Privacy Policy

This Privacy Policy explains how Promino, a service operated by Nicolas Gutierrez (Bergamo, Italy) (“Promino”, “we”, “us”, or “our”), collects, uses, and protects personal information when you visit promino.co, use the Promino app at studio.promino.co, or use the websites we host on your behalf (together, the “Service”). We are the data controller for the personal information described in this policy, except where we act as a processor on behalf of our customers, as explained below. You can reach us about privacy at info@promino.co.

This policy covers two distinct relationships. First, the data we control as a business: information about visitors to promino.co and about the account holders who use the Promino builder. Second, the data we process on behalf of our customers: the information that visitors submit to websites our customers build and publish with Promino. We keep the two separate throughout this policy because your rights and our responsibilities differ in each case.

We collect the following categories of personal information:

• Account information - your name, email address, and a securely hashed password when you create a Promino account. Authentication is handled through our infrastructure provider, Supabase.
• Billing information - when you subscribe to a paid plan, our payment processor, Stripe, collects and processes your payment details. We do not store full card numbers; we receive limited billing metadata (such as plan, country, and the last four digits) needed to manage your subscription.
• Content you create - the text, images, settings, and site configuration you add when building sites with Promino.
• Support communications - the contents of support tickets, emails, and other messages you send us.
• Usage and technical data - IP address, browser and device information, pages viewed, and server logs, collected automatically to operate and secure the Service.

We use a small number of cookies that are necessary to deliver and secure the Service, including authentication and session cookies in the app. We do not use advertising cookies or track you across other websites. Our use of cookies is described in full in our Cookie Policy.

We process your personal information to:

• provide, operate, and maintain the Service and your account;
• process payments and manage your subscription;
• respond to your support requests and communicate with you about the Service;
• secure the Service, prevent abuse, and debug problems;
• improve our products and understand how the Service is used; and
• comply with our legal obligations.

When you arrive at promino.co from one of our online advertisements, the web address may contain identifiers that the advertising platform adds to your click — including the Google Ads click identifiers gclid, gbraid, and wbraid, and standard campaign tags such as utm_source, utm_medium, and utm_campaign. We read these identifiers from the web address and, if you go on to create an account, store them with your account.

We use this information only to understand which advertisements and campaigns lead people to sign up or subscribe, so we can measure and improve the effectiveness of our advertising. We rely on our legitimate interest (Article 6(1)(f) GDPR) in measuring and improving our marketing. We do not use these identifiers to build advertising profiles or to track you across other websites, and we do not set advertising cookies on our sites — the identifiers are read from the web address and stored on our own servers.

Where we measure the outcome of an advertising campaign, we may share a click identifier together with the related event — for example, that an account was created or a subscription was purchased, and its value — with Google Ireland Limited and Google LLC, so the conversion can be matched to your original ad click. Google processes this data under its own privacy policy. This may involve a transfer to the United States under the European Commission's Standard Contractual Clauses.

If you would prefer that we not store or use these advertising identifiers, contact us at info@promino.co and we will remove them from your account.

Where the GDPR applies, we rely on the following legal bases: performance of a contract (to provide the Service you sign up for and to bill you); legitimate interests (to secure, debug, and improve the Service, and to communicate with you about it), balanced against your rights; consent (where we ask for it, such as optional communications); and compliance with a legal obligation (for example, tax and accounting records).

Promino uses AI to help select sections and generate first-draft content. To provide these features, the inputs you give us (such as a description of your business or the text of a section) are sent to our AI providers, Anthropic (content generation) and OpenAI (text embeddings used for matching sections). These providers process the inputs to return a result and, under our agreements with them, do not use your inputs to train their models. Please do not enter personal or sensitive information into AI prompts that you would not want processed by these providers.

We share personal information with the following trusted providers only as needed to run the Service. Each acts under contract and may process data outside the EU/EEA (see “International transfers” below):

• Supabase - database, authentication, and file storage
• Stripe - payment processing and subscription billing
• Cloudflare - content delivery, domain routing, edge caching, and security
• Fly.io - application hosting
• Resend - transactional and notification email
• Anthropic - AI content generation
• OpenAI - text embeddings for section matching
• Unsplash - stock imagery used in the builder
• Google Fonts - web fonts served on published sites

We do not sell your personal information.

Google (Google Ireland Limited) — advertising and conversion measurement (Google Ads).

When you build a website with Promino and it collects information from your visitors (for example, through a contact or signup form), you are the data controller for that information and we are your processor. We process visitor submissions only to provide the Service to you and according to your settings, including the retention period you choose. You are responsible for having your own privacy notice and a lawful basis for collecting your visitors’ data. We make a data processing agreement available to customers who require one.

Some of our providers are located outside the European Economic Area, including in the United States. Where personal information is transferred outside the EEA, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses or an equivalent transfer mechanism offered by the provider.

We keep your account information for as long as your account is active and for a reasonable period afterwards to meet legal, accounting, and dispute-resolution needs. Visitor form submissions are retained for the period configured on your site and are then deleted automatically. Backups are retained on a rolling basis and overwritten in the ordinary course.

Depending on your location, you may have the right to access, correct, delete, or receive a copy of your personal information; to restrict or object to certain processing; and to withdraw consent where processing is based on consent. To exercise any of these rights, contact us at info@promino.co. If you are in the EU/EEA and believe we have not handled your data lawfully, you have the right to lodge a complaint with your local supervisory authority - in Italy, the Garante per la protezione dei dati personali.

We protect personal information with measures including encryption in transit, hashed credentials, access controls, and reputable infrastructure providers. No method of transmission or storage is completely secure, but we work to protect your information and to notify you and the relevant authorities of a breach where required by law.

The Service is not directed to children and is not intended for use by anyone under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us personal information, contact us and we will delete it.

We may update this policy from time to time. When we do, we will revise the “last updated” date above, and we will provide more prominent notice of material changes where appropriate.

For any question about this policy or your personal information, contact us at info@promino.co, or by post to Promino, Bergamo, Italy.