Privacy Policy & Terms of Use

Introduction

This website (https://consigliere.com)  is operated by Consigliere Labs, Inc, an AI powered creative engine offering services and solutions. 

By accessing or using this website, you acknowledge and agree to these Terms of Use and this Privacy Policy. We are committed to maintaining discretion, integrity, and the protection of personal data.

Personal Data Collection

We may collect and process the following types of personal data:

• Identification and Contact Information: name, email address, phone number, company name, professional role, and any information you voluntarily submit via contact forms or other means of correspondence.
• Business Context Information: details pertaining to potential advisory engagements, project discussions, or prospective collaborations.
• Website Usage Data: including IP address, browser type, operating system, and interaction data, collected through standard analytics tools and cookies.

Purpose of Processing Personal Data

We process personal data solely for legitimate business purposes, which include:

• Responding to inquiries and expressions of interest.
• Communicating with clients, prospective clients, and professional contacts.
• Managing the delivery of our services and maintaining professional relationships.
• Improving the functionality and security of our website.
• Fulfilling legal and regulatory obligations.

We do not engage in profiling or automated decision-making based on personal data.

Google Sign-In and Google User Data

Our client and team applications, including Consigliere Publisher, our brand studio apps, and the connectors that let AI assistants such as Claude use those apps, let you sign in with your Google account. When you do, Google shares the following with us, and nothing more:

• Your name and profile photo, so we can show who is signed in.
• Your email address, so we can confirm which workspaces, brands, and documents you are allowed to see.
• Your Google account ID, so we can recognize you the next time you sign in.

We use this information only to sign you in, to control your access to the documents and brand workspaces shared with you, and to record who created or changed them. We do not use it for advertising, we do not sell it, and we do not share it with anyone except the infrastructure providers that run our applications (Google Cloud and Firebase). We do not request access to your Gmail, Google Drive, Calendar, contacts, or any other Google data.

Consigliere’s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

We keep this information while your account is active. You can ask us to delete it at any time by emailing hello@consigliere.com, and we will delete it within 30 days. You can also revoke our access at any time from your Google Account permissions page.

Meta Advertising Data

Consigliere Ads, our internal performance dashboard, uses Meta’s Marketing API to read advertising data from the Meta ad accounts of clients who have given us access. It connects server side, with a Meta Business Manager system user, and is not a consumer product: access is limited to authorized Consigliere team members, who sign in with their work Google account, and, when Meta reviews the app, a test account we provide for that review. Our clients’ customers and the people who see their ads never have accounts in it.

Consigliere Ads does not use Facebook Login and does not request Meta consumer permissions such as email, public_profile, user_friends, user_gender or user_birthday. It has no access to anyone’s personal Facebook or Instagram data.

Through the Marketing API we read:

• Account structure: ad account, campaign, ad set and ad IDs and names.
• Performance metrics: spend, impressions, clicks, conversions, return on ad spend, and video metrics, reported in aggregate by Meta.
• Creative: the images, videos, thumbnails and text of the ads, and their previews, which we may tag or transcribe to analyze what each ad does.

We use this data only to report on and improve the advertising we run for that client, and we share what we derive from it only with that client. We do not sell it, use it to target or profile individuals, or combine it with data from other clients’ accounts for anyone else’s benefit. Beyond that client, it goes only to Meta itself (when we call its API), to the infrastructure providers that run the app, and to professional advisors or authorities when the law requires it.

To analyze the creative and write weekly performance summaries, we send the ads themselves and a selection of this data (ad names, performance metrics and transcripts of what the ads say) to Google’s Gemini models on Vertex AI, part of Google Cloud. Google processes it as our service provider under its Google Cloud terms and does not use it to train its models. The results are shown only to Consigliere and to the client whose ads they describe.

The app runs on Google Cloud (Cloud Run, with Firebase for sign-in), and the data is kept in Google Cloud Storage and our analytics warehouse, with access limited to authorized Consigliere personnel and systems. Like most web applications, it also keeps standard technical logs (timestamps, request paths, IP addresses and browser details) for security, reliability and debugging. We keep advertising data, and the sign-in records of the people who use the app, for as long as we work with the client and as long as needed to meet legal or contractual obligations and keep a security audit trail, and then delete or de-identify them.

A client can withdraw our access at any time by removing Consigliere from their Business Manager or ad account, and can ask us to delete the data we hold for their accounts by following the steps on our Data Deletion page.

Data Sharing and Disclosure

We do not sell, rent, or otherwise disclose personal data to third parties, except as necessary to facilitate the above purposes, in which case we may share data with trusted service providers (such as website hosting, email platforms, or analytics providers), subject to appropriate confidentiality and data protection agreements.

Children

This website and our applications are not directed to children, and are not intended for anyone under 16.

Data Security

We implement appropriate technical and organizational measures to safeguard personal data against unauthorized access, loss, alteration, or misuse, in accordance with applicable data protection laws and industry standards.

Use of Cookies

This website uses cookies and similar technologies to enable core functionality and to gather usage statistics. By using this site, you consent to our use of cookies as described herein.

You may adjust your browser settings to manage cookie preferences.

Your Rights

Subject to applicable laws, including the UK GDPR and other relevant data protection regulations, you may have the right to:

• Access the personal data we hold about you.
• Request rectification of inaccurate data.
• Request erasure of your personal data.
• Object to or restrict certain types of processing.
• Lodge a complaint with an appropriate supervisory authority.

To exercise these rights, email us at hello@consigliere.com.

Amendments to this Policy

We reserve the right to update or amend these Terms of Use and this Privacy Policy at any time. Changes will take effect upon posting on this page, with an updated effective date.