Privacy Policy | Promo.com | Visual Content Creation Platform

Privacy Policy

Your privacy is important to us. We highly value and respect the privacy of the personal information we obtain from you by using our Site, App and/or Services (collectively, the "Service") and we have created this privacy policy (the "Privacy Policy") to inform you about how we collect, use and share your personal information, and our privacy practices in general.

By accessing and using the Services, you agree to be bound by this Privacy Policy. If you do not agree to any of the provisions as set hereunder in this Privacy Policy, you have no right to use the Services. This Privacy Policy should be read together with the Terms of Service and together they constitute the entire agreement between you and us.

This Privacy Policy applies to any and all Personal Information we may collect online including without limitations through our emails and/or by using any of our Services.

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically to read the most updated Privacy Policy. Your continued use of the Services shall be deemed to be your continued acceptance of the terms of this Privacy Policy, as amended.

Information That We Collect

The Personal Information we collect from customers helps provide you with our Services. Here are the types of information we gather:

Information Provided by You. During your use of the Services, we may collect certain Personal Information delivered by you to us either as part of your registration to the Services or in any other way. This personal information may be updated by you from time to time. As a result of your use of the Services, you may supply us with such personal information as your name, e-mail address, uploaded content and metadata such as the source of that content (collectively, "Personal Information").

Automatic Information. When using our Services, we may also collect certain analytical information that may identify you personally, including information that your browser or device generates, such as your IP address, your browser information (including browser type, capabilities and language), your operating system, the date and time you accessed the website, and the Service from which you linked to our Service ("Analytical Information", and together with the Personal Information, the "Information"). In addition, we may collect other information from you (such as location-based data) that have been stripped of your Information. We may group some or all this Information into aggregate data in order to describe the use of the Services to our existing or potential business partners, sponsors, advertisers or other third parties, or in response to a government request. We may also group demographic information that we collect from our users into aggregate data for the same purposes. We reserve the right to use and share any aggregate and anonymized Information with third parties for any lawful purpose. We may associate your Information with non-Personal Information within our database and we treat all the associated information as your protected Information under this Privacy Policy. However, except as noted below, we do not share this associated your Information with third parties.

Use of Information Collected

Internal Use. We use Personal Information for internal purposes only, to improve our Service and to better tailor the Service to meet your needs. In addition, we use the Personal Information collected to analyze Service usage and to deliver information to you about certain promotions, services or items that might interest you. From time to time we may use your e-mail address to contact you regarding Service notices, or to invite you to participate in surveys about your experience using our Service, including new features of the Service. If you agree to participate in a survey, we will also collect your telephone number and any information included in your answers to the survey.

Editing Information. You may review and edit any of your Information by using your e-mail address and password. If you cancel your account, your Personal Information shall be deleted from our database except for residual information within our databases, aggregate information access logs, backup logs and other records, which may or may not contain personally identifiable information.

Resolving Problems. We may use your Personal Information and other data obtained from your current and past activities, to resolve disputes and troubleshoot problems.

We will not sell, trade or rent your Personal Information to others unless you explicitly provide us with permission to do so.

Disclosure of Personal Information

At Your Request. We will not disclose, sell or transfer any of your Information to any third parties, except if you request us to do so as part of the Services.

Legal Disclosures. In the event we are required to disclose Information and other related information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws, we will make such disclosure.

Sale of Business. In the event the ownership of all or a part of our business were to change, your Information and other related information pertinent to the business' operations would likely be transferred to, or licensed for use by, the new owner.

To Protect the Services. We may disclose your Personal Information and other related information in the event we reasonably believe such disclosure is necessary to protect the Services, our rights or property, or the rights of any third party.

Third Party Service Providers. We use third-party service providers to perform certain services on our behalf. We may provide your Information to these third-party service providers when the information is necessary for them to perform their duties. These third-party service providers are contractually restricted from using your Information for any other purpose and required to comply with all applicable laws with respect to your Information and other related information they receive.

Special Cases. We may disclose your Information and other related information, in special cases when we have reason to believe that disclosing such information is necessary to identify, contact or bring legal action against someone who may be violating this Privacy Policy or may be causing injury to or interference with (either intentionally or unintentionally), our rights or property, other users, or anyone else that could be harmed by such activities. You thus authorize us to disclose any information about you to law enforcement or other government officials if we, in our sole and absolute discretion, believe that such disclosure is necessary or appropriate.

Sharing of Information

Our Privacy Policy only addresses the use and disclosure of your Information we collect from you. To the extent that you disclose information to other third parties by using the Services, different rules may apply to the use or disclosure of the Personal Information, which you disclose to them. For example, we may share your information to one or more of those chosen third-party sites or services via application programming interfaces (ā€œAPIā€), such as YouTube API Services, for the purpose of enabling you to use or access their services. We do not control the privacy policies of third parties and users will be subject to the privacy customs and policies of such third parties, such as Google Privacy Policy, and Google Security Settings page which allows you to revoke the API Clientā€™s access to your data.

Protection of Information

Information collected about you is protected in several ways. If you create an account, access by you to your Information is available through a password and unique user ID selected by you. Your password is encrypted. We recommend that you do not divulge your password to anyone. In addition, your personal information resides on proprietary secured servers that only selected personnel and contracts have access to via password.

We use industry standard security measures to protect your Personal Information so that it is not made available to unauthorized parties. However, we cannot guarantee that the Personal Information submitted to, maintained on, or transmitted from our systems will be completely secure. If you have any questions regarding which measures and techniques we use, feel free to contact us at [email protected]

Cookies

The Site uses various types of cookies which help us administer and operate it, as further described in our Cookies Policy

Other Websites, Services and Communities

Please be aware that when you are using the Services or our Site, you could be directed via hyperlinks or other means to third-party websites, services and online communities that are not affiliated with us. These websites, services and online communities may send their own cookies to visitors to collect data or solicit your Personal Information. The privacy policies of these websites, services and online communities may be very different from this Privacy Policy. We are not responsible for the privacy practices of these other websites, services and online communities and cannot guarantee the security of any of your Personal Information collected, used or shared there.

Policy Regarding Children

You must be 13 years old or older to use the Site and the Services; we do not knowingly collect information from children under the age of 13. If we become aware that we have collected Personal Information from a child under the age of 13 years old, we will use commercially reasonable efforts to delete such information from our database. If you are between 13 and 17 years old, you agree that you received your parent or legal guardian's consent to use and access the Site and the Services.

European Citizens

If you are a European resident, the following disclosures are made pursuant to the EU General Data Protection Regulations:

Data Controller

We are the data controller of the personal data we collect via the Service. Promo Ltd. is the data controller of the personal data we collect via the Services and use and share as further described above. We are located at Hauteville Trust (BVI) Limited, P.O. Box 3483, Road Town, Tortola, British Virgin Islands.

Representative In The EU

The European representative of Promo Ltd., for purposes of this Privacy Policy is Promo.com Spolka z ograniczona odpowiedzialnoscia (Promo.com Z.O.O), If you are within the European Economic Area, you may contact our European representative the at the following address: Zelazna 59A Street, 00-848 Warsaw, Poland.

Your EU Rights

You have the right to access the personal information about you that we store on our systems, and have us update, correct or delete it. In addition, you may at any time withdraw your consent to any activity which you provided us your consent. You are also entitled to obtain from us your Information (excluding data we obtained from other sources) in a structured, commonly used and machine-readable format, and have the right to transmit those data to another data controller. If you wish to exercise any of these rights, contact us at: [email protected]

You can also have the right to lodge a complaint to the supervisory authority under the General data Protection Regulations ("GDPR"), in particular in the Member State of your residence, place of work or where the alleged infringement of the GDPR occured. For a list of supervisory authorities in the EU, click here.

Data Retention

We retain personal data as long as we need it for the purposes for which it was obtained or until you ask to delete it. If you ask us to delete the Information, we may still have to retain it to comply with our legal obligations, resolve disputes and enforce our agreements

Legal Basis For Processing Personal Data:

Information Type Purpose Legal Basis
Processing Personal Information Online marketing and provision of the services The legal basis under EU law for processing and collecting your Personal Information is our legitimate interests in operating our Services.
Processing Personal Information Profiled advertising The legal basis under EU law for collecting and processing your Personal Information for profiled advertising purposes is your explicit consent
Processing Analytical Information Operation and enhancement The legal basis under EU law for processing and collecting Analytical Data is our legitimate interests in operating our Apps, ongoing management of our business and business development

Questions

You may direct questions concerning this Privacy Policy by email to [email protected] by adding the word 'privacy' in the subject line.

Last Update: September 2023