On 25 May 2018, the EU General Data Protection Regulation (GDPR) replaced the 1995 EU Data Protection Directive (European Directive 95/46/EC). Sites Promo.academy and the Promo.academy (hereinafter Promo Academy) are committed to GDPR compliance across the company, and we have evaluated the new requirements and restrictions imposed by the GDPR as well as have reviewed where and how we collect, use, store and dispose of personal data and updating policies, standards and documentation as necessary.
1. What type of information we collect
1.1. Non-Personally Identifiable Information. Promo Academy collects non-personally identifiable information that your browser makes available whenever you visit Websites. This information includes your Internet connection and hardware specs, browser type, browser language, the date and time of your query and one or more cookies that may uniquely identify your browser.
1.2. Personally Identifiable Information. In addition, we collect your personal information such as your full name, credit card information, billing address, your email address, your Skype ID, history of communication with Promo Academy, history of payments, IP address, system information, your activities on the Websites, and any other information you provide when using Promo Academy services or interacting with us in any way.
We do not collect your sensitive personal information, in particular, confidential medical facts, racial or ethnic origins, political or religious beliefs or sexuality.
If we hold any information about you which is incorrect or if there are any changes to your details or if you wish to see a copy of the information that we hold about you, please let us know at [email protected] so that we can keep our records accurate and up to date. You are also free to contact us regarding deletion of some or of all information we have gathered about you as well as your Promo Academy account.
1.3. Additionally and only upon your grant of respective permissions we may collect information from third party service providers.
Our Data Protection Officer monitors relevancy of the information collected as well as compliance with the GDPR and performs all the tasks determined by Art. 39 of GDPR. You can contact our Data Protection Officer regarding privacy questions related to your use of the Service by emailing at [email protected]
2. How we collect the information
To facilitate your use of the Service, Promo Academy may automatically collect certain types of information when you access or use the Service, complete surveys, send and receive communications, perform search queries and marketing activities.
Promo Academy may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies on our Websites, such as pixels and web beacons, to analyze trends, administer the websites, track users’ movements around the websites, serve targeted advertisements, and gather demographic information about our user base as a whole.
2.1. Cookie Policies. “Cookies” are small text files which are transferred from our websites, product or service and stored on your computer’s hard drive. We use a combination of cookies to help us provide you with a personalised service, and also to help make our websites, products and services better for you. You are able to configure your browser to restrict or block cookies and similar technologies if you wish, however if you disable those you may find this affects your ability to use certain parts of our websites, products or services.
3. How we use the information
From time to time, we may use your information to contact you with details about our products and services which we feel may be of interest to you. We may also share your information with our group companies, business partners so that they (or we) can contact you with information about their products or services which we feel may be of interest to you.
3.2. Personally Identifiable Information. We use the personally identifiable user information that we collect to provide any information and services that you have requested or any products that you have ordered. We may also contact you for feedback on your use of our products, services or our websites.
We may use and analyse the information that we collect so that we can administer, support, improve and develop the current Services offerings, to develop new Services, to be able to tailor the Services to one’s specific needs if feasible, for convenience of users and communication with them.
We may use that information to send you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number or any information requested by our payment processors and gateways, including but not limited to PayPal, VISA, Mastercard, Amex, Discover, PayPro. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
4.1. Disclosure to Third-Parties. Promo Academy does not share your personal information with third parties or the public except as set forth herein. We may share your personal information with our third-party service providers, such as SMTP infrastructure providers, analytical services, payment processors, merchants, or resellers, performing services, which supplement our Services. These service providers may have access to personal information as needed to perform their functions. Third parties with whom we share your data currently include, but are not limited to Google, YouTube, Facebook and Twitter. We do not sell your personal information.
4.2. Research. We may use and disclose to third parties information we collect in aggregated, non-personally identifiable form for research and informational purposes and to help us make sales, marketing and business decisions.
4.3. Events and Webinars. Promo Academy may share the names, email addresses and other details of users who register for some of our webinars and events, both online and offline, with the respective webinar speakers, announced special guests, our partners at the events, and others. We carefully select these persons and require them to use this information for the purposes related to the event (including webinars). We will try to label such events (including webinars) on the registration forms therefor, but if you affirmatively do not wish your name, email address or other details disclosed, please contact us before registering for any Promo Academy event to confirm whether your personal information will be shared at the specific event that you are considering. You may not opt-out of sharing your information at an event where such information is shared. Your only recourse is not to register for an event which so shares information.
4.5. Special Circumstances. Promo Academy will not disclose your personally identifiable information except as set forth in this Section 4, including in subsections below:
- when requested to do so by law enforcement agencies;
- when obliged to do so under the law;
- for the purpose of pursuing outstanding debts or liabilities;
- and when given permission to do so by you.
4.6. Use of Information for Commercial Purposes. You may object to the use of your personal data for commercial purpose at any time by logging in to your Promo Academy account and managing your settings or by contacting us at [email protected]
5. Information storage
We will store your usage data until such time when you withdraw your consent for us to do so. All other data as specified above will be retained for as long as is necessary for the purpose(s) for which we originally collected it. We may also retain information as required by law.
5.2. Password. Where we have given you (or where you have chosen) a password which enables you to access certain Services or specific areas of the Websites, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.
5.3. Disclaimer. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us via the Internet; any such transmission is at your own risk.
6. Information security
6.1. Security Measures. We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We use Secure Sockets Layer (SSL) encryption when collecting, transferring, and handling sensitive data such as credit card information or personal data. SSL encryption is designed to make the information invisible to anyone but us. SSL encryption is enabled when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the top of your browser window.
6.2. Limited Access to Information. We work hard to restrict access to personal information to Promo Academy employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
6.3. Be Aware. To prevent being a phishing website victim, always check domain details when you are providing your personal information. Please, be aware that if you suspect the website you are on is a fake site representing to be Promo Academy or to provide the Services, contact us directly at [email protected]
6.4. Controlling Your Personal Information. Promo Academy may, from time to time, make available to users chat rooms, forums, message boards, and other interactive features. You should be aware that when you voluntarily disclose personally identifiable information (e.g. user name, e-mail address) via blog, forums, postings, profiles or other areas of the Websites, that information, along with any substantive information disclosed in your communication, can be collected, correlated and used by third parties and may result in unsolicited messages from other posters or third parties. Such activities are beyond the control of Promo Academy. Please do not post any personal information on the Websites or in other areas that you expect to keep private.
6.6. Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Websites, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. We also maintain presences on social media platforms including Facebook, Twitter, Pinterest and Reddit. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
7. Users’ rights
- User has the right to amend and correct the provided data in a personal account;
- User can change or delete his/her personal data in the user account;
- User has the right to review his/her personal data and demand to transfer or delete this data;
- User has the right to restrict collection and processing of data;
- User is entitled to get his/her personal data anonymized.
8. Compliance and cooperation with regulatory authorities
9. Collection of information from children
We do not knowingly collect personally identifiable information relating to children. In the event that we learn that we have collected personally identifiable information from anyone under 16 years of age without prior parental consent, we will take steps to promptly delete such information. By providing your personal information to Promo Academy, through the Service, you represent that you are at least 16 years of age or older.
10. Transfers outside Europe
Personal data in the European Union is protected by data protection laws but other countries do not necessarily protect your personal data in the same way. Our websites and some of our products or services or parts of them may be hosted in the United States and this means that we may transfer any information which is submitted by you through the websites, product or service outside the European Economic Area (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) to the United States. When you send an email to us, this may also be stored on email servers which are hosted in the United States or outside the EU. We have taken steps to ensure that our hosting provider uses the necessary level of protection for your information but if you do not want your information to be transferred outside the EEA you should not use our websites, product or service or contact us via email.
11. No error-free performance
12. Do not track
Because there currently isn’t an industry or legal standard for recognizing or honoring DNT (Do Not Track) signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.
13. Legal notices
14. Contact information