Privacy Policy

PromoGen is operated by PromoGen s.r.o., Prague 14300, Czech Republic (Company ID 12345678, VAT CZ12345678) ("we", "us"). We are the controller of the personal data described in this policy. You can reach us at support@promogen.example.

• Account data: your first and last name, email address and, if you sign in with Google, the name, email and profile picture Google shares with us. We do not receive or store your Google password.
• Sign-in data: one-time sign-in links sent to your email and session records that keep you signed in.
• Your content: images you upload, texts you enter, your designs and the banners you export.
• Billing data: your plan, subscription status and the identifiers of your customer and subscription records at our payment provider. Card details are entered on and processed by Stripe; we never see or store full card numbers.
• Technical data: IP address, browser type, pages visited, timestamps and error logs, collected automatically when you use the service.
• Communications: messages you send us and our replies.

We do not collect special categories of personal data and ask you not to upload such data in images or texts.

• To provide the service — creating your account, signing you in, storing your projects, rendering and delivering your exports (performance of our contract with you).
• To take payments and keep accounting records (performance of contract and our legal obligations under tax and accounting law).
• To keep the service secure and working — preventing fraud and abuse, debugging, enforcing our Terms (our legitimate interest in a safe, reliable service).
• To improve the product — measuring how the service is used with Google Analytics and testing variations of pages (your consent in the EU/EEA, the UK and other opt-in countries; elsewhere our legitimate interest, subject to your right to opt out — see "Cookies and your choices").
• To communicate with you — service and billing messages (contract) and, only if you agree, product news (consent, which you can withdraw at any time).
• To comply with the law and to establish, exercise or defend legal claims (legal obligation and legitimate interest).

We group the cookies we use into three categories:

• Strictly necessary — always on, because the service cannot work without them: session cookies that keep you signed in and protect sign-in requests, and cookie_consent, which remembers your cookie choice for 6 months.
• Analytics — Google Analytics (_ga, _ga_*, up to 2 years). They tell us which pages and features are used, from which countries and devices, and how visitors arrive. Google Analytics does not log or store IP addresses for EU visitors, and its advertising and personalisation features are switched off.
• Product experiments — visitor_id, a random identifier kept for up to 12 months, so you see a consistent version of a page while we test improvements. Without it you see the standard version.

If you are in the EU/EEA, the UK, Switzerland or most other countries, analytics and experiment cookies are set only after you agree in the cookie banner ("Accept all", or by switching a category on under "Customize"). Until then, and if you click "Reject all", only strictly necessary cookies are used and Google Analytics is not loaded.

If you are in the United States, analytics and experiment cookies are on by default and you can opt out at any time in the banner or with "Your Privacy Choices". If your browser sends a Global Privacy Control (GPC) signal, we treat it as a request to opt out and do not set these cookies.

You can change your choice at any time with the "Cookie settings" or "Your Privacy Choices" link at the bottom of every page. Withdrawing consent is as easy as giving it; when you switch a category off, we remove its cookies from your browser. Withdrawal does not affect processing that took place before it. We ask for your choice again every 6 months and when we materially change the cookies we use.

Our payment page is provided by Stripe, which sets its own cookies to process payments and prevent fraud; these are necessary for paying and are governed by Stripe's privacy policy. You can also delete or block cookies in your browser settings; blocking necessary cookies will prevent you from signing in.

We do not sell your personal data. We share it only with service providers who process it on our behalf and under our instructions:

• Stripe — payments and subscription management;
• UploadThing — storage and delivery of uploaded images and exported banners;
• Google — sign-in with Google, if you choose it, and Google Analytics, if you accept analytics cookies;
• Upstash — the queue that runs your exports in the background;
• our email delivery provider — sign-in links and service emails;
• our hosting and database providers — running the service and storing its data.

We may also disclose data where required by law, to protect our rights or the safety of others, or to a successor if our business is reorganised or sold, in which case this policy continues to apply.

Some of our providers are located outside the European Economic Area, including in the United States. Where data is transferred outside the EEA, we rely on an adequacy decision (such as the EU–US Data Privacy Framework) or the European Commission's Standard Contractual Clauses, together with appropriate safeguards.

• Account data and your content: for as long as your account exists, then deleted within 30 days of account deletion, except backups, which are overwritten within a further 30 days.
• Uploaded images and exported banners: when you delete a project or a banner, its images and exports are deleted from our storage straight away. An image you remove or replace in a project, an earlier export replaced by a new one, and an upload you never save into a project are deleted automatically, usually within a day.
• Billing and invoice records: for the period required by tax and accounting law.
• Technical logs: usually up to 30 days, longer only if needed to investigate a security incident.
• Unused sign-in links expire after 24 hours.

If you are in the EU/EEA, the UK or Switzerland, you have the right to (for US residents, see the next section):

• access the personal data we hold about you and get a copy;
• correct inaccurate data — you can change your name in your account settings;
• have your data deleted;
• restrict or object to certain processing, including processing based on legitimate interests;
• receive your data in a portable format;
• withdraw consent at any time, without affecting earlier processing;
• lodge a complaint with your data protection authority.

To exercise these rights, email us at support@promogen.example from the address linked to your account. We reply within one month and may ask you to confirm your identity.

This section applies to residents of US states with consumer privacy laws, including the California Consumer Privacy Act as amended by the CPRA ("CCPA"), and the laws of Colorado, Connecticut, Virginia, Utah, Texas, Oregon and other states.

Categories of personal information we collected in the past 12 months: identifiers (name, email address, account and cookie identifiers, IP address); commercial information (plan and subscription history); internet or other electronic network activity (pages visited and features used); approximate geolocation derived from IP address; and the content you upload. We collect it from you, from your browser or device, and from Google if you sign in with Google. We use it for the purposes described in "Why we use your data" and keep it for the periods in "How long we keep data". We do not collect sensitive personal information for the purpose of inferring characteristics about you.

No sale; limited sharing. We do not sell personal information for money and do not use it for targeted (cross-context behavioural) advertising. Analytics and experiment cookies may be considered "sharing" or a "sale" under some state laws; you can opt out of them with "Your Privacy Choices" at the bottom of every page, and we honour the Global Privacy Control signal as a valid opt-out. We do not knowingly sell or share the personal information of consumers under 16.

Your rights. Subject to the law of your state, you may request to know or access the personal information we hold about you, to correct it, to delete it, to receive a portable copy, and to opt out of sale, sharing, targeted advertising and profiling. You may also limit the use of sensitive personal information, although we do not use it for purposes that would require this. We will not discriminate against you — for example by charging different prices or giving a lower quality of service — for exercising your rights.

How to make a request. Use "Your Privacy Choices" to opt out, or email support@promogen.example for other requests. We verify requests by matching the email address linked to your account, and respond within 45 days (extendable once by 45 days where the law allows). You may use an authorised agent, who must give us proof of your signed permission; we may still ask you to verify your identity. If we refuse a request, you may appeal by replying to our decision; we will answer the appeal within the period your state's law requires and, if it is denied, you may contact your state Attorney General.

We use encryption in transit, access controls and reputable providers to protect your data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your data, we will notify you and the authorities where the law requires.

PromoGen is not intended for anyone under 16. We do not knowingly collect data from children; if you believe a child has given us data, contact us and we will delete it.

We may update this policy from time to time. We will post the new version here with a new effective date and, for significant changes, tell you by email or in the service before they take effect.

Questions about this policy or your data: support@promogen.example, or by post to PromoGen s.r.o., Prague 14300, Czech Republic. See also our Terms of Service.