Effective Date: September 18th 2018
2. INFORMATION WE COLLECT
“Personal Information” is information that directly or indirectly identifies you, such as your name, email address, and device identifiers.
“Usage Information” is information that, by itself does not individually identify you, such as browser type, operating system, the webpages you viewed, and how long you viewed them. PromoWise generally does not treat Usage Information as Personal Information unless required by applicable law.
We may link together different types of Usage Information or link Usage Information to Personal Information. If linked information directly or indirectly identifies an individual person, then PromoWise treats the linked information as Personal Information.
(a) Provide our Services to you: Most often, the reason we process your information is to perform the contract that you have with us. For example, we use your information to maintain your account.
(b) Legitimate interests: We use your information when we have legitimate interests in doing so. For example, we analyze users’ behavior to continuously improve Services and for administrative, fraud detection and legal purposes.
(c) Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the information provided below.
3. HOW WE COLLECT INFORMATION
User Provided Information: We collect information that you provide directly to us, such as when you create or modify your account, request customer support or otherwise communicate with us. This information includes (a) your name, postal address, email address, telephone number, company name, and title; (b) username, password and other registration information; (c) transaction-related information, such as when you use web applications from us or register for the Services; (d) information you provide us when you contact us for help; and (e) other information you choose to provide and enter using the Services.
Automatically Collected Information: The Services automatically collect information about how you use the Services, such as (i) your mobile device or computer type, including your system and application software; (ii) the type of mobile device or computer you use, the pages and screens you view and how long you viewed them; (iii) your mobile device’s unique device ID; (iv) the IP address of your computer or mobile device; (v) your operating system, traffic data, logs and other communication data; and (vi) metadata and other information associated with other files stored on your device. Some of this automatically collected information is Personal Information.
Information Collected from Third-Party Sources: We may combine information we receive from other sources with information we collect through the Services. For example, (a) if you engage with a third-party site application whose API we use (e.g. Salesforce) or who uses our API, we may receive information about you or your connections from such site or application; or (b) if you are referred to us by one of our referral partners, we receive information about you from such referral partner.
4. DATA COLLECTION TECHNOLOGY
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (i.e., the internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Data Collection Technology helps us improve your experience of the Services by, for example, storing your password, measuring the success of marketing campaigns, compiling statistics related to use of the Services and helping us analyze technical and navigational information about the Services in order to detect and prevent fraud.
We may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, including the language your system uses and the country and time zone in which your computer or device is located.
We also use Google Analytics, which is a Google service that collects aggregate information about use of the Services and reports website trends. Google Analytics does not directly identify individual users. You can learn about Google’s practices and opt out by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
Your Control of Cookies: Some web browsers, including some mobile web browsers, provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. You also may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including PromoWise, do not respond to DNT signals.
5. HOW WE USE INFORMATION
We may use the information that we collect about you to: (a) set up and maintain your registration with the Services; (b) communicate with you; (c) send you marketing and advertising materials; (d) deliver relevant content to you; (e) provide features through the Services; (f) prevent and investigate fraud and other misuses of the Services; (g) protect our rights and property; (h) operate, manage and improve the Services; (i) ensure the technical functionality and security of the Services; (j) administer and improve the Services and your experience on the Services; (k) analyze trends and gather broad aggregate demographic information; (l) statistically monitor how many people are using the Services or opening our emails; (m) develop, improve and protect the Services; (n) research our audience; (o) audit and analyze the Services; and (p) ensure the technical functionality and security of the Services.
6. HOW WE SHARE INFORMATION
PromoWise may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to identify an individual (“Anonymized Information”). PromoWise shares Anonymized Information with third parties and does not limit third parties’ use of the Anonymized Information because it is no longer Personal Information.
Applicable law may require PromoWise to disclose your Personal Information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) disclosure would mitigate PromoWise’s liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of PromoWise, users, customers, business partners or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).
California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to [email protected] or write us at: PromoWise, 200 East Randolph Suite 5100-38 Chicago, IL, 60601.
7. CHILDREN’S PRIVACY
The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.
8. SECURITY OF PERSONAL INFORMATION
PromoWise takes precautions intended to help protect information that we process but no system or electronic data transmission is completely secure. Any transmission of your Personal Information is at your own risk and we expect that you will use appropriate security measures to protect your Personal Information.
You are responsible for maintaining the security of your account credentials for the Services. PromoWise will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of your Personal Information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, PromoWise will provide any such notice that PromoWise must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
We retain Personal Information in identifiable form only for as long as necessary to fulfill the purposes for which the Personal Information was provided to PromoWise or, if longer to comply with law legal obligations, to resolve disputes, to enforce agreements and similar essential purposes.
9. YOUR CHOICES ABOUT INFORMATION
If you would like to review, correct, update or delete Personal Information that you have previously provided to us or if you would like to suppress, restrict or receive an electronic copy of your Personal Information (if these rights are provided to you by applicable law), please contact us via email at [email protected]
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database and any other limitations you would like to put on our use of your Personal Information. For your protection, we only fulfill requests when received from the email address associated with your account. We may need to verify your identity before fulfilling your request.
Please note that we often need to retain certain information for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. We also may not allow you to review certain data for legal, security or other reasons.
(a) the length of time we have an ongoing relationship with you and provide Services to you (e.g., for as long as you have an account with us or keep using the Services);
(b) whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them);
(c) whether retention is advisable considering our legal position (e.g., for statutes of limitations, litigation or regulatory investigations).
10. LINKS TO OTHER WEBSITES AND SERVICES
12. NOTICE TO INTERNATIONAL VISITORS
13. HOW TO CONTACT US
If you have any questions, comments, or concerns about how we handle your Personal Information, then you may contact us at [email protected]