Privacy Policy

Effective from: 1 June 2025. Last updated: 19 August 2026. Wersja polska

This privacy policy describes what data we collect, how we use it and how we protect it within the Phanes service available at getphanes.com. The data controller is DSEG spolka z ograniczona odpowiedzialnoscia, with its registered office in Warsaw, ul. Klobucka 8B lok. 106, 02-699 Warsaw, Poland, KRS 0001073261, NIP (tax ID) 9512584109, REGON 527119256, contact: contact@getphanes.com.

1. What data we collect

Providing data is voluntary but necessary to use the Phanes services - without signing in with Google you cannot create an account, and without granting access to the selected ad or analytics accounts you cannot use the corresponding audit and recommendation features. Not providing the data means those features cannot be used.

2. Purpose and legal basis of processing

We use data obtained from Google interfaces (Google Ads, Google Analytics, Search Console) EXCLUSIVELY to provide and improve features visible to the signed-in user. We do not use this data for targeted advertising, creditworthiness assessment or any purposes not directly related to the operation of Phanes.

Phanes uses AI models (Claude, Anthropic) to automatically analyse ad campaign data and to generate recommendations and suggested changes. AI recommendations are advisory in nature - by default, every change to an ad account requires manual approval by the user (human-in-the-loop). If the user deliberately enables autonomy mode, Phanes independently performs only defined, safe optimisation actions within agreed budget limits; this mode can be disabled at any time.

Automated analysis may involve elements of profiling within the meaning of Art. 4(4) GDPR (automated evaluation of ad campaign performance); however, it concerns campaigns and ad accounts, not the evaluation of natural persons. Phanes does not use automated decision-making, including profiling, that produces legal effects concerning the user or similarly significantly affects the user within the meaning of Art. 22 GDPR.

3. Security and protection of sensitive data

Security procedures are in place to protect the confidentiality of your data, and sensitive data (including Google user data) is protected with encryption. Specific mechanisms:

4. Sharing and transfer of data

We do not sell user data. We do not pass on or sell data obtained from Google interfaces to data brokers, ad networks or advertisers. We process data solely to provide the Phanes services. We use the following processors, to whom we entrust data to the extent necessary:

Processors based in the USA (Vercel, Stripe, Anthropic) ensure an adequate level of data protection in accordance with Chapter V GDPR: Vercel - certification under the EU-U.S. Data Privacy Framework (DPF); Stripe - DPF certification and Standard Contractual Clauses (SCC) in the data processing agreement; Anthropic - Standard Contractual Clauses built into the Commercial Terms of Service and Data Processing Addendum.

Separately from the processors above: if you give consent in the cookie banner (section 7), data about your activity on the getphanes.com pages - pages visited, clicks on plan buttons, completed purchases together with amount and currency, and online identifiers (cookies, advertising identifiers) - is received for advertising and analytics purposes by: Google Ireland Limited (Google Tag Manager, Google Analytics, Google Ads) and Meta Platforms Ireland Limited (Meta pixel and Conversions API). To the extent of their own use of this data, these companies act as independent controllers (and, for Meta measurement events, as a joint controller), in accordance with their privacy policies. Data may be transferred to the USA on the basis of EU-U.S. Data Privacy Framework certification. Without your consent none of these tools operate and no data is shared.

5. Google API data - Limited Use

Phanes' use of information received from Google APIs complies with the Google API Services User Data Policy, including the Limited Use requirements. In particular, this means that data from Google Ads, Google Analytics and Search Console: (a) is used exclusively to provide and improve user-facing features; (b) is not transferred to third parties except as necessary to provide the service, as required by law, or with the user's consent; (c) is not used for targeted advertising; (d) is not used to train generalised AI/ML models.

Compliance statement required by Google: "Phanes' use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements."

6. Data retention and deletion

We store ad and analytics account data and access tokens for as long as you use the service. The encrypted data cache is refreshed and overwritten on an ongoing basis. You can disconnect an account or delete your data at any time via the data deletion page or by sending a request to contact@getphanes.com. After an account is disconnected we delete the related tokens and ad/analytics data; after account deletion we delete the user's data without undue delay (as a rule within 30 days), except for data we must retain for legal requirements (e.g. billing documentation/invoices kept for 5 years from the end of the calendar year in which the tax payment deadline passed).

7. Cookies and measurement technologies

Essential cookies (no consent required). Phanes uses cookies necessary for the service to function: maintaining the sign-in session (NextAuth.js), remembering the selected language (phanes_locale) and remembering your consent decision (phanes_consent). These files are not used for tracking and by law do not require consent.

Analytics and advertising cookies (only with consent). If you give consent in the cookie banner, measurement tools loaded through Google Tag Manager operate on the service's pages: the Meta pixel and Google tags (Google Ads, Google Analytics). They are used to measure the effectiveness of our ads (e.g. which ad click ended with a plan purchase) and for site analytics. The legal basis is your consent (Art. 6(1)(a) GDPR). Until you give it, we apply Google Consent Mode v2 with default denial - none of these tools store cookies or send data. Recipients of the data and transfer rules are described in section 4.

Withdrawing consent. You can withdraw or change your consent at any time, as easily as you gave it: . You can also delete cookies in your browser settings. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal.

8. Your rights (GDPR)

You have the right to:

9. Changes to this policy

We will announce material changes to this privacy policy with a notice in the application. The current version is always available at getphanes.com/en/privacy-policy.

10. Contact

For privacy and personal data matters: contact@getphanes.com

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