The terms require developers to implement and maintain technical and organizational security measures adequate to protect all platform-sourced data against unauthorized access, use, or disclosure.
This analysis describes what Meta's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a contractual security standard obligation for developers that runs parallel to, and must be assessed against, applicable regulatory security requirements such as GDPR Article 32 and the FTC's security expectations under the FTC Act and Safeguards Rule.
Interpretive note: The provision's 'appropriate' standard is not defined with specific technical benchmarks, leaving adequacy determinations subject to interpretation by both Meta and regulatory authorities.
The updated terms authorize Meta to retain user-submitted content if its systems flag the content for a potential policy violation, in addition to retention tied to legal compliance and contractual rights. This expands the circumstances under which content may be preserved without explicit time limits. Under the revised language, content retention decisions may now be driven by automated policy-violation flagging in addition to legal or contractual necessity. Developers integrating the Llama API should understand that flagged content may be retained indefinitely pending policy review.
View change record →This new provision establishes affirmative security obligations on developers, shifting responsibility for data protection from Meta to the application layer.
View full change record →Under this clause, developers accessing Meta platform data are contractually obligated to implement security measures protecting user data from unauthorized access or disclosure, establishing a minimum security expectation that applies independently of any regulatory floor.
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"You must have and maintain appropriate technical and organizational measures to protect Platform Data against unauthorized access, use, or disclosure.— Excerpt from Meta's Llama API Terms of Service
1. REGULATORY LANDSCAPE: This provision directly engages GDPR Article 32 (security of processing), the FTC Safeguards Rule for financial service developers, HIPAA Security Rule for healthcare-adjacent applications, and state breach notification laws including the New York SHIELD Act and California's data security law. The FTC, state AGs, and EU DPAs are enforcement authorities depending on developer jurisdiction. 2. GOVERNANCE EXPOSURE: Medium. The provision does not define specific security standards, encryption requirements, penetration testing frequency, or incident response timelines, leaving adequacy determinations to interpretation. Developers who experience a data breach involving platform data face simultaneous Meta contractual breach exposure and regulatory investigation risk. 3. JURISDICTION FLAGS: EU/EEA developers must satisfy GDPR Article 32's requirement for security appropriate to the risk, including pseudonymization and encryption where appropriate. New York developers are subject to the SHIELD Act's reasonable security requirements. Healthcare and financial service developers face sector-specific security standards that set a higher floor than this provision's general language. 4. CONTRACT AND VENDOR IMPLICATIONS: Developers must flow down security requirements to sub-processors handling platform data through data processing agreements that include technical and organizational measure specifications. Platform security audits should include assessment of sub-processor security posture. The terms' audit rights provision reinforces that Meta may inspect security measures directly. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should map current security controls against applicable regulatory standards (GDPR Article 32, NIST Cybersecurity Framework, SOC 2 Type II) and document the adequacy determination. Incident response plans should specifically address Meta platform data breach notification obligations, which may include notification to Meta as well as to regulators and affected users under applicable law.
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This provision establishes a contractual security standard obligation for developers that runs parallel to, and must be assessed against, applicable regulatory security requirements such as GDPR Article 32 and the FTC's security expectations under the FTC Act and Safeguards Rule.
Under this clause, developers accessing Meta platform data are contractually obligated to implement security measures protecting user data from unauthorized access or disclosure, establishing a minimum security expectation that applies independently of any regulatory floor.
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