PRIVACY POLICY

Last Updated: November 11, 2025

Company: pi-optimal UG (haftungsbeschränkt) Address: Unter den Linden 15, 72762 Reutlingen, Germany Email: hello@pi-optimal.com Website: https://pi-optimal.com

1. INTRODUCTION

pi-optimal UG (haftungsbeschränkt) ("we," "our," or "us") operates pi-automate (the "Service"), which provides workflow automation services for Google Ads accounts.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use pi-automate, particularly in relation to your Google Ads account data.

1.1 Legal Basis for Data Processing (GDPR)

We process your personal data under the following legal bases:

(a) Consent (Art. 6(1)(a) GDPR): When you authorize us to access your Google Ads account

(b) Contract Performance (Art. 6(1)(b) GDPR): To provide the services you have requested

(c) Legitimate Interests (Art. 6(1)(f) GDPR): To improve our services and prevent fraud

2. DATA WE COLLECT

2.1 Google Ads Account Data

When you connect your Google Ads account to pi-automate, we may access and process:

  • Campaign data (names, settings, budgets, performance metrics)
  • Ad data (content, creatives, targeting settings, performance)
  • Account information (settings, billing preferences, user permissions)
  • Performance metrics (clicks, impressions, conversions, costs, and other advertising metrics)
  • Customer lists (if used in your campaigns)
  • Conversion data
  • Change logs (history of account changes, including email addresses of users who made changes)
  • User information (email addresses and names of users with access to your Google Ads account)

Scope of Access: We request full read-write access to your Google Ads account to enable comprehensive workflow automation as defined by you.

Important Note: Change logs and user information may include email addresses of other people who have access to your Google Ads account (e.g., your team members, agency staff, or client employees if you are an agency). By connecting your Google Ads account, you confirm you have authority to share this information with us.

2.2 Account and Usage Data

  • Email address and authentication tokens
  • Workflow definitions you create
  • API call logs and usage statistics
  • Technical data (IP address, browser type, device information)

2.3 Communication Data

  • Support requests and correspondence with our team

3. HOW WE USE YOUR DATA

Primary Purpose: Execute your workflow automations

  • Process natural language workflow instructions
  • Create, modify, pause, or delete campaigns and ads as instructed
  • Adjust budgets and bids according to your defined rules
  • Generate reports and insights based on your Google Ads data
  • Authenticate your access to the Service
  • Track campaign changes via change logs to understand account history and prevent conflicts with manual changes

AI Processing: Your data and workflow instructions are processed through Azure OpenAI services (located in Sweden) to understand natural language workflows and generate appropriate API calls to Google Ads.

Service Operations: Track usage for billing purposes (when applicable), troubleshoot technical issues, and improve service functionality.

Operational Modes:

  • Co-Pilot Mode (Default): Shows proposed changes before execution; you approve each action. Note: AI suggestions may be incorrect - you are responsible for evaluating and approving/rejecting suggestions.

  • Autopilot Mode (Experimental): Fully automated - AI makes autonomous campaign decisions and executes automatically without approval. Highly experimental and not recommended.

Both modes are experimental.

4. GOOGLE API SERVICES COMPLIANCE

pi-automate's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically:

(a) Limited Use: We only use your Google Ads data for the purposes explicitly disclosed in this Privacy Policy

(b) No Sale of Data: We will never sell your Google Ads data to third parties

(c) No Advertising Use: We do not use your Google Ads data for serving advertisements

(d) Secure Transfer: Data is only shared with third parties as described in Section 5 below

(e) Human Readable Privacy Policy: This policy is accessible and understandable

5. DATA SHARING AND THIRD-PARTY SERVICES

5.1 Microsoft Azure

Purpose: Cloud infrastructure and data storage Location: Azure Europe West (Netherlands) for primary data storage; Azure Sweden for AI/LLM processing Data Shared: All data processed through our Service Legal Basis: Necessary for service delivery

5.2 Azure OpenAI Services

Purpose: Natural language processing for workflow automation Location: Sweden Data Shared: Workflow instructions and Google Ads data necessary for automation Legal Basis: Necessary for core service functionality

5.3 No Other Third Parties

We do not currently use third-party analytics, marketing, or advertising services. We do not sell, rent, or trade your data with any third parties.

6. DATA STORAGE AND SECURITY

6.1 Storage Location

Primary Data: Stored in Microsoft Azure Europe West region (Netherlands) AI Processing: Azure OpenAI Sweden region

6.2 Data Retention

Active Accounts: We retain your data while your account is active and you maintain authorization.

Deleted Accounts: Upon account deletion or authorization revocation, we delete your data within 30 days, except where retention is legally required.

Backup Systems: Backups may retain data for up to 90 days for disaster recovery purposes.

6.3 Security Measures

We implement industry-standard security practices:

  • Encryption in Transit: All data transmission uses HTTPS/TLS encryption
  • Encryption at Rest: Authentication tokens and sensitive data are encrypted in our databases
  • Access Controls: Role-based access controls limit internal access to data
  • Authentication: Secure login mechanisms protect your account

Important Notice: As a startup, we do not currently hold formal security certifications (e.g., SOC 2, ISO 27001). We implement reasonable security measures appropriate to our size and resources.

7. YOUR RIGHTS UNDER GDPR

As a data subject in the European Union, you have the following rights:

7.1 Right of Access (Art. 15 GDPR)

You may request a copy of the personal data we hold about you.

7.2 Right to Rectification (Art. 16 GDPR)

You may request correction of inaccurate personal data.

7.3 Right to Erasure (Art. 17 GDPR)

You may request deletion of your personal data. We will delete your data within 30 days of your request.

7.4 Right to Data Portability (Art. 20 GDPR)

You may request your data in a structured, commonly used format. This feature is not yet automated but can be provided upon request.

7.5 Right to Withdraw Consent (Art. 7(3) GDPR)

You may revoke access to your Google Ads account at any time through:

7.6 Right to Object (Art. 21 GDPR)

You may object to processing of your personal data.

7.7 Right to Lodge a Complaint

You may file a complaint with your local data protection authority. In Germany:

To exercise any of these rights, contact us at: hello@pi-optimal.com

8. INTERNATIONAL DATA TRANSFERS

Your data is primarily stored within the EU (Azure Europe West - Netherlands). AI processing occurs in Azure Sweden (within the EEA).

Microsoft Azure is covered by the EU-U.S. Data Privacy Framework and provides appropriate safeguards for data transfers.

9. CHILDREN'S PRIVACY

pi-automate is not intended for users under 18 years of age. We do not knowingly collect data from children. If you believe we have collected data from a minor, please contact us immediately at hello@pi-optimal.com.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last Updated" date
  • Sending an email notification for material changes

Continued use of pi-automate after changes constitutes acceptance of the updated Privacy Policy.

11. CONTACT INFORMATION

For questions, concerns, or to exercise your rights:

Email: hello@pi-optimal.com

Postal Address: pi-optimal UG (haftungsbeschränkt) Unter den Linden 15 72762 Reutlingen Germany

Data Protection Officer: For data protection inquiries, contact hello@pi-optimal.com

Effective Date: November 11, 2025

This Privacy Policy complies with:

  • General Data Protection Regulation (GDPR) - EU Regulation 2016/679
  • German Federal Data Protection Act (BDSG)
  • Google API Services User Data Policy