HQ Privacy Policy

1. Who we are

Agbisit Acquisitions Ltd is a company registered in England and Wales (company number 16795399), with its registered office at 4 Savile Drive, Halifax, West Yorkshire, HX1 2EU, United Kingdom. We are the controller of the personal data described in this policy. We are registered with the UK Information Commissioner's Office under registration number ZC130402.

Privacy questions and requests: legal@catna.cc. General support: support@catna.cc.

2. The short version

• HQ is where CATNA's team runs sales, client care and content. Only staff can sign in.
• HQ publishes and measures CATNA's own content on the YouTube channel and Instagram accounts CATNA connects to it. It does not connect to clients' or viewers' accounts.
• We do not sell personal data, and HQ runs no advertising or third-party analytics.
• You have rights over your data and can use them at any time (Section 10).

3. Staff who sign in to HQ

What we collect:

• Your account: email address, name, profile picture if you add one, department, Discord user ID, time zone, and your password, stored only as a one-way hash (we never see or keep the password itself).
• Sign-in records: when you last signed in and how many times, and, to stop repeated wrong passwords, a short record of failed attempts keyed to the account and the network address used.
• Your activity in HQ: which HQ pages you open and on which days, the reports and notes you file, and a log of the changes you make to records.
• If you connect an AI assistant to HQ through HQ's connector, the access it was given, with its keys stored only as hashes.

How we use it, and our lawful basis:

• To give you access, keep your account secure and show the right parts of HQ for your role. Lawful basis: our legitimate interest in running a secure internal tool, and, where you work for us under a contract, performance of that contract.
• To keep an accurate record of who changed what, to understand which parts of HQ the team uses, and to run the team's reporting. Lawful basis: our legitimate interest in running and improving our business.

4. The YouTube channel and Instagram accounts connected to HQ

CATNA connects only its own YouTube channel and its own Instagram accounts to HQ. Staff use HQ to schedule and publish CATNA's content to them and to see how that content performs.

YouTube. HQ uses YouTube API Services. When the channel is connected, HQ asks Google for three permissions: to upload videos, to view the YouTube account (Google's read-only YouTube permission), and to view YouTube Analytics reports for the channel. With them, HQ:

• stores the channel's ID and name, the permissions granted, and the access and refresh tokens Google issues, encrypted,
• uploads the videos, titles, descriptions and thumbnails staff schedule in HQ; the files are kept in our own storage until they are published and are deleted about seven days later, unless staff keep a file for a later post,
• reads back the status of the videos it uploaded, so staff can see whether each one went out,
• reads the channel's and its videos' statistics and analytics reports (such as views, likes and comment counts, watch time and how long viewers keep watching), which are totals for the channel and its videos, not data about individual viewers, so staff can see how CATNA's content performs.

HQ does not read the personal data of viewers, the text of comments, or private messages. YouTube data in HQ is available only to CATNA staff and to the hosting, database and storage providers that hold it for us, and is never sold or shared with anyone else. Google processes data in YouTube under the Google Privacy Policy.

Removing access. Staff can disconnect the channel in HQ, which deletes the stored tokens. The account owner can also revoke HQ's access at any time on the Google security settings page. Statistics already collected stay in HQ as CATNA's record of its own content until we delete them, which we do on request.

Instagram. HQ uses Meta's Instagram API. When an account is connected, HQ asks Meta for three permissions: basic access to the professional account, publishing content, and reading insights. With them, HQ:

• stores the account's ID and username and the access token Meta issues, encrypted, and renews it before it expires,
• publishes the posts staff schedule; staged files follow the same seven-day rule as for YouTube,
• reads the account's posts and captions, each post's statistics (such as views, reach, likes, comments, shares, saves, watch time and follows) and how they change day by day, and the account's audience as Instagram groups it (age, gender, country and city, never individual people), and keeps a small copy of each post's cover image, because Instagram's own image links expire, so staff can see how CATNA's content performs.

Meta processes data under the Meta Privacy Policy. Access can be removed by disconnecting the account in HQ, which deletes the stored token, or in the account's Instagram settings. To ask us to delete data HQ holds about a connected account, email legal@catna.cc.

Lawful basis: our legitimate interest in publishing and measuring our own content on accounts we operate.

5. Records about people who book calls and about program clients

HQ is CATNA's internal sales and client system, so it holds the records described in the CATNA Privacy Policy, Section 3 for people who book a call or message us and Section 4 for program clients. That policy sets out what we collect, why, our lawful basis and how long we keep it. In HQ specifically:

• bookings arrive from our scheduling provider, with the booking answers and campaign tags, and the call notes our team writes, including a link to the call recording where there is one,
• client records hold contact details, program and payment status, the Whop and Discord identifiers that link a client to their membership, and our team's notes, tasks, check-ins and progress scores,
• once a day HQ also reads a summary of each client's workspace in Creator OS, CATNA's client app, and keeps the latest reading only: the client's posting counts, the weekly figures they report (such as new leads, sales conversations, the cash they collected and the week's rating, never their written answers), a summary of their own log of new customers, summaries of their plan and of their connected Instagram account, and their join date and whether the workspace is archived. A reading older than two days is not shown,
• once a day HQ also records, from the CATNA Discord bot, how quickly our team replied to each client in their own channel, and when and for how long the client was in the community's voice channels, never the messages themselves,
• once a week HQ receives from the CATNA Discord bot a short note about each client's private channel with our team, written by an AI service (Anthropic) from the last seven days of messages there, the client's and ours, for clients whose program is active or paused: how the client seems to be doing, what they appear stuck on, any question of theirs that went unanswered, and a suggested rating with a one-line reason. The messages go from Discord to Anthropic and back; HQ never receives or stores them, only the note. A team member reads the note and decides whether to record a check-in; the AI sets no rating and changes no record, and the note is never shown to the client or used in Creator OS,
• payment records come from our payment provider and include the billing name, card brand and last four digits, the product and the payment status; HQ never holds full card details,
• the tools our sales team uses to manage conversations with people who contact us report where each conversation stands into HQ.

AI. HQ uses an AI service (Anthropic) for two things, and in both the AI writes words only; it does not change records or make any decision about anyone. It writes the weekly team summary from figures HQ has already calculated, which can include the names of clients who need attention and a one-line reason; HQ keeps a copy of what was sent and returned so staff can check it. Through the CATNA Discord bot it also writes the weekly note on each client's private channel described above; HQ keeps the note, the model used and who accepted or dismissed it, and never the messages.

6. Who we share data with

We share personal data from HQ only with:

• service providers who run HQ for us: hosting (Vercel), database (Neon), file storage for staged posts (Cloudflare), the AI service that writes the weekly summary and the weekly client-channel notes (Anthropic), our scheduling and payment providers (Calendly, Whop) and the service that carries bookings into HQ (Zapier), our sales team's conversation tools, and Discord, where HQ posts notifications to private staff channels,
• Google and Meta, when HQ publishes to the channel and accounts connected to it (Section 4),
• our staff and contractors who need it to do their work, under a duty of confidentiality,
• professional advisers, such as lawyers and accountants, where needed,
• authorities, where the law requires it.

We do not sell personal data. If CATNA's business is sold or merged, personal data may pass to the buyer, who must use it as this policy describes.

7. Cookies

HQ sets cookies in staff browsers only: one keeps you signed in, short-lived ones protect sign-in and the connection of an account and show its result, and a few remember your display choices (such as the theme and how lists are shown). HQ uses no advertising or third-party analytics cookies.

8. International transfers

Several of our providers, including Vercel, Neon, Anthropic, Google, Meta, Discord and Cloudflare, process data outside the UK, mostly in the United States. Where data leaves the UK, we rely on a UK adequacy regulation (including the UK Extension to the EU-US Data Privacy Framework where the provider is certified) or on the UK International Data Transfer Agreement or Addendum. You can ask us for details of the safeguard that applies.

9. How long we keep data

• Staff accounts and activity records: while you have an HQ account and up to 12 months after it is closed, then deleted, except the record of changes, which we keep as long as the records it describes.
• Tokens for connected accounts: until the account is disconnected or access is revoked.
• Statistics about CATNA's own channel and accounts, including each post's daily history and the cover copies: while CATNA uses HQ to measure its content, unless we are asked to delete them sooner.
• Videos and images staged for publishing: about seven days after they are posted, unless kept for a later post.
• Records about people who book calls and about clients: as set out in Section 8 of the CATNA Privacy Policy.
• AI notes on a client's channel: for the length of the client's program and for 24 months after it ends, then deleted, unless we are asked to delete them sooner. Anthropic deletes what it receives and returns within 30 days by default.

10. Your rights

Under UK data protection law you can ask us to give you a copy of your personal data, correct it, delete it, restrict or object to how we use it (including any use based on our legitimate interests), or send it to you or another organisation in a portable format. Some rights have limits; for example, we may need to keep records to deal with a dispute. To use a right, email legal@catna.cc. It is free of charge. We will respond within one month, or tell you within that month if a complex request needs up to two more months, and why.

11. Complaints

If you are unhappy with how we handle your data, please tell us first at legal@catna.cc. We will acknowledge your complaint within 30 days and respond in full without undue delay. You also have the right to complain to the UK Information Commissioner's Office. If you live outside the UK, you may also be able to complain to the data protection authority where you live.

12. Security and age

We protect personal data with reasonable technical and organisational measures, such as access by role, one-way hashing of passwords and encryption of stored account tokens. No system is perfectly secure. HQ is for staff aged 18 and over.

13. Changes to this policy

We will update this policy when the way HQ uses personal data changes, and change the date at the top. If a change is significant, we will tell staff directly.