Legal
Privacy Policy
How PAIQ RAAS, S.L. collects, uses, and protects your personal data.
PAIQ RAAS, S.L. ("PAIQ", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our platform at paiq.io.
Company details:
PAIQ RAAS, S.L.
NIF: B27677392
Málaga, Spain
hello@paiq.io
1. Who This Policy Applies To
This policy applies to:
- Account holders — Instagram creators and businesses who register for PAIQ
- Website visitors — anyone who accesses paiq.io
- Message senders — individuals who send DMs to an Instagram account managed by PAIQ (see Section 6 for the specific legal basis applied to senders)
2. What Data We Collect
We collect the following types of personal data:
Account information
- Name and email address (when you register)
- Billing information (processed by Stripe — we do not store card details)
- Instagram account identifiers (username, account ID)
Instagram message data
- DM content that you authorise PAIQ to process on your behalf
- Sender information from incoming messages (as permitted by Instagram's API and Meta's platform policies)
Usage data
- How you interact with the PAIQ dashboard
- Feature usage and settings preferences
- Log data (IP address, browser type, access times)
3. How We Use Your Data
We use your data to:
- Provide and operate the PAIQ service
- Process and generate AI-powered responses to your Instagram DMs
- Personalise your AI agent to match your communication style
- Send you account-related emails (billing, security, updates)
- Improve our platform and fix issues
- Comply with legal obligations
- Support: when you contact us from the dashboard, we use your message, your email address, the account owner's email address, an account identifier, the business name, plan and interface language to answer you (Art. 6(1)(b) GDPR; for a team member who is not the account owner, our legitimate interest in supporting our customers, Art. 6(1)(f) GDPR). Messages reach our mailbox through Resend, which keeps sent emails for up to 30 days; the copy in our mailbox is kept for 1 year after the last message, or 6 years for messages about billing, payments, refunds or cancellations (art. 30 Código de Comercio), then deleted.
We do not sell your data to third parties. We do not use your data or your followers' data for advertising. Customer data is never used to train any third-party AI model (see Section 7).
4. Automated Decision-Making and AI Processing
PAIQ uses artificial intelligence to draft and send replies to Instagram DMs on your behalf. You should know:
- AI-generated replies are produced based on the configuration and Skills you set up in your PAIQ account
- You retain full control: you can review, pause, override, or disable automated replies at any time via the dashboard
- We do not make solely automated decisions producing legal or similarly significant effects on data subjects within the meaning of Article 22 GDPR
- Escalation logic is designed to route sensitive interactions (complaints, refund requests, legal threats) to you for human handling: the assistant pauses on that conversation and you reply from the dashboard.
If you have questions about how a specific reply was generated, contact hello@paiq.io.
5. Legal Basis for Processing (GDPR Article 6)
We process your data under the following legal bases:
- Operating the PAIQ service for account holders: Contractual necessity — Art. 6(1)(b)
- Processing incoming DMs from senders: Legitimate interest — Art. 6(1)(f), to enable the account holder to reply on their own behalf
- Service improvement, security, fraud prevention: Legitimate interest — Art. 6(1)(f)
- Marketing emails: Consent — Art. 6(1)(a)
- Billing records, tax compliance: Legal obligation — Art. 6(1)(c)
6. Processing of Message Senders' Data
When a third party sends a DM to an Instagram account managed by PAIQ, we process their message content and Instagram identifiers to enable a reply. We rely on legitimate interest (Art. 6(1)(f) GDPR): the sender has voluntarily contacted the account, the account holder has a reasonable interest in replying, and the processing is limited to what is strictly necessary for that reply.
In addition to the message itself, we save contact details you write in a message, such as your name, email address or phone number, so that the business you wrote to, and its team, can see them in its dashboard, and the owner of its account can download them. We do not use them for anything else.
Senders may exercise the rights listed in Section 9 by contacting hello@paiq.io.
7. Data Storage, Security, and AI Subprocessors
All customer data is stored on servers located within the European Union (Hetzner, Germany).
We protect your data using:
- AES-256 encryption of off-site backups
- TLS encryption in transit
- Row-level security and tenant isolation in our database
- Access controls limiting who within PAIQ can access data
- Regular security reviews
AI processing: DM content is sent to our AI providers (OpenAI and Anthropic) via API for the sole purpose of generating replies. These providers may retain that content for up to 30 days to monitor for abuse or misuse of their services — or longer where their policies or the law require — and PAIQ does not direct or extend that retention. Under our commercial API terms with them, this content is not used to train their AI models. OpenAI and Anthropic provide this service to us through their Irish companies, OpenAI Ireland Limited and Anthropic Ireland, Limited. Where they process the content in the United States, they make that transfer themselves, under their data processing terms with us.
Instagram message data is processed in real time and is not retained longer than necessary to provide the service.
8. Data Sharing and Subprocessors
We share data only with vetted third-party providers necessary to operate the service. A live subprocessor list is published at paiq.io/subprocessors.
Categories include:
- Payment processing — Stripe (Ireland/US)
- Instagram API — Meta Platforms (Ireland/US)
- AI inference: OpenAI Ireland and Anthropic Ireland, via API, with processing that may extend to the United States; customer data is not used for model training
- Cloud infrastructure: Hetzner (Germany), with encrypted backups on Scaleway (France)
- Email and operational tooling — listed in full at paiq.io/subprocessors
International transfers (Chapter V GDPR): Where we send personal data to a provider outside the European Economic Area, we rely on the European Commission's Standard Contractual Clauses, supplemented where appropriate by additional technical measures, and on the EU-US Data Privacy Framework where the provider is certified under it. OpenAI, Anthropic and Stripe serve us through companies established in the EU; where they process data outside the EEA, they make that transfer themselves, under their own safeguards. Each provider and its transfer basis is listed at paiq.io/subprocessors.
Our email provider, Zoho, stores email in the EU; Zoho support staff in India may access it remotely for technical support, under Standard Contractual Clauses.
We do not share your data with advertisers, data brokers, or any third party for marketing purposes.
9. Your Rights Under GDPR
As a data subject, you have the right to:
- Access — request a copy of the personal data we hold about you
- Rectification — ask us to correct inaccurate data
- Erasure — request deletion of your data ("right to be forgotten")
- Portability — receive your data in a structured, machine-readable format
- Restriction — ask us to limit how we process your data
- Objection — object to processing based on legitimate interest
- Withdraw consent — at any time, where consent was the legal basis
- Not be subject to solely automated decisions with legal or similarly significant effects (Art. 22)
To exercise any of these rights, contact us at: hello@paiq.io
We will respond within 30 days.
Right to lodge a complaint: You also have the right to lodge a complaint with the Spanish supervisory authority, the Agencia Española de Protección de Datos (AEPD) — www.aepd.es — or with your local EU data protection authority.
10. Data Retention
We retain your data for as long as your account is active. Upon account deletion:
- Account data is deleted when the account is deleted, except an account identifier, the subscription record (plan, billing dates and the Stripe reference, with no name, email or card data) and the checkout consent records described in this section. The subscription record is kept for 6 years after account closure (art. 30 Código de Comercio) as the billing record behind the invoices, then deleted. Invoices are kept for 6 years in the systems of our payment provider, Stripe.
- Contract acceptance and checkout consent records are kept for 6 years after account closure (art. 30 Código de Comercio; Art. 17(3)(e) GDPR), then deleted
- Instagram message content, AI replies and contact details saved from messages are deleted at once when all data is deleted from the dashboard settings, or 30 days after Instagram is disconnected. If a free trial ends without a paid subscription, or a paid subscription ends without renewal, the Instagram connection, message content, AI replies, contact details saved from messages and leads are deleted 30 days after the trial or subscription ends. You can also ask at hello@paiq.io, and we will act within 30 days. Backups expire within a further 30 days.
- Anonymised, non-identifiable usage statistics may be retained for service improvement
11. Children
PAIQ is not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you believe we have collected data from a minor, contact hello@paiq.io and we will delete it.
12. Cookies and local storage
We use only cookies and browser storage that are strictly necessary for the service you request, so no consent is required (art. 22.2 LSSI). We use no analytics or advertising cookies and no third-party tracking.
- Dashboard (app.paiq.io): sign-in cookies that keep you logged in and protect your account. The access cookie lasts 15 minutes and the refresh cookie 7 days, renewed while you use the dashboard. Both are deleted when you sign out. During Google or Instagram sign-in, a security cookie is used that expires within minutes.
- Website (paiq.io): the language you choose, saved in your browser's local storage (paiq-language).
- PAIQ Access (access.paiq.io): the language and theme you choose and the report access code you enter, saved in your browser's local storage (va-idioma, paiq-tema, va-codigo) so that your purchased report stays unlocked.
Local storage remains until you clear it in your browser settings. If we ever add analytics or other optional cookies, we will ask for your consent first and update this section.
13. Data Protection Officer
PAIQ RAAS, S.L. has assessed its obligations under Article 37 GDPR. Privacy and data protection questions can be addressed to hello@paiq.io, where they will be handled by the founders directly. We will appoint a formal Data Protection Officer if and when our processing activities meet the Article 37 thresholds.
14. Data Breach Notification
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the AEPD within 72 hours of becoming aware of it, and notify affected users without undue delay where the risk is high (Articles 33 and 34 GDPR).
15. PAIQ Access (access.paiq.io)
PAIQ Access (access.paiq.io). For the accessibility checker, PAIQ is the data controller for purchase data (buyer email and payment data, processed by Stripe; we do not store card data) and for the URLs submitted for analysis and the audit result. Reports are generated on demand and are not stored on our servers; the content of the analysed page, which may include third parties' personal data, is processed only transiently to generate the report and is not retained. If you choose to receive a report by email, the address and the attached report pass through our email provider (Resend), which retains delivery data for up to 30 days under its own terms, and are not stored by PAIQ. The browser holds only your language, theme and unlock code, on your device. PAIQ does not process personal data on behalf of PAIQ Access customers, including Agency subscribers, so no data processing agreement under art. 28 GDPR applies to that service. Legal bases: performance of a contract (art. 6.1.b GDPR) for the service and delivery, legitimate interest (art. 6.1.f) for security and abuse prevention, legal obligation (art. 6.1.c) for tax and accounting records.
16. Changes to This Policy
We may update this policy from time to time. We'll notify registered users by email of material changes and update the "last updated" date above. Continued use of PAIQ after changes constitutes acceptance.
17. Contact
For any privacy-related questions or to exercise your rights:
hello@paiq.io
PAIQ RAAS, S.L. — NIF B27677392 — Málaga, Spain