This Privacy Policy explains how we use the personal information that Promo Coders collects or generates both in relation to this website and our products and services.
This Privacy Policy applies to your use of the Promo Coders Website and/or Promo Coders Products (as defined below). If you do not wish to be bound by this PP and/or the TOU, exit the Promo Coders Website, Publisher Asset (as defined below) and/or Promo Coders Products terminate your usage (or attempt to use) of the Product(s).
This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on the Promo Coders Website.
1. BACKGROUND
2. THE PRODUCTS AND SERVICES WE PROVIDE
3. THE TYPES OF PERSONAL DATA WE COLLECT
4. HOW WE USE USER'S INFORMATION
5. DISCLOSURE OF USER'S INFORMATION TO THIRD PARTIES
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
7. HOW WE SAFEGUARD USER'S INFORMATION
8. HOW LONG WE KEEP USER'S PERSONAL DATA
9. USER'S RIGHTS
10. DESIGNATED REPRESENTATIVE
11. QUESTIONS AND CONCERNS
1.1 Promo Coders with its registered office at 8 The Green, Ste A, Dover, DE 19901 and other companies in the Promo Coders group collect and use certain Personal Data (as defined below). Promo Coders is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
1.2 At Promo Coders we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Promo Coders in the course of carrying on commercial activities.
1.3 We use the following definitions in this Privacy Policy:
(A) "Customer" a publisher who owns/controls/operates Internet assets (such as Websites) ("Publisher Assets") who incorporates Promo Coders Products in his assets ("Publisher") or an advertiser who provides us with content to be served through Promo Coders Products and/or Publishers assets ("Advertiser"), or with whom Promo Coders has a contractual relationship
(B) "Personal Data" means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Promo Coders (or its representatives or service providers).
(C) "Promo Coders", "we" or "us" means Promo Coders and other companies in the Promo Coders group.
(D) "Promo Coders Website" www.promo-coder.com or any other Promo Coders website displaying this Privacy Policy.
(E) "User" a person making any use of Promo Coders Website and/or Promo Coders Products.
2.1 This Privacy Policy concerns the following categories of information that we collect about the User when providing the following products and services:
(A) Information we receive through our websites ("Promo Coders Websites");
(B) Information we receive through our products ("Promo Coders Products");
(C) Information we receive through our support or cloud-based services ("Promo Coders Services").
2.2 Personal Data may be collected from (a) Promo Coders Websites – for example with respect to personnel of our Customers engaging us through the Promo Coders Website; (b) Promo Coders Products – for example when a User interacts with Publisher assets.
3.1 Information that a User provides to Promo Coders. This includes information about Users that they provide to us. The nature of the services Users are requesting will determine the kind of Personal Data we might ask for, though such information may include:
(A) Basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
(B) Any information that a User chooses to share on Promo Coders internet forums which may be considered Personal Data.
3.2 Information that we collect or generate about Users. This includes:
(A) A file with Users' contact history to be used for enquiry purposes so that we may ensure that Users are satisfied with the services which we have provided to them;
(B) Information on the internet usage or browsing habits of Users of Publisher Assets;
(C) The internet browser used, the internet device operating system and device ID, IP address (from which geo location may be extracted to a level of a city)
3.3 Information we obtain from other sources:
(A) Cookies.
(B) Anonymized data. In addition to the categories of Personal Data described above, Promo Coders will also process further anonymized information and data that is not processed by reference to a specific individual.
4.1 Users' Personal Data may be stored and processed by us in the following ways and for the following purposes:
Business operation
(A) to understand Users needs and interests;
(B) Through Promo Coders Products, on Publisher Websites, we may provide advertisements to Users based on their recent browsing behaviour;
(C) To communicate with Users in order to provide them with services or information about Promo Coders and Promo Coders Products;
(D) To allow Users to use and access the functionality provided by the Promo Coders Products and/or Promo Coders Website;
(E) To assess Users' application for Promo Coders Products and/or Promo Coders Website, where applicable;
(F) To set up Customers to use Promo Coders Products and/or Promo Coders Website;
Security purposes
(G) To conduct analysis required to detect malicious data and understand how this may affect the User and/or our IT system;
(H) For statistical monitoring and analysis of current attacks on devices and systems;
5.1 We may share Users' Personal Data within the Promo Coders group of companies for the purposes described above.
5.2 We may also share Users' Personal Data outside of the Promo Coders group for the following purposes:
(A) With our business partners (such as Promo Coders Customers);
(B) With third party agents and contractors for the purposes of providing services to us;
(C) If we sell our business or assets;
(D) To the extent required by law;
(E) If we are acquired by a third party;
6.1 Promo Coders is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis.
6.2 Where we transfer Users' Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements.
7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information.
7.2 As a condition of employment, Promo Coders employees are required to follow all applicable laws and regulations, including in relation to data protection law.
8.1 The purpose for which we are using it – Promo Coders will need to keep the data for as long as is necessary for that purpose;
8.2 Legal obligations – laws or regulation may set a minimum period for which we have to keep Users' Personal Data.
9.1 In all the above cases in which we collect, use or store Users' Personal Data, Users may have the following rights and, in most cases, Users can exercise them free of charge:
(A) The right to obtain information regarding the processing of Users' Personal Data and access to the Personal Data which we hold about them;
(B) The right to withdraw Users' consent to the processing of Users' Personal Data at any time. Please note, however, that we may still be entitled to process Users' Personal Data if we have another legitimate reason for doing so;
(C) The right to request that we rectify Users' Personal Data if it is inaccurate or incomplete;
(D) In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible;
(E) The right to request that we erase Users' Personal Data in certain circumstances. Please note that there may be circumstances where Users ask us to erase their Personal Data but we are legally entitled to retain it;
(F) The right to object to, or request that we restrict, our processing of Users' Personal Data in certain circumstances;
(G) The right to lodge a complaint with the relevant data protection regulator if Users think that any of their rights have been infringed by us.
9.2 Users can exercise their rights by contacting us using the details listed in Section 12 below.
10.1 Certain content is made available through the Promo Coders Products and/or Promo Coders Website is of third parties. Such content (which may include targeted advertising content) is made available to Users by link to such third parties sites or products, ads displayed on their Internet device, or otherwise. Promo Coders does not control the content made available by such third parties or the practices they employ. Promo Coders is not and will not be liable or responsible for any content provided by such third parties or the practices they employ. Users are advised to check the privacy policies and terms of use of any third party before interacting or making any use of such third party's software, site or product.
10.2 Promo Coders Products and/or Promo Coders Website may also include social media features and scripts, such as the Facebook Like button and widgets, or interactive mini-programs that run on our site. These features, if Users decide to use them, may collect their IP address, which page they are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Users' interactions with these features are governed by the privacy policy of the entity providing it.
The Promo Coders Products and/or Promo Coders Website content is intended for adults and we will not knowingly collect personal information from children under 16 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If a User is the parent or legal guardian of a child under age 16 who they believe has submitted personal information to the Promo Coders Products and/or Promo Coders Website, they should contact us immediately.
If you have any questions or concerns about Promo Coders's handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information:
Address: 8 The Green, Ste A, Dover, DE 19901
Email Address: [email protected]
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Promo Coders's Privacy Officer will provide you with the contact information for that regulator.