Privacy Policy

1. About This Policy

This Privacy Policy applies to the PromoPilot platform ("Service"), a marketing campaign management and AI-powered creative generation platform. By using our Service, you consent to the data practices described in this policy.

1.1 Data Controller

The data controller responsible for your personal information is:

BGO s.r.o.
Identification Number (IČO): 19173661
Registered in the Czech Republic
Email: info@promopilot.com
Website: https://promopilot.com

1.2 Scope

This policy covers all data processing activities related to PromoPilot, including our website, web application, API services, and any related services we provide.

2. Information We Collect

2.1 Information You Provide Directly

When you register and use our Service, we collect the following information:

2.2 Information We Collect Automatically

• Authentication Tokens: JWT tokens and refresh tokens for session management (stored as secure, httpOnly cookies)
• Account Activity: Login timestamps, last activity date, account status
• Usage Analytics: Server-side analytics including feature usage, campaign creation steps, credit consumption, API requests
• System Logs: Error logs, performance metrics, API responses for debugging and service improvement
• Technical Information: Browser type, IP address, device type, timestamp data (for security and fraud prevention)

2.3 Information from Third-Party Services

• Stripe Payment Data: Payment transaction details, customer ID (we do not store credit card numbers)
• AI Processing Results: Outputs from Azure OpenAI, Google Gemini, and Anthropic Claude models

3. How We Use Your Information

3.1 Service Delivery

• Account Management: Create and maintain your user account, authenticate access, manage subscriptions
• Campaign Creation: Process campaign requirements, generate marketing strategies, create creative assets
• AI Processing: Send your campaign data and brand materials to AI services for analysis and content generation
• Asset Generation: Create HTML5 banners, images, and marketing materials based on your specifications
• File Storage: Store your uploaded brand materials and generated assets in secure cloud storage
• Payment Processing: Process credit purchases through our payment provider (Stripe)

3.2 Service Improvement

• Platform Optimization: Analyze usage patterns to improve features and user experience
• Quality Assurance: Monitor AI output quality, asset generation success rates, system performance
• Bug Fixes: Identify and resolve technical issues, improve platform stability
• Feature Development: Understand user needs to develop new features and capabilities

3.3 Communication

• Service Communications: Send account notifications, password resets, security alerts
• Support: Respond to your inquiries, provide technical assistance
• Marketing (Future): With your consent, send promotional emails about new features, updates, and offers (you can opt-out anytime)

3.4 Legal Compliance

• Security: Detect and prevent fraud, abuse, and security threats
• Compliance: Comply with legal obligations, respond to legal requests
• Business Operations: Maintain business records, financial reporting

4. Third-Party Services & Data Processing

We use the following third-party services to operate PromoPilot. These services may process your data as described below:

4.1 Cloud Infrastructure

• Microsoft Azure:
  • Azure Kubernetes Service (application hosting)
  • Azure Database for PostgreSQL (data storage)
  • Azure Blob Storage (file storage for assets and brand materials)
  • Azure Service Bus (asynchronous job processing)
  • Azure Key Vault (secure secrets management)
  • Azure Application Insights (monitoring and logging)

4.2 AI & Machine Learning Services

We send your campaign data, brand materials, and content to the following AI services for processing:

• Azure AI Foundry:
  • OpenAI GPT models (text generation, strategy creation)
  • GPT-Image-1 (image generation)
• Google Cloud AI:
  • Gemini models (multimodal AI processing)
• Anthropic:
  • Claude models (advanced text generation and analysis)

4.3 Payment Processing

• Stripe: Payment processing for credit purchases
  • We do not store credit card information
  • Stripe stores payment method details securely
  • We receive only transaction confirmation and customer IDs
  • PCI DSS compliant payment processing
  • Payment metadata includes: base credits, bonus credits, total credits

4.4 Data Processing Locations

Your data may be processed in the following locations:

• European Union: Primary data storage and processing
• United States: Some AI services (Azure OpenAI, Anthropic, Google Cloud) process data in US data centers
• Data Transfer Safeguards: All data transfers comply with GDPR requirements using Standard Contractual Clauses (SCCs) and appropriate safeguards

5. Data Security

We implement industry-standard security measures to protect your personal information:

5.1 Technical Security Measures

• Encryption: All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
• Password Security: Passwords are hashed using industry-standard algorithms (bcrypt) and never stored in plain text
• Access Control: Role-based access control (RBAC) with principle of least privilege
• Authentication: JWT tokens with short expiration times (15 minutes) and secure refresh mechanisms
• Secrets Management: API keys and credentials stored in Azure Key Vault, never in code
• Network Security: Private endpoints, network security groups, and firewall rules

5.2 Organizational Security Measures

• Access Logging: All data access is logged and monitored for suspicious activity
• Regular Audits: Security audits and vulnerability assessments
• Data Minimization: We collect only data necessary for service operation
• Employee Training: Team members trained on data protection and security practices
• Incident Response: Security incident response plan and breach notification procedures

5.3 Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities within 72 hours as required by GDPR.

6. Data Retention

6.1 Retention Periods

We retain your personal information for the following periods:

6.2 Account Deletion

When you delete your account:

• Your account is immediately marked as deleted and inaccessible
• Personal data is anonymized or deleted within 90 days
• Campaigns, assets, and brand materials are permanently deleted within 90 days
• Some data may be retained in backup systems for up to 90 days, then permanently deleted
• Aggregated, anonymized analytics data may be retained for statistical purposes

7. Your Privacy Rights (GDPR)

As a user in the European Union, you have the following rights under GDPR:

7.1 Right of Access

You have the right to request a copy of all personal data we hold about you. To exercise this right, contact us at info@promopilot.com with subject line "Data Access Request".

7.2 Right to Rectification

You can update your personal information (name, email, password) directly in your account settings. For other corrections, contact us at info@promopilot.com.

7.3 Right to Erasure ("Right to be Forgotten")

You can delete your account at any time through your account settings. This will permanently delete all your personal data within 90 days. For immediate deletion, contact us at info@promopilot.com.

7.4 Right to Restrict Processing

You can request that we limit how we process your personal data. Contact us at info@promopilot.com to exercise this right.

7.5 Right to Data Portability

You can export your campaign data, brand materials, and generated assets at any time through the application interface. For a complete data export, contact us at info@promopilot.com.

7.6 Right to Object

You can object to certain types of processing, including:

• Direct marketing communications (opt-out via email or account settings)
• Processing based on legitimate interests (contact us with your objection)

7.7 Right to Withdraw Consent

Where we process data based on your consent, you can withdraw consent at any time. This does not affect the lawfulness of processing before withdrawal.

7.8 Right to Lodge a Complaint

You have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

7.9 Response Time

We will respond to all requests within 30 days. If we need more time, we will inform you of the delay and the reason.

8. Cookies & Tracking

8.1 Essential Cookies Only

PromoPilot uses only essential cookies necessary for the Service to function. We do NOT use:

• Marketing or advertising cookies
• Third-party tracking cookies
• Analytics cookies (like Google Analytics)
• Social media tracking pixels

8.2 Authentication Cookies

We use the following essential cookies:

• JWT Access Token: Authenticates your session (expires after 15 minutes)
• JWT Refresh Token: Maintains your session (expires after 7 days)
• Cookie Properties: HttpOnly, Secure, SameSite=Strict for maximum security

8.3 Server-Side Analytics

All usage analytics are performed server-side and do not involve client-side tracking. We analyze:

• Feature usage patterns (which features are used most)
• Campaign creation flow (where users experience issues)
• Token consumption (to optimize pricing and performance)
• Error rates and performance metrics (to improve service quality)

This data is aggregated and anonymized for analytics purposes.

9. Marketing Communications

9.1 Current Status

We currently do NOT send marketing emails. We only send:

• Account-related notifications (password resets, security alerts)
• Service updates (downtime notifications, critical updates)
• Support responses (when you contact us)

9.2 Future Marketing Communications

In the future, we may offer optional marketing communications to inform you about:

• New features and product updates
• Special offers and promotions
• Educational content and best practices
• Industry news and insights

9.3 Your Marketing Preferences

Before we send any marketing communications, we will:

• Request your explicit consent (opt-in)
• Provide clear unsubscribe options in every email
• Honor opt-out requests immediately
• Never share your email with third-party marketers

9.4 How to Opt Out

If we introduce marketing emails in the future, you can opt out:

• Click "Unsubscribe" in any marketing email
• Update preferences in your account settings
• Contact us at info@promopilot.com

10. AI-Generated Content & Privacy

10.1 How AI Processes Your Data

When you use PromoPilot's AI features, your data is processed as follows:

• Campaign Planning: Your campaign goals, audience, and requirements are sent to AI models to generate strategic recommendations
• Brand Analysis: Your website URL, uploaded images, or brand descriptions are analyzed by AI to extract brand guidelines
• Strategy Generation: Your campaign data and brand information are processed to create marketing strategies
• Asset Generation: Your campaign content is used to generate HTML5 banners, copy, and creative assets

10.2 AI Provider Policies

Our AI service providers have committed to the following:

• No Training on User Data: Azure OpenAI, Anthropic Claude, and Google Gemini do not use customer data to train their models (per enterprise agreements)
• Data Retention: AI providers may temporarily retain data for processing but delete it according to their policies
• Privacy Commitments: All AI providers are GDPR-compliant and have appropriate data processing agreements

10.3 Your Content Ownership

• You retain full ownership of all input content (brand materials, campaign descriptions, uploads)
• You own the generated outputs (strategies, creative assets, marketing materials)
• Generated content may not be unique if similar inputs are provided by other users

11. Data Sharing & Disclosure

11.1 We Do NOT Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

11.2 When We Share Data

We share your data only in the following circumstances:

• Service Providers: With trusted third-party services necessary to operate PromoPilot (Azure, Stripe, AI providers) under strict data processing agreements
• Legal Requirements: When required by law, court order, or government regulation
• Security & Fraud: To detect, prevent, or investigate security incidents, fraud, or illegal activity
• Business Transfers: In the event of a merger, acquisition, or sale of assets (you will be notified)
• With Your Consent: When you explicitly authorize us to share your data

11.3 Anonymized Data

We may share aggregated, anonymized data that cannot identify you personally for:

• Industry research and reports
• Service improvement and optimization
• Business analytics and decision-making

12. Children's Privacy

PromoPilot is not intended for use by individuals under the age of 16. We do not knowingly collect personal information from children under 16.

If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information immediately.

If you believe we have collected information from a child under 16, please contact us at info@promopilot.com.

13. International Data Transfers

PromoPilot operates globally and may transfer your data across international borders:

13.1 Primary Data Location

• European Union: Primary database and file storage hosted in EU Azure regions
• GDPR Compliance: All EU data processing complies with GDPR requirements

13.2 Transfers Outside the EU

Some AI processing services are located outside the EU:

• United States: Azure OpenAI, Anthropic Claude, Google Cloud AI services may process data in US data centers
• Safeguards: All transfers use Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy Decisions: We rely on adequacy decisions where available
• Data Processing Agreements: All third-party processors have GDPR-compliant data processing agreements

13.3 Your Rights

You have the right to request information about international data transfers and the safeguards in place. Contact us at info@promopilot.com for details.

14. Changes to This Privacy Policy

14.1 Policy Updates

We may update this Privacy Policy from time to time to reflect changes in:

• Our data processing practices
• Legal or regulatory requirements
• New features or services
• Third-party service providers

14.2 Notification of Changes

When we make material changes to this policy, we will notify you by:

• Updating the "Last Updated" date at the top of this page
• Sending email notification to registered users
• Displaying an in-app notification upon your next login
• Posting a prominent notice on our website

14.3 Your Consent

Your continued use of PromoPilot after we publish changes constitutes your acceptance of the updated policy. If you disagree with changes, you may delete your account.

15. Contact Us & Data Protection Officer

15.1 Privacy Inquiries

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

Email: info@promopilot.com
Subject Line: Privacy Inquiry - [Your Request Type]
Website: https://promopilot.com

15.2 Data Controller

BGO s.r.o.
Identification Number (IČO): 19173661
Registered in the Czech Republic
Company Registry

15.3 Response Time

We aim to respond to all privacy inquiries within:

• General inquiries: 5 business days
• GDPR requests: 30 days (as required by law)
• Urgent security matters: 24 hours

15.4 Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with your local data protection supervisory authority. For Czech Republic users:

Úřad pro ochranu osobních údajů (ÚOOÚ)
Office for Personal Data Protection
Website: https://www.uoou.cz

16. Additional Information

16.1 Related Policies

This Privacy Policy should be read in conjunction with:

• Terms and Conditions - Legal agreement for using PromoPilot

16.2 Language

This Privacy Policy is provided in English. In the event of any conflict between different language versions, the English version shall prevail.

16.3 Severability

If any provision of this Privacy Policy is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

Summary of Key Points