longer than 90 days.
- Exported files are retained for no longer than 30 days.
- Access tokens remain in macOS Keychain until the connection ends or the tokens are revoked or replaced.
The data controller runs the application's data deletion function at least once a month. The entire local database can be deleted from the application settings when necessary.
Hiding, deletion or blocking carried out on Facebook may remain in Meta's systems after the local database has been deleted. These actions are governed by the Facebook Page settings and Meta's rules.
Your rights
Subject to the conditions of the GDPR, you have the right to:
- receive information about the processing of your personal data;
- request access to your personal data;
- request correction of inaccurate personal data;
- request erasure of your personal data;
- request restriction of processing;
- object to processing based on legitimate interests;
- lodge a complaint with the competent supervisory authority;
- seek a judicial remedy.
Requests may be sent to tuzson.barnabas@gmail.com.
The data controller will respond without undue delay and, as a general rule, within one month of receiving the request. To prevent unauthorised erasure or access, the data controller may ask the data subject to verify their identity and the Facebook comment concerned.
Erasure request
You may request deletion of personal data stored in the application by emailing tuzson.barnabas@gmail.com.
To help identify the relevant data more quickly, include:
- the display name used on Facebook;
- a link to the relevant comment or post;
- a subject line such as “KommentModerator data erasure request”.
After verifying the request, the data controller will delete identifiable personal data from the application's local database unless continued retention is required by law or necessary for a legal claim.
Access granted to the application through a Facebook account can also be revoked in Facebook settings under “Apps and websites” or business integrations.
Request data erasureComplaints
You may lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of Information:
Hungarian National Authority for Data Protection and Freedom of Information (NAIH)Address: 1055 Budapest, Falk Miksa utca 9–11., Hungary
Postal address: 1363 Budapest, Pf. 9., Hungary
Email: ugyfelszolgalat@naih.hu
Website: www.naih.hu
Current contact details are available on the official NAIH website.
Changes to this notice
The data controller may amend this notice, particularly where the operation of the application, service providers used or applicable law changes.
Material changes will be indicated on the publicly available privacy page. The current effective date and version number will always appear at the beginning of this notice.