Privacy Policy

1. Who we are

Dirigent is a service provided by ICM AS (hereinafter referred to as "we", "us" or "our"). We are the data controller for the processing of your personal data in connection with our service.

2. What personal data we collect

We collect the following categories of personal data:

• Account information — name, email address and password upon registration.
• Payment information — billing details and payment history. Card details are handled by our payment provider and are never stored by us.
• Google Ads data — campaign data, ad groups, keyword statistics, budgets and performance metrics retrieved via the Google Ads API when you connect your account.
• Usage data — information about how you interact with the service, e.g. page views, clicks and AI chat history.
• Technical data — IP address, browser type, device information and cookies.

3. How we use your data

We use your personal data to:

• Provide and maintain the service, including AI-driven optimization of your Google Ads campaigns.
• Manage your account and authenticate your identity.
• Process payments and send receipts.
• Communicate with you about service updates, notifications and support.
• Improve the service through analysis of usage patterns (anonymized and aggregated).
• Fulfil legal obligations.

4. Legal basis for processing (GDPR)

We process your personal data based on the following legal grounds:

• Contract — processing necessary for the performance of the contract between you and us (e.g. providing the service, managing your account).
• Legitimate interest — to improve our service, prevent misuse and ensure security, where our interests do not override your rights.
• Consent — for non-essential cookies and marketing communications. You may withdraw your consent at any time.
• Legal obligation — where we are required to process data by law (e.g. accounting requirements).

5. Sharing with third parties

We never sell your personal data. We share data with the following categories of recipients:

• Payment providers — to process payments securely.
• Google Ads API — to read and optimize your campaigns according to your instructions. We only access through the permissions you grant us.
• AI providers — to provide AI analysis and chat features. Data is sent in minimized form.
• Hosting and infrastructure providers — to operate the service securely.
• Authorities — if required by law.

6. Data storage and security

We store your personal data for as long as your account is active or as long as necessary to fulfil the purposes described in this policy. When you delete your account, your personal data will be deleted within 30 days, except for data we are required to retain by law.

We implement appropriate technical and organizational measures to protect your data, including encryption in transit (TLS), encrypted storage of sensitive data and strict access controls.

7. Your rights

Under the GDPR, you have the following rights:

• Right of access — you may request a copy of the personal data we process about you.
• Right to rectification — you may request that we correct inaccurate data.
• Right to erasure — you may request that we delete your data ("the right to be forgotten").
• Right to data portability — you may request to receive your data in a structured, machine-readable format.
• Right to object — you may object to processing based on legitimate interest.
• Right to restrict processing — you may request that we restrict processing under certain circumstances.

To exercise your rights, contact us at [email protected]. We will respond within 30 days.

8. Cookies

We use cookies and similar technologies to improve your experience. For detailed information about which cookies we use, their purpose and lifespan, see our cookie policy.

9. Contact information

If you are not satisfied with how we process your personal data, you have the right to file a complaint with the relevant supervisory authority (e.g. the Swedish Authority for Privacy Protection or the Norwegian Data Protection Authority).

10. Changes to this policy

We may update this privacy policy from time to time. In case of significant changes, we will notify you via email or through a clear notice in the service. The latest version always applies and is available on this page.