Privacy Policy

Last updated & effective from: October 20, 2023

This statement discloses the privacy practices for PromoNow Ltd, our website/app, and how we safeguard user data.

We take your privacy and security very seriously. Users agree to their information being held and processed in accordance with GDPR. Specifically; personally identifiable data will only be used by us and any data sub-processors we appoint for the purposes of platforms we operate. The lawful basis we use for collecting and processing your information in Europe (as required by current legislation) are as follows:

• Where it is necessary for entering into or performing a contract with you;
• Where we have a legitimate interest to do so, provided your rights do not override those interests;
• Where you have consented to its uses;
• Where our colleagues believe it is in your vital interests to share your personal details;
• Where required to comply with our legal obligations.

PromoNow^TM provides services internationally, many of our clients are global organisations. For the purposes explained in this Policy, your personal data may be transferred to a client's group companies (including service providers operating on their behalf) and other third parties in countries, out of the EEA and UK, which do not have the same level of data protection laws as those in the country where you are located. We and our clients use a variety of legal mechanisms, including EU Standard Contractual Clauses, to help ensure that your rights and protections will travel with your data. The processing of personal data complies with the key data protection principles of fair handling of personal data and ensuring adequate level of protection of personal data. In most cases, for example promotions that consumers enter, The Privacy Policy of the Promoter who is the data controller will apply, attention will be draw to this policy at the earliest opportunity to participants.

‍Duration of processing: Data will be safely deleted within a reasonable time once our relationship with you has come to an end and our necessary purposes as stated have been completed. Click here to learn more about your rights under GDPR, including data rectification, erasure, processing and lodging a complaint. By signing up or logging in and/or continuing to use this website, other websites we host, and data we manage, you are accepting our privacy & security policy and our terms of service. This statement discloses the privacy practices for PromoNow Ltd, any sub contractors and sub processors we work with, and how we safeguard user data.
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As Data Controller: When using this website, PromoNow Ltd is the controller and responsible for your personal data (collectively referred to as "PNL”, "we", "us" or "our" in this privacy policy), whereas;

‍As Data Processor: When using other web applications, promotional platforms and websites we maintain, and in providing participant / winner management support / handling / validation services, on behalf of other Data Controllers we are deemed the Data Processor. As a Data Processor, (including as a Sub-Processor) we have important responsibilities and contractual obligations, as set out below:

As Data Processor we agree to;

only act on the controller’s documented instructions, unless required by law to act without such instructions;
ensure that people processing the data are subject to a duty of confidence;

take appropriate measures to ensure the security of processing;

only engage a sub-processor with the controller’s prior authorisation and under a written contract. In using our Services a Controller is authorising as required and necessary us to engage any sub-processor we assess and deem capable of meeting or exceeding the agreed data safeguarding standards herein;
take appropriate measures to help the controller respond to requests from individuals to exercise their rights;

taking into account the nature of processing and the information available, the processor must assist the controller in meeting its UK GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments;

delete or return all personal data to the controller (at the controller’s choice) at the end of the contract, and the processor must also delete existing personal data unless the law requires its storage; and

submit to audits and inspections. The processor must also give the controller whatever information it needs to ensure they are both meeting their Article 28 obligations.
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If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Privacy Team using the details set out below.
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Contact details: If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
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Registered data controller number ZA720375
Full name of legal entity: PromoNow Ltd
Email address: [email protected]
Postal address: Spring Meadows Technology Park, SO32 2TH, United Kingdom

‍Registered EU data representation number (Numero REA) RM - 1598978
Full name of representative: Paul Cheatle
Email address: [email protected]
Postal address: Via delle Macere 20, Formello (RM), Rome, CAP 00060, Italy

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Personal information: We intend to give you as much control as possible over your personal information. In general, you can visit PromoNow^TM on the Web without telling us who you are or revealing any information about yourself. There are times, however, when we may need information from you, such as your name and address. It is our intent to let you know before we collect personal information from you on the Internet. We also make use of cookies, this helps our website remember some details about you, they're commonly used to make it easier for you online.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services sold and purchased by supplier members to our operator members.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Data subjects: Our policy is not to work on projects requiring the capture of special category, sensitive personally identifiable information, such as; health, race religion, sexual orientation, criminal records and trade union membership. This website, any other web applications, platforms and services we provide are not intended for children and we do not knowingly collect data or process data relating to children.

If you choose to give us personal information via the Internet that we or our business partners may need to correspond with you, process an interaction or provide you with a subscription, for example it is our intent to let you know how we will use such information. If you tell us that you do not wish to have this information used as a basis for further contact with you, we will respect your wishes. We do keep track of the domains from which people visit us. We analyse this data for trends and statistics, and then we discard it.

Information security and quality: We intend to protect the quality and integrity of your personally identifiable information. We have implemented appropriate technical and managerial procedures to maintain information that is accurate, current, and complete. Data centres we use are ISO27001 certified. We will make a sincere effort to respond to your requests to correct personal information inaccuracies in a timely manner. We are a fully registered user under the Data Protection Act.

Business relationships: The PromoNow^TM  site contains links to other Web sites. PromoNow^TM is not responsible for the privacy practices or the content of such Websites.

Cookies: There are various technologies, including one called "cookies", which can be used to provide you with tailored information from a Web site. A cookie is an element of data that a Web site can send to your browser, which may then store it on your system. Some PromoNow^TM pages use cookies or other technologies so that we can better serve you when you return to our site. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. For more information, please e-mail: [email protected].

PromoNow^TM is also supporting the development of some technologies that will let you manage and control the release of your personal information wherever you go on the Internet.

Questions regarding this statement should be directed to [email protected].

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