As used in this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within Canada, United States or internationally.
Our primary goals in collecting information are to provide and improve our Site, Application, services, features and content, to administer your use of the Site and Application (together, the "Service") and to enable users to enjoy and easily navigate the Site and Application.
When you register with us through the Site or Application and become a Member and when you choose to post a Listing or purchase a promotion, or when you wish to contact another Member, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you ("Identity Information"). Identity Information includes, but is not limited to, your name, phone number, email address, social security number (SSN), and home postal address, but does not include your credit card number or billing information. In order to process some of your transactions through the Site and Application, we may also ask for your credit card number and other billing information ("Billing Information") (Identity Information and Billing Information together, "Personal Information"). If the address of a Listing you post matches that of your credit card billing address, that address would be considered Identity Information. Some Personal Information is required, like your name and email address, and other Personal Information is optional, like your date of birth. We reserve the right to require address confirmation for products included in Listings. If we require such confirmation, we will contact you via phone or email in order to confirm the address of the Promoter or Business included in the applicable Promo Listing. We use your Personal Information to provide the Service and administer your inquiries.
We collect Personal Information in connection with your registration to join the Service. You can register to join via the Site or Application by completing the required forms.
You can also register to join by logging into online accounts you may have with third party service providers ("SNS")(e.g. Facebook, Twitter); each such account, a "Third Party Account", via our Site or Application as described below. As part of the functionality of the Site, Service and Application, you may link your Promo Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to Promo through the Site, Service or Application; or (ii) allowing Promo to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to Promo and/or grant Promo access to your Third Party Account (including, but not limited to, for use for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating Promo to pay any fees or making Promo subject to any usage limitations imposed by the applicable SNS. If you decide to register by logging into a Third Party Account via our Site or Application, we will obtain the Personal Information you have provided to the applicable SNS (such as your "real" name, email address, profile picture, names of SNS friends, names of SNS groups to which you belong, other information you make publicly available via the applicable SNS and/or other information you authorize Promo to access by authorizing the SNS to provide such information) from your Third Party Accounts and use that information to create your Promo Account and Promo Account profile page and you will become a Member. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available and store (if applicable and as permitted by the SNS and authorized by you) the information in your Third Party Accounts so that it is available on and through your Promo Account on the Site, Service and Application. If there is information about your "friends" or people with whom you are associated in your Third Party Account, the information we obtain about those "friends" or people with whom you are associated, may also depend on the privacy settings such people have with the applicable SNS. If you register to be a part of our Affiliate Program, we will collect your name, website name, website URL, email address and affiliate program payment preferences (including, but not limited to, bank account number and routing number, bank account name, PayPal account email address, billing address and other financial information). We use this information to enable your participation in the Affiliate Program and to make payments related thereto. More information on our Affiliate Program is accessible at promo.co/affiliates
We also collect the other information that you provide as part of registration and the administration and personalization of your Promo Account profile (e.g., without limitation, zip code (on its own), your location passed from the native mobile application and individual preferences or demographic information) ("Non-Identifying Information").
We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your demographic information). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Promo Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site, Application and Service are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We also use your Personal Information to contact you with Promo newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your "Notifications" information. (See "Changing or Deleting Information," below.) Please note that we may also use your Personal Information to contact you with information related to your use of the Service; you may not opt out of these notifications.
When you visit the Site and Application, whether as a Member or a non-registered user just browsing (any of these, an "Promo User"), our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type or the webpage you were visiting before you came to our Site and Application, pages of our Site and Application that you visit, the time spent on those pages, information you search for on our Site and Application, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Application and the Service and for the Site and Application's technical administration, to increase our Site and Application's functionality and user-friendliness, and to better tailor our Site and Application to our visitors' needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Our Site and Application may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site and Application are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
As part of the Service, Promo Users may communicate with Promo Members through use of the "Contact Owner", "Newsletter Subscription", and "Ask Question" feature on the Site and Application. The message they create in the corresponding template will be sent from Promo to those email addresses on their behalf. These email addresses will be used only for the purpose of sending the email communication to the addressee.
Identity theft and the practice currently known as "phishing" are of great concern to Promo. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your Promo Account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website at http://www.ftc.gov.
The Site, Application and Service can be used to facilitate the listing of promotions and purchase of Goods or Services. Listings for such Goods or Services are made available via the Site, Application and Service by Owner or designated Promoter. Listings posted by Promoter, ratings and reviews of Promoter and Customers, and the Profile Information (as defined below) of Promoters and Customers, are visible to any Promo User.
When you create an Promo Account, we will set up an Promo Business profile page for you. Your Promo microsite page will include your username, name, address, bio, and website. Any information you choose to provide as part of your Profile Information will be publicly visible to all consumers and consequently should reflect how much you want other users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage members to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your Profile Information at any time.
If you post a Promo Listing, we may publish that Listing publicly via the Site and Application and may enable third parties to publish your Listing on their websites through the use of an HTML embed "widget". We may also display the geographical location of your Promo Listing in the form of a map so that potential Customers can see the general area and neighbourhood of your location.
If you request to make a purchase via the Site, Application and Service, Promo will share the following information about you with the applicable Promoter or Seller: (i) your first and last name, (ii) a link to your Promo Account profile page, (iii) your shipping address and (iv) your email address. All of this information will enable the Seller to ship any items and complete your purchase.
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site and Application-related services (e.g., without limitation, maintenance services, database management, web analytics, fraud detection services relating to the activity of Promo Users and improvement of the Site and Application's features) or to assist us in analyzing how our Site, Application and Service are used. These third parties may have access to your Personal Information; if they do, this access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose. We may also provide Personal Information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.
Promo cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Promo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or appropriate to administer our Promo Sellers.
Promo may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
All Members may review, update, correct or delete the Personal Information in their registration profile by contacting us at [email protected] or editing the relevant part of their profile. If you would like us to cancel your Promo Account, please contact us at [email protected] Please note that, if you cancel your Promo Account, any reviews you have posted via the Site and Application will remain publicly viewable via the Site and Application. Please see below for privacy contact information.
Promo is very concerned with safeguarding your information. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site and Application, you can contact us.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site and Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Our Site and Application contain links to other websites. If you choose to visit an advertiser by "clicking on" a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
With your consent we may post your testimonial on the Site and Application along with your name. If you want your testimonial removed please contact us.
The Site and Application are not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.