Client - Privacy Policy

Revised: September 28, 2018

The purpose of this Privacy Policy is to describe how Silicon Vegas LLC d/b/a Promogo (“Promogo”) may collect, use, store, disclose and process (“process”) your information, through your access to or use of the Promogo platform, including the website and associated domains of https://www.promogo.io, related Promogo mobile applications, any other Promogo services or websites that link to this Privacy Policy, all of which as may be updated from time-to-time, including any successor websites, domains, and mobile applications (collectively, the “Service”).

Your privacy is important to us. Promogo encourages you to read this Privacy Policy in its entirety, but here are a few key points of our privacy practices:

HOW PROMOGO COLLECTS AND USES INFORMATION

When you use the Service, Promogo collects certain information about you, such as your name, physical address, email address, telephone number, password and other personal information. You may further provide Promogo messages, media and other content through your use the Service. Promogo may also use cookies and similar technologies to collect information about your activities on the Service. Promogo will process this information to provide you the Service, to communicate directly with you (including advertising), to conduct research and for other purposes to which you consent.

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How Promogo May Share Your Information

Promogo may share information about you with its affiliates, third-party business associates and service providers to help Promogo provide the Service.

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How Promogo Protects Your Information

Promogo takes physical, technological and operational measures to protect the information you provide through the Service against loss, theft and unauthorized access, use, disclosure or modification.

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YOUR rights over YOUR INFORMATION

You may access and modify your personal data through the settings menu on the Service.   You may contact hello@promogo.io for additional assistance with your personal data.

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How Long Promogo Keeps Your Information

Promogo will retain your information as long as necessary for the purposes outlined in this Privacy Policy.

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Additional privacy information

Promogo is located and will process your information in the United States.  The Service is not for use by children under the age of 13 years old. Promogo may update this policy from time to time.

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1.                 General

(a)               Consent. By accessing or using the Service, you consent to the processing of your information in accordance with: (i) this Privacy Policy; (ii) any related terms of service, end user license agreement, enterprise agreement, or services agreement (collectively, “Service Terms”); and (iii) as permitted or required by applicable law.

(b)               Interpretation. For the purposes of this Privacy Policy, the words “such as,” “include,” “includes” and “including” shall be deemed to be followed by the words “without limitation.”

2.                 HOW PROMOGO COLLECTS AND USES INFORMATION

(a)               Information That You Provide Directly. Promogo may ask for or you may provide certain information such as your name, physical address, email address, telephone number, password, and other information. Promogo may retain any such information, as well as messages, media (e.g., photos and video), and other content that you send through the Service or that you otherwise provide to Promogo. Promogo processes this information for general business purposes and to operate, maintain, improve, and provide the features and functions of the Service, and as further described below.

(b)               Information Collected or Received from Third Parties. Promogo may receive information about you from third parties. You should always review and, if necessary, adjust your privacy settings on third-party services before linking or connecting them to the Service. Promogo may also collect information about you from Promogo’s third-party business associates, publicly-available sources and Promogo’s affiliates.

(c)               Analytics information. Promogo may collect, measure and analyze traffic and usage trends for the Service, and Promogo may use third-party analytics tools, including cloud-based tools, to help Promogo for such purposes (“Analytics Tools”). This allows Promogo to understand, among other things, who is using the Service, how they are using it, and ways to improve the Service. Analytics Tools may use cookies and persistent device identifiers to collect and store information about you, such as time of visit, pages visited, time spent on each page, IP address, and type of operating system used.

(d)               Cookies. When you access or use the Service, Promogo may send one or more cookies (small text files containing a string of alphanumeric characters) to your computer that uniquely identify your browser and enhance your navigation within the Service. A cookie may also convey information to Promogo about how you use the Service (such as the pages you view, the links you click and other actions you take), and allow Promogo or Promogo’s third-party business associates to track your usage of the Service. Promogo uses at least two different types of cookies: persistent and session cookies. A persistent cookie remains on your device after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions for removal of cookies. A session cookie is temporary and is deleted after you close your browser. You can set your web browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the Service may not function properly if cookies are disabled.

(e)               Log File. Log file information is automatically reported by your browser each time you access a web page. When you access or use the Service, Promogo’s servers may automatically record certain log file information, such as your web request, internet protocol (IP) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links within the Service, domain names, landing pages and pages viewed.

(f)                Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) allow for the tracking of a user’s response to an email or usage of a website in a manner that does not reveal personally-identifiable information. Promogo may use clear GIFs or similar technologies to assess responses to emails and usage of the Service, such as tracking when emails are opened and which links are clicked by recipients. You can disable the ability of clear GIFs to capture information by blocking cookies.

(g)               Device Identifiers. When you access or use the Service using a mobile device, Promogo may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (UUID). Device identifiers are small data files or similar data structures stored on or associated with your device that uniquely identify your device. A device identifier may consist of data stored in connection with the device hardware, operating system or other software, or data sent to the device by Promogo. A device identifier may convey information to Promogo about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation within the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

(h)               Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Advertising identifiers may be modified or disabled by users in the device operating system’s settings.

(i)                Location Data. When you access or use the Service, Promogo may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (such as latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to Promogo information about how you browse and use the Service. Some features of the site, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

(j)                Commercial Communications. Promogo may use the information Promogo collects or receives to communicate directly with you, such as sending you emails containing newsletters, promotions and special offers. Promogo may also use the information to send you service-related notices (such as account verification, technical and security notices).

(k)               Use of Certain Service-Type Data. Promogo may process the information described in this Section 2 to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (ii) provide custom, personalized content or information; (iii) monitor and improve the effectiveness of the Service; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys.

(l)                Use of Information with Your Consent. Promogo may further process your information for any other purpose for which you provide consent.

(m)             Account Login. If you have an account with the Service and log in while you access or use the Service, the information described in this Section 2 may be collected and maintained in a manner that associates such information with your name or contact information.

(n)               Combining Information. Promogo may combine any of the information that Promogo collects from or about you, from one or multiple sources, and process it in the manner described in this Privacy Policy.

3.                 How Promogo May Share Your Information

(a)               Business Associates and Service Providers. Promogo may share information about you with third-party business associates and service providers that perform services on Promogo’s behalf in connection with the Service. Promogo may also share information about you with any of Promogo’s affiliates for purposes consistent with this Privacy Policy and the Service Terms.

(b)               Business Change. If Promogo becomes involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of Promogo’s business otherwise changes, Promogo may share or transfer your information to third parties in connection with such transaction or change in ownership, including as part of the due diligence process conducted by the parties to a potential transaction.

(c)               Necessary Disclosure: Regardless of the choices you make concerning your information and to the extent permitted or required by applicable law, Promogo may disclose information about you to third parties to: (i) enforce or apply this Privacy Policy or the Service Terms; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect Promogo’s rights, reputation, safety or property, or that of Promogo’s users or others; (iv) protect against legal liability; (v) establish or exercise Promogo’s rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; violation of the Service Terms; or as otherwise required by law.

(d)               Sharing Information. Promogo may share certain service-type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear GIFs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks) with Promogo’s third-party business associates for the purposes described in Section 2. Promogo may also aggregate or otherwise remove all personally-identifying characteristics from your information and share that aggregated, de-identified data with third parties.

4.                 How Promogo Protects Your Information

Promogo takes physical, technological and organizational measures to protect the information you provide through the Service against loss, theft, and unauthorized access, use, disclosure or modification. Promogo encrypts your information and complies with applicable data protection laws, including applicable data breach notification laws, to protect your information. However, Promogo cannot ensure or warrant the security of any information you transmit to Promogo or guarantee that information within the Service will not be accessed, disclosed, altered or destroyed. Communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to Promogo via email.

5.                 YOUR rights over YOUR INFORMATION

(a)               Accessing and Managing Your Personal Data. You may access and modify your personal data through the settings menu on the Service.   To delete, download or restrict use of your personal data, or for any additional assistance or inquiry regarding such data, please contact hello@promogo.io. To help protect your privacy and maintain security, Promogo may take steps to verify your identity before granting you access to the personal data. To the extent permitted by applicable law, a charge may apply before Promogo provides you with a copy of any personal data that it maintains about you.

(b)               Controlling Your Settings. You can manage settings through the settings menu on the Service.  You can limit your browser or mobile device from providing certain information by adjusting the settings in the browser, operating system or device. Please consult the documentation for the applicable browser, operating system or device for the controls available to you. You can also stop receiving promotional emails from Promogo by following the unsubscribe instructions in those emails. Note that unsubscribe is not available for certain emails, such as those concerning your relationship or dealings with Promogo and those necessary to provide the Service.

(c)               Targeted Advertising. You can learn more about targeted ads and your choices to prevent third parties from delivering targeted ads to your browser or device by visiting http://optout.networkadvertising.org/ and http://optout.aboutads.info/. You should be aware that even if you opt out of targeted ads, you may still see ads within the Service, although the ads may not be tailored to your interests.

(d)               Do Not Track. At this time, Promogo does not recognize “do not track” signals sent from web browsers. Third-party services that Promogo uses may collect personal information about individual users and their activities over time and across different websites. In some cases, you may be able to disable tracking mechanisms, but doing so may disable certain features of the Service. To disable tracking, please consult the documentation for your browser, operating system or device. For some devices, it may not be possible to disable tracking mechanisms. Section 2 of this Privacy Policy provides more detail on how Promogo uses cookies and similar technologies.

6.                 How Long Promogo Keeps Your Information

Promogo will retain your information as long as necessary for the purposes outlined in this Privacy Policy, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law.

7.                 Additional privacy information

(a)               International. The Service may be hosted or operated in countries other than the country in which you reside. Those countries may have different data protection laws and regulations from those that apply in your home country. By accessing or using the Service, you authorize Promogo to process and transfer your information in the United States and in any other country where it operates. Please be aware that the governments, courts, and law enforcement, security or agencies of a particular jurisdiction may be able to obtain access to or disclosure of your information as permitted by the laws of that jurisdiction.

(b)               Children’s Privacy. The Service is not directed to children and is intended for use by adults only. Promogo does not knowingly collect personal information from individuals under 13 years of age. If you are under the age of 13, you may not use the Service or submit any personal information through the Service.

(c)               Third-Party Services and Services. The Service may reference or provide links to other websites or resources. If you access any website or resources provided by a third party, this Privacy Policy will not apply. Your interactions with such websites and resources are subject to the privacy policies of the third parties that operate them. Please review those policies carefully to understand how those parties will treat your information.

(d)               Updates to this Privacy Policy. Promogo may update this Privacy Policy from time to time, and the updated version of this Privacy Policy will be effective upon posting. Please check this page to review the most up-to-date version of this Privacy Policy. By continuing to use the Service after an updated version has been posted, you agree that the new policy will apply to you.