Revised: September 28, 2018
Promogo may share information about you with its affiliates, third-party business associates and service providers to help Promogo provide the Service.
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.
You may access and modify your personal data through the settings menu on the Service. You may contact firstname.lastname@example.org for additional assistance with your personal data.
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.
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.
(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.
3. How Promogo May Share Your Information
(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.
(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 email@example.com. 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.
6. How Long Promogo Keeps Your Information
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.