Effective Date: November 2, 2016
We are firmly committed to our users, and know that your privacy is important to you and, thus, for us as well. We undertake several measures to protect your privacy, and we are honored to receive your trust. Please, feel free to contact us via telephone or email if you have any queries for us. Rest assured that we will never spam your inbox or otherwise disclose your personally identifiable information (“PII”) to any third party without your prior express permission. Overall, thePromo works hard to earn and keep your trust, so it adheres to the following principles to protect your privacy:
- We do not rent or sell your PII to third parties.
- We do not disclose your contact information with other users or third parties without your consent.
- Any PII that you provide to thePromo will be secured with industry standard safety protocols and technology.
The words “collect”, “use”, “process”, “treat”, “disclose” and analogous, as used herein, are related to PII and other data that we may receive from our clients, users and/or visitors, including cookies inside a computer, along with statistical and analytical complication thereof in order to create aggregate databases and marketing strategies.
Scope of this Policy
This Policy is applicable to users and visitors who enter our Site. thePromo is an online discount and rebate coupon and code online marketplace where its users may browse an online directory of discount and rebate coupons for third party products and services, among other Services and functionalities offered by us from time to time. Users are able to access the Site on a free basis, where they will be able to browse discount and rebate coupons opportunities, among other functionalities that we may include from time to time. Your access to the Site is only offered for your individual, non-commercial use, and not for the use or benefit of any third party you may represent.
When you register with thePromo you will need to provide certain PII to us, including but not limited to, your name, last name, phone number, IP address and email. We will store your PII for the sole purpose of improving your shopping experience. We will use this data to send updates on your order and provide you with customer support. If you do not wish to disclose any PII, then your sole remedies shall be to close this web tab, delete your account and/or exit the Site. Our Site or ads do not collect any sensitive personal data about you (i.e. gender, racial origin, financial information).
Please be aware that if you post information on a public forum or bulletin board, any PII you elect to disclose therein there may or will be read, collected and/or used by other users of such forums and could be used to send you unsolicited messages.
thePromo does not knowingly collect any kind of information from persons under the age of thirteen (13). Through the simple use of our Services and/or browse of the Site, you hereby represent and warrant that you are at least eighteen (18) years of age --or older-- as of the date of first access to the Site, and, if you are still a minor (which may depend on the jurisdiction where you reside), are using the Site under the direct supervision of your parent or legal guardian.
Information collected, purpose and use
In order for us to provide our Services, and to improve the shopping experience for our users, clients and/or visitors, we will need to undertake the storage, use, combination, integration, disclosure, process and transfer of certain PII, either among our affiliates or other authorized third parties. We generally collect, use and disclose your PII to:
- Verify your e-mail address; send password retrieval links and other account notices.
- Provide news regarding our Services and Site.
- Send communications and updates about your orders.
- Improve your shopping experience and provide you with customer support
- Develop, research, process, safeguard and improve our communications and Services.
- Answer to queries and suggestions you submit to us.
- Analyze trends, track member user patterns and recommend products and services that may be of interest to you.
Accordingly, we will undertake the open and transparent management of your PII and will: (i) inform you about how your personal information may be used and disclosed (including overseas); (ii) maintain the safety and integrity of your personal information; and/or (iii) enforce your individual right to access and correct your personal information. Passwords and financial data are stored in encrypted databases, which we cannot access. If you need a new password, we will send you a link for a new one.
Our Site may offer you the functionality of using your social media credentials (e.g. Facebook, Google, and Twitter) to use single-sign-off into our Site, and in that manner we may also collect certain PII from you as you log onto our Site. We will not collect more information from you when using your social media credentials beyond the personal information such third parties disclose to us.
Control of your information
Our users, visitors and registered members will generally be able to edit, select or delete the amount and type of PII they may disclose to us when using our Site. We continuously try to improve our user experience, and strive to provide you the best choices for the disclosure, edition or removal of your PII being processed by us, as well as to respect and enforce your right to privacy.
Safety of your information
We use industry standard protocols and technology to protect you registered user information and PII, such as VeriSign and Secure Socket Layer (SSL) sessions. Our Secure Socket Layer encrypts all transaction data for transmittal in a format that prevents data theft by unauthorized third parties. However, please take into account that the Internet and e-mail transmissions are not a secure or error free communication means. Additionally, we may undertake internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store PII.
Information release and disclosure
We must reserve our right to disclose your PII, when we or our affiliates, licensors, officers, agents and/or representatives reasonably believe it necessary to protect our interests or where you result to be in breach of our Terms and/or Policy. Accordingly, we will have the right to disclose any and all collected PII and/or personal data, under the following circumstances:
- If required under applicable law, rules or regulations;
- In response to a valid request or subpoena from a government or law enforcement agency;
- To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices);
- To defend the property, rights and integrity of any of our users, advertisers or licensors;
- To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.
From time to time, we may temporarily share our users' PII only to our authorized third party service providers, which perform certain services on our behalf, and only after your express consent. The purposes of this temporary transfer may include, but are not limited to: customer support service, community management, web analytics, advertising, marketing, surveys, contests, promotions and other features offered via our Site.
Commercial Electronic Email Messages
From time to time, we will ask you for express permission and consent to receive Commercial Electronic Email Messages (‘CEM’), which we will sometimes send from or to computers to our users. A CEM is a message in an electronic format (e.g. emails, SMS, social media messages, push notifications and other form of communications) which is then sent to an electronic address (e.g. email, instant message accounts, smart phone, social media profile) that contains a message asking recipients to participate in commercial activities (e.g. purchase of products and services).
Express consent for CEMs does not apply for those that we may send for security, refunds or guarantees of products and services of our Site. Our optional email newsletters are also considered CEMs, and therefore you may subscribe or unsubscribe from them at will, usually on your account settings, or by following the unsubscribe links contained therein.
Personal data owners’ rights and revocation of consent
Any user of our Site shall have the right to make a request to us in order to enforce his rights to:
- Access his PII;
- Rectify his PII, when inaccurate or incomplete;
- Cancel the process of his PII;
- Object --with legitimate reasons-- the process of his PII; and/or
- Revoke his consent for the use, storage, treatment, process and/or, disclosure of his PII.
The enforcement and upholding of your ’ARCO’ rights should be requested to us in writing and must include, at a minimum, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your ARCO request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PII with regard to which you seek to enforce any of your ARCO rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
In order to enforce of your ARCO rights, please contact us by email. Upon receipt of your ARCO request, and after due review, we may then edit, deactivate and/or delete your PII from our Site. Please take into account that we may not be able to delete all of your data from some our databases and that, if so is the case, we will then mark such data as permanently inaccessible.
Cookies and beacons
Third party sites and services
Our Site and Services may also implement hyperlinks to the websites of our commercial partners and other third parties. If you click on such links, you are choosing to visit such websites, and will be redirected thereto. Please take into consideration that we are not responsible for the privacy and personal data practices undertook by such third parties (including any tools, cookies, information or content contained thereinto), and that we do not have control over the manner in which such third-parties may collect, process, treat or use your PII.
Please be advised that when you use a link to go from our Site or Services to another website, our Policy and Terms are no longer into effect and that your browsing thereof is at your own and final risk. In addition, any banner or ad that we may have on our Site does not constitute any endorsement of any third party thereof.
From time to time, we may use Google Analytics, AdWords and AdSense tracking codes, along with other third party software tools (such as remarketing codes) in order to collect marketing analytics about the pages you browse on our Site or when you undertake specific actions through our Services. This is to provide you a customized, targeted advertising experience. For example, third party vendors may show you thePromo ads on certain websites across the Internet, even after you leave our Site. The collected information is anonymized, meaning it cannot be tracked back to individuals. Using Google and other analytics tools, we learn how to optimize, and serve ads based on a user’s past visits, giving you a better experience.
In order to enforce and uphold your right to privacy, you have the option to elect not to receive this type of advertising from us or third parties, now or in the future. You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org. In addition, you may set browser and system preferences for how Google and other third parties serve ads to you and even permanently block some or all browsing ads, by using tools such as ad-blockers and browser plug-ins.
International Residents Notice
thePromo has its headquarters in the United States of America (‘USA’). Henceforth, your PII may be accessed by us or our affiliates, agents, partners, advertisers or third party service providers elsewhere, and you hereby consent to such access and transfer by providing us such information. If you are accessing our Site from other regions, you ought to know that you are thereby transferring your PII to the USA and, thus, you hereby consent to such transfer to the USA or to any other country in which we operate.
We reserve the right to amend, change and update our Site, Service, Policy and/or Terms from time to time, at our sole and final discretion, and therefore we strongly suggest that you revisit our Policy and Terms frequently for any updates. We will conspicuously post the update on the Site, send you an email and/or otherwise conspicuously notify you of any material changes to the Policy. Your continued use of the Service after the effective date of modifications to the Policy, either by registration or simple use, thereby indicates your acknowledgement of any modifications thereof.