ProMarketerX - Privacy Policy
Last Updated 13/12/22
The purpose of this “Privacy Policy” is to inform all individuals from whom Personal Data is collected by ProMarketerX (“You” or “Your”). This Privacy Policy describes how ProMarketerX collects, uses and discloses information, and what choices you have with respect to the information. When we refer to “ProMarketerX”, we mean the business entity Innovonation LTD operating as the ProMarketerX Agency. A company registered at 22 Rosebank, Dunfermline, KY11 4BD ("Company," "we," or "us") that acts as the controller of your information.
1. Applicability of this Privacy Policy
This Privacy Policy applies to ProMarketerX’s professional services and software solutions (collectively, the “Services”), ProMarketerX and other ProMarketerX websites (collectively, the “Websites”) and other interactions (e.g. customer inquiries, email, user events, etc.) you may have with ProMarketerX. If you do not agree to the terms, do not access or use the Services, Websites or any other aspect of ProMarketerX’s business.
This Privacy Policy does not apply to any third-party applications or software that integrates with the Services ProMarketerX provides (“Third Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Terms of Service”), including the processing of any messages, files or other content submitted through Services, Websites and ProMarketerX personnel (collectively, “Customer Data”). The customer (“Customer”) is the entity or person that entered into the User Agreement.
Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to the person.
Non-Personal Data means any information that does not result in the identification of a person.
2. What information We collect
ProMarketerX may collect and receive Personal Data and other information (“Other Information”) in a variety of ways.
ProMarketerX Companies: We receive information about you from companies that are owned by ProMarketerX or through third-party partners (“Affiliates, Partners & Subsidiary”) in accordance with their terms and policies. We work with Partners who provide fulfilment, training and other services relating to our Programs. Affiliates help us to market, promote and resell our products. We receive information from these partners, such as billing information, and primary contact information.
Other Partners: We receive information about you and your activities from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.
Personal Data likely includes:
• Title;
• first and last name;
• postal address;
• email address;
• phone number(s);
• login and password;
• financial data (credit card number and expiry date, name and address of the cardholder);
• IP address; and
• any other Personal Data as may be relevant for the purposes listed below.
In all cases, however, the Personal Data gathered is limited to data necessary for the purposes described in Article 4 below.
Other Information: ProMarketerX also collects, generates and/or receives Other Information:
Automatic Data Collection Technologies: ProMarketerX uses cookies and similar technologies in our Websites that help us collect usage information. The Websites may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and across other websites and online services.
How do we use them?
• Where strictly necessary. These cookies and other technologies are essential in order to enable the Websites to function properly and provide the feature you have requested.
• For functionality. These cookies and similar technologies remember choices you make such as language or search parameters. We use these cookies to provide you with an experience more appropriate with your selections and to make your use of the Websites more tailored.
• For performance and analytics. These cookies and similar technologies collect information on how users interact with the Websites and enable us to improve how the Websites operate. For example, we use Google Analytics cookies to help us understand how visitors arrive at and browse our products, services and website to identify areas for improvement such as navigation, user experience, and marketing campaigns.
• Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They remember the websites you have visited and that information is shared with other parties such as advertising technology service providers and advertisers.
• Social media cookies. These cookies are used when you share information using a social media sharing button or “like” button on our websites or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
How are cookies used for advertising purposes?
Cookies and other ad technology such as beacons, pixels, and tags help us market more effectively to users that we and our partners believe may be interested in ProMarketerX. They also help provide us with aggregated auditing, research, and reporting, and know when content has been shown to you.
How can you opt-out?
To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit.
Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.
For other browsers, please consult the documentation that your browser manufacturer provides.
You may opt-out of third-party cookies from Google Analytics on its website.
You can opt-out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com).
If you do not accept cookies, however, you may not be able to use all aspects of our Websites. ProMarketerX and our third-party partners also collect information using web beacons (also known as “tracking pixels”).
Many browsers include their own management tools for removing flash cookies and HTML5 local storage objects. You may be able to opt-out of receiving personalized advertisements as described in Section 8 “Your Rights.”
You will not be able to opt out of any cookies or other technologies that are “strictly necessary” for the Websites to function.
“Do Not Track” Signals
Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt-out of receiving marketing from us as described in Section 8 “Your Rights.”
3. Age limitations
Our Website and Services are not intended for children under 18 years of age. No one under the age of 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at: scottjmillar@gmail.com
4. How we use the information we collect
As stated above, you provide Your Personal Data on a voluntary basis. Personal Data will be used by ProMarketerX in accordance with Your instructions, including any applicable terms of the User Agreement, and as required by applicable law.
ProMarketerX uses Personal Data in furtherance of our legitimate interests in operating our Services, Websites and business.
We are the sole owners of the information retrieved and collected by the Website and Services. We will not sell or rent this information to anyone. We will use your information to respond to you, regarding the reason you contacted us. We will not share your information with any third party outside of our organization, other than as necessary to fulfil your request.
Personal Data is generally collected to carry out the business of ProMarketerX, such as improving ProMarketerX’ marketing and advertising efforts, better tailoring ProMarketerX’ products and services to customers’ needs or complying with reporting obligations required by law, and similar activities.
ProMarketerX collects and uses Your Personal Data for the purpose of carrying out its business, in particular for the following purposes:
• To enable You to request and receive information on ProMarketerX and ProMarketerX products and services;
• To provide You with a personalized interactive use of the Websites;
• To ascertain Your requirements and interests and provide You with the most suitable products and/or services;
• To allow You to open and maintain an account to obtain specialized documentation and technical assistance;
• To access all the features and options offered by the Websites;
• To enable ProMarketerX to manage surveys;
• To enable ProMarketerX to manage its marketing activities;
• To enable ProMarketerX to manage its business relationships: sales opportunities, commercial offers, purchasing, contracts, orders, invoices, etc;
• To provide You with commercial or support-type services;
• To enable You to register for events;
• To enable ProMarketerX to manage its Research & Development activities;
• To process an application from You and manage partnership sources;
• To manage Your training on ProMarketerX campaigns and services;
• Any other purposes associated with the purpose of carrying out the business of ProMarketerX.
Subject to applicable local law, by providing Your e-mail address, You hereby expressly authorize, ProMarketerX and its subsidiaries to use it together with other relevant Personal Data to send You commercial or marketing messages.
ProMarketerX might also use Your email address for administrative or other non-marketing purposes (for example, to notify You of significant changes to the Websites and Services).
5. Data processing and retention
Processing of Personal Data includes using, storing, recording, transferring, adapting, summarizing, amending, reporting, sharing and destroying Personal Data as necessary under the circumstances or as otherwise required by law.
All Personal Data that is collected will be stored for a limited duration that is relevant for the purpose of such collection and only for so long as required by applicable law.
ProMarketerX will take all commercially reasonable steps to retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the User Agreement and Customer’s use of Services, and as required by applicable law.
ProMarketerX may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after your contract has lapsed for the period of time needed for ProMarketerX to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
6. How we share Personal Data
We share information that helps us operate, provide, improve, customise, support and market our Services.
Business Partners: Your Personal Data may be disclosed to and used by an Affiliate, Subsidiary, or Partner of ProMarketerX for the purposes stated in Article 4 of this Privacy Policy. ProMarketerX may share Your Personal Data with the Partner assigned to You or in the territory where You are located for the purpose of ProMarketerX business. ProMarketerX may also share Your Personal Data with Partners when ProMarketerX and the business partner participate in a program together and in which You engage.
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
Please note that ProMarketerX may transfer Your Personal Data outside of the European Union, as long as before transferring Your Personal Data, ProMarketerX has ascertained that non-European Union entities, including ProMarketerX’s affiliates and subsidiaries, offer an adequate level of protection in accordance with European legislation.
Where ProMarketerX has knowledge that a third party to which ProMarketerX has provided Personal Data for the purposes listed in Article 4 above, is using or disclosing Personal Data contrary to this Privacy Policy or to applicable laws, ProMarketerX will take reasonable steps to prevent or stop such use or disclosure.
You will have the opportunity to decide whether You authorize ProMarketerX to use Your Personal Data for a purpose which is different from the purpose for which it was originally collected.
ProMarketerX may also disclose Your Personal Data if required by law or if ProMarketerX believes in good faith that such disclosure is reasonably necessary to comply with legal process or protect the rights, property, or personal safety of ProMarketerX, our customers, or the public.
If allowed by applicable law, ProMarketerX may also share Your Personal Data with third parties in order to offer You targeted marketing or advertising.
These transfers may be transmitted over the internet or by any other method that ProMarketerX determines is appropriate and in accordance with applicable law.
7. How we transfer Personal Data internationally
International transfers of information we collect:
We collect information globally and primarily store that information in the United States. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you with the Services. Whenever we transfer your information, we take steps to protect it.
International transfers within the ProMarketerX Companies:
To facilitate our global operations, we transfer information to the United States and allow access to that information from countries in which the ProMarketerX-owned or operated companies have operations for the purposes described in this policy. These countries may not have equivalent privacy and data protection laws to the laws of many of the countries where our customers and users are based. When we share information about you within and among ProMarketerX affiliates, we make use of the European Commission-approved standard contractual data protection clauses.
International transfers to third parties:
Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area, we make use of the European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.
We encourage you to contact us as provided below should you have a privacy-related complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the ICO – Information Commissioner’s Office which we recognize as our independent supervisory authority. Through this third-party dispute resolution provider, we have committed to cooperating and complying with the information and advice provided by an informal panel of data protection authorities in the European Economic Area in relation to unresolved complaints. You may also contact your local data protection authority within the European Economic Area (as applicable) for unresolved complaints.
Contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
8. Your rights
ProMarketerX will take reasonable steps to ensure that the Personal Data collected is used for the purposes stated in this Privacy Policy and that such Personal Data is correct and up to date.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep.
To the extent that ProMarketerX’s processing of your Personal Data is subject to the General Data Protection Regulation, ProMarketerX relies on its legitimate interests, described above, to process your data. ProMarketerX may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to ProMarketerX’s use of your Personal Data for this purpose at any time.
ProMarketerX may deny access or erasure to Personal Data in limited circumstances, defined by applicable laws and regulations.
Access and update your information: You will have the right to access or modify Personal Data and set communication preferences or object to the sending of marketing communications from ProMarketerX by following the instructions available within each marketing communication received from ProMarketerX. If you cannot use the tools, contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a submission or request was created for you without your permission or you are no longer interested in ProMarketerX services, you can request that we delete your contact information as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved. contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
Opt-out of communications: You may opt-out of receiving promotional communications from us by using the unsubscribe link within each marketing email, or by contacting us as provided below to have your contact information removed from our email lists. Even after you opt-out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services if you are an active customer. contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
Delete your information: You may ask us to delete the information we retain about you. Please note, however, that we may need to retain certain information for record-keeping purposes, to complete transactions or to comply with our legal obligations. Contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information. Contact ProMarketerX for assistance by sending an email to the following address: scottjmillar@gmail.com
9. Data security
ProMarketerX undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties.
ProMarketerX maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. As part of those safeguards, ProMarketerX employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third parties. However, while ProMarketerX strives to protect Your Personal Data, considering the inevitable risks of data transmission over the internet, ProMarketerX cannot guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond ProMarketerX’s reasonable control.
Since all Personal Data is confidential, access is limited to employees, contractors, and agents of ProMarketerX who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.
However, it is important for You to exercise caution to prevent unauthorized access to Your Personal Data. You are responsible for the confidentiality of Your password and information appearing on Your account.
10. Third-party links
The Websites might offer links to third-party websites not controlled by ProMarketerX or its subsidiaries which may be of interest to You.
ProMarketerX does not exercise any control over the content of third-party websites or the practices of these third parties relating to the protection of Personal Data that they might collect and are thus not in the control of ProMarketerX. Consequently, ProMarketerX declines all liability for the content of third-party websites or the practices of these third parties concerning the protection of Personal Data.
It is, therefore, Your responsibility to inform yourself of the privacy policies of these third parties.
11. Dispute resolution
Although ProMarketerX has put in place reasonable safeguards to protect Personal Data, we recognize that there is no method of transmitting or storing Personal Data that is completely secure.
However, ProMarketerX is committed to ensuring the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact ProMarketerX via the following address: scottjmillar@gmail.com
ProMarketerX will investigate and attempt to resolve complaints regarding the use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy.
12. Changes to this Privacy Policy
ProMarketerX may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, ProMarketerX will provide additional notice, such as via email or notification through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account.
13. Contact
For any additional questions concerning this Privacy Policy, to opt-out of receiving information from ProMarketerX or any request for rectification, completion, update, or deletion of Your Personal Data You may send an email to the following email address: scottjmillar@gmail.com