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PROMO Affiliate Program – Privacy Policy

Welcome to the PROMO Affiliate Program, which gives registered affiliates ("Affiliates") an opportunity to receive commission for successfully referring users to subscribe to PROMO, our online service for creating quality videos (the "Platform" and the "Affiliate Program", respectively). We, at Easy Hi Ltd. ("EasyHi", "we", "us", "our") respect your privacy.

This Privacy Policy (the "Policy") explains our privacy practices for the Affiliate Program. It describes how we collect personal information, use it and share it and the rights and options available to you with respect to your information.

Providing us with your personal information is a choice you make. We appreciate that and thank you for making this choice. You are not legally obligated to provide us with this information, but we do need it to administer the Affiliate Program and let you register to it.

This policy is combined into our PROMO Affiliate Program Agreement (the "Terms"), and is a part of them.

In short...

The following key points of the Privacy Policy are only brought for your convenience. They do not substitute the full Policy.

  • Information we collect. We collect information you actively provide us (for example, when you register to the Affiliate Program or when you ask to redeem your commission) and certain information about the device you use to access the Affiliate Program.
  • Using the information we collect. We use the information we collect to provide you the Affiliate Program’s features and functionalities (e.g., paying you a commission if you successfully referred users to subscribe to the Platform). We also use it to improve and customize the Affiliate Program and the Platform and develop new services. We also process your personal data for marketing purposes, and you have the right to object at any time to processing your personal data for such marketing.
  • Sharing the Information We collect. We may share your information in order to operate, maintain and enhance the Affiliate Program and the Platform. For example, we will share your payment information with our payment service providers, in order to process commission payments.
  • Access to Information. You may request to access your personal information, or have us update, correct or delete such information, if the applicable law provides you those rights. You may also be entitled to obtain from us a copy of the personal data you provided us.
  • Aggregated information. We may use the information we collect from you to create de-identified, statistical or aggregated information, and make it available to others for any purpose.
  • Retention. We retain your information for as long as we deem necessary for the purpose it was first obtained. If you withdraw your consent to us processing your data, we will erase your personal data from our systems and terminate your Affiliate Account.
  • Security. We implement measures to reduce the risks of damage and unauthorized access or use of information, but they do not provide absolute information security.
  • Children privacy. You must be 18 years of age or older in order to be enrolled to be an Affiliate. We do not knowingly or intentionally collect information about children who are under 18 years of age.
  • Changes to the Policy. We may change this Policy, in which case we will seek your consent to those changes.

INFORMATION WE COLLECT

Information you actively provide us

Registration. The Service is available only to registered affiliates. To register as an affiliate and create an Affiliate Account, you will be asked to provide your full name, and your e-mail address. You will also need to choose a username and a password. You may modify your Affiliate Account settings, at any time.

Commission and payout. Prior to any payout of your commission, you will be asked to provide your address, the entity name you are applying on behalf of (if applicable) and your PayPal e-mail, to allow us to wire the relevant commission.

Inquiries. If you contact us for questions or complaints, or for technical support, we will collect the information related to your inquiry. This may include your Affiliate Account name and other contact information, depending on the nature of your inquiry.

Information we automatically collect

Device information. We collect information about your personal computer or mobile device, including its model, its operating system, unique device identifiers, browser type, mobile network information and the Internet Protocol (IP) address through which you accessed the Affiliate Program (if applicable).

CHILDREN'S PRIVACY

If you are not yet 18 years of age, then you may not participate in the Affiliate Program as an Affiliate, and must not provide any personal details to us.

We do not intentionally collect personal information about children who are under 18 years of age. If we learn that a child under the age of 18 provided personally identifiable information to us without verifiable parental consent, we will use commercially reasonable efforts to delete such information from our databases.

USE OF COLLECTED INFORMATION

Your consent serves as the legal basis for processing your information. You may withdraw consent at any time, without affecting the lawfulness of data processing we carried out based on your consent before such withdrawal.

We use the information we collect for the following purposes:

  • Operating the Affiliate Program and providing its features and functionalities, that is, to give Affiliates an opportunity to receive commission for successfully referring users to subscribe to the Platform.
  • Improving and customizing the Affiliate Program and the Platform and developing new services.
  • Sending you updates as well as commercial messages related to the Affiliate Program and the Platform.
  • Providing you with support, handling complaints and contacting you when we believe it is necessary.
  • Enforcing the Terms and this Policy and preventing misuse of the Affiliate Program or the Platform.
  • Complying with any applicable law and assisting law enforcement agencies and competent authorities, if we believe it is necessary or justified.
  • Taking any action in any case of dispute involving you, with respect or in relation to the App.

SHARING INFORMATION COLLECTED

We may share the information outlined in this Policy, with others, in any of the following instances:

  • With third party service providers to operate, maintain and enhance the Affiliate Program and the Platform. We may share your payment information with our payment service providers, in order to process commission payments.
  • If you have breached the Terms, abused your rights to use the Affiliate Program or the Platform, or violated any applicable law. Your information may be shared with competent authorities and with any third party, if we believe it is necessary or justified.
  • If the operation of the Affiliate Program or the Platform is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition).
  • We may share personally identifiable information with our corporate group entities, but their use of such information must comply with the Policy.

ACCESSING, UPDATING OR DELETING YOUR PERSONAL INFORMATION AND OBTAINING A COPY OF IT

You may ask to access the personal information about you that is stored in our systems, or have us update, correct or delete such information. If you wish to exercise any of these rights, contact us at: [email protected]

OBJECTING TO DIRECT MARKETING

Among other things, we use your personal data for marketing purposes. You have the right to object at any time to processing your personal data for such marketing.

AGGREGATED INFORMATION

We may use the information we collect, as outlined above, to compile anonymized or aggregated information. We may share, sell or otherwise communicate and make available such anonymized or aggregated information to any other third party, at our sole discretion.

TRANSFER OF DATA OUTSIDE YOUR TERRITORY

We may store and process information in the EU and in other countries such as the United States. We may also process information using cloud services. The laws in those other countries may provide a lesser degree of data protection than the laws of your own country. You agree to the transfer of your information to such other countries for the purpose of processing as described in this Policy, including through cloud services.

INFORMATION SECURITY

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. These measures do not provide absolute information security. Therefore, it is not guaranteed and you cannot expect that the Affiliate Program or the Platform will be immune from information security risks.

CALIFORNIA RESIDENTS

The following disclosure is made pursuant to California Online Privacy Act (CA Civil Code § 22575): When you use our Affiliate Program or the Platform, other parties, such as Google, may collect personally identifiable information about your activities over time and across different websites or online services.

We do not respond to browsers' "Do Not Track" requests.

EUROPEAN CITIZENS

The following disclosures are made pursuant to the European General Data Protection Regulation (GDPR):

  • You have the right to withdraw your consent at any time; and to submit a complaint to the relevant supervisory data protection authority.
  • Easy Hi Ltd. is the data controller in respect of the processing activities outlined in this Policy.

DATA RETENTION

We retain personally identifiable information for as long as we deem necessary for the purposes set forth above. We may delete any information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

If you withdraw your consent to us processing your data, we will erase your personal data from our systems (unless the data is required for EasyHi to establish, exercise or defend against legal claims), terminate your Affiliate Account, and inform other data controllers to which we have disclosed your personal data of the erasure request. Please remember that the Affiliate Program and the Platform do not provide back-up services for any data or information uploaded or used by you.

NEWSLETTERS

We only send newsletters to registered users and all newsletters we send contain an "unsubscribe" link.

CHANGES TO THIS PRIVACY POLICY

We may change this Policy, in which case we will seek your consent to those changes. If you do not consent to the amended Policy, we may initiate payout of the commission you have accumulated and terminate the Terms and your Affiliate Account and block your access to, and use of, the Affiliate Program.

CONTACT US

You may contact us with any questions or comments, at: [email protected].

Our postal address is: Hauteville Trust (BVI) Limited, P.O. Box 3483, Road Town, Tortola, British Virgin Islands.

Last Update: November 2016