Promen is serious about customer privacy. This Privacy Policy describes the type of personal information we may collect from you or you may provide to us when you visit our website at www.thepromen.com (our “Website”) or purchase our products. This Privacy Policy also explains our practices for collecting, using, maintaining, protecting, and disclosing such data, which may include, but not be limited to personal information.
By accessing or using our Website, you agree to the terms of this Privacy Policy, including but not limited to our collection and processing of your Data. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT ACCESS OUR WEBSITE.
SECTION 1 - LAWFUL BASES FOR COLLECTION AND PROCESSING OF DATA THROUGH OUR WEBSITE; PERSONAL DATA WE COLLECT AND PROCESS
When you visit our Website, we automatically collect certain information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse our Website, we collect information about web pages or products that you view, the websites or search terms that referred you to our Website, and information about how you interact with our Website.
When you make a purchase or attempt to make a purchase through our Website, we also collect certain information from you, including your name, billing address, shipping address, payment information (such as credit card numbers), email address, and phone number. This personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device herein is collectively referred to as “Data.”
In the past twelve (12) months, the categories of personal information that we have collected from consumers visiting this website include Contact information, such as name, postal address, email address, phone number. Online identifiers, such as username and IP address. Usage information, such as how you and your device interact with our website (e.g., the pages you visit, the search terms you enter).
Other information, such as credit card information, that you provide to conduct transactions.
We have collected such personal information solely from the following categories of sources:
Directly from customers when engaged in transactions through this website or other manner of direct communications.
Directly and indirectly from activity on our website ( www.thepromen.com ). For example, from requests through our website portal or website usage details collected automatically.
SECTION 2 - WHAT DO WE DO WITH YOUR DATA?
The Data we collect from customers is used to fulfill orders placed through our Website, which includes the processing of payment information, preparing orders for shipment, and providing order confirmations and other order-related communication. In addition, we’ll use data from your visit to our Website to improve and optimize the customer experience, to screen for potential risk and fraud, to provide the most relevant advertisements and email communications to you, and to assess the success of our current marketing and advertising campaigns. Pursuant to General Data Protection Regulations (GDPR), we are considered a “controller” of Data and we may engage third-party “processors” of Data.
We may use or disclose the Data we collect for one or more of the following business purposes:
To fulfill or meet the reason for which the information is provided. For example, we will use the address information you provide us in order to have the product delivered to you.
To provide you with information concerning our products or services that you request or consent to receiving from us.
To carry out our obligations and enforce our rights arising from any sales transactions entered into between you and us, including for billing and collections.
To improve our website and present its contents to you.
For testing, research, analysis, and product development.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information.
BEHAVIORAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
SECTION 3 - YOUR RIGHTS
Through your access to our Website and provision of Data as described herein, you have provided your consent for our use and collection of your Data. However, in the event, you change your mind, and no longer wish that we utilize your Data, you may withdraw your consent for us to contact you, for the continued collection, use, or disclosure of your information at any time, or modify your contact information, by contacting us at support@thepromen.com and indicate on the subject line, “Privacy Compliance,”
Personal information that we collect, use, and share. We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. We also work with third-party advertising and social media companies like Google and Facebook that collect your device data and online activity data from individuals who visit our website to help deliver interest-based ads to you, please refer to the Interest-based advertising section above and our "Cookie Policy" below for more information.
The chart below summarizes how we collect, use, and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy.
|
Category of personal information (PI) |
PI we collect in this category |
Source of PI |
|
Identifiers |
· Contact data
· Registration data
· Data about others
· Profile data
· Communications
· Marketing data
· Purchase data |
· You
· Business partners
· Data providers
· Public sources
· Third-party platforms
|
|
Commercial Information |
· Contact data
· Registration data
· Purchase data
· Communications
· Marketing data
· Device data
· Online activity data |
· You
· Business partners
· Data providers
· Public sources
· Automatic collection |
|
Financial Information |
· Purchase data |
· You
· Business partners |
|
Online Identifiers |
· Device data
· Online activity data |
· Automatic collection |
|
Internet or Network Information |
· Device data
· Online activity data |
· Automatic collection |
|
Inferences |
May be derived from your:
· Device data
· Online activity data |
|
|
Protected Classification Characteristics |
We do not intentionally collect this information but it may be revealed in profile data or other information we collect |
|
The business and commercial purposes for which we collect this information are described in the section above entitled HOW WE USE YOUR PERSONAL INFORMATION. The categories of third parties to whom we disclose this information are described in the section above entitled SHARING YOUR PERSONAL INFORMATION.
Information. You can request information about how we have collected, used and shared, and used your Personal Information during the past 12 months.
The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in our service quality.
We have provided additional information about how you can opt out of the use of your information for interest-based advertising in the “Your Choices” section of our Cookie Policy mentioned below.
Right to information, access, and deletion. You can request to exercise your information, access, and deletion rights by emailing at support@thepromen.com.
We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
What types of cookies and similar tracking technologies do we use?
We use cookies and other tracking technologies in the following categories described in the table below.
|
Type |
Description |
Who serves the cookies |
How to control them |
|
Advertising |
These cookies are used by advertising companies to collect information about how you use our website over time. These companies use this information to show you ads they believe will be relevant to you. |
|
See ‘YOUR CHOICES’ below. |
|
Analytics |
These cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients. |
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our website by downloading and installing a browser plugin available here.
See YOUR CHOICES below.
|
|
|
Essential |
These cookies are necessary to allow the technical operation of our Service (e.g., they enable you to move around on a website and to use its features). |
|
See YOUR CHOICES below. |
Web Beacons
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our website and in our HTML formatted emails to track the actions of users on our website and interactions with our emails. Unlike cookies stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on web pages or within HTML formatted emails. Pixel tags are used to demonstrate that a web page was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and compile statistics about usage of the website to manage our content more effectively.
YOUR CHOICES
Like many companies online, we use services provided by Google, Facebook, and others companies that use tracking technology. Your choices for opting out of these companies’ use of your personal information for interest-based advertising include:
Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide the functionality to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our website from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of the use of your information for interest-based advertising:
Google: https://adssettings.google.com
Facebook: https://www.facebook.com/about/ads
Criteo: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/
Bounce Exchange: https://www.bouncex.com/privacy/your-ad-choices/
Advertising industry opt-out tools. Some of our business partners that collect information about users’ activities on or through the website or Apps may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. You can use the following opt-out options to limit the use of your information for interest-based advertising by participating companies:
Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org/?c=1
Users of our Apps may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.
Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt-out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.
SECTION 4 - RIGHT TO OPT-OUT
We provide you the opportunity to opt out of marketing communications by clicking the “unsubscribe” link in email communications or by contacting us using the contact information provided here. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.
NAI http://optout.networkadvertising.org/
DAA http://optout.aboutads.info/
SECTION 5 - DATA RETENTION
By submitting your Data through our Website, you agree to the transfer, storing, and processing of your data, which, depending on the use of third-party services, may be processed, transferred, and stored outside of the country where you reside. When you place an order through our Website, we will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
SECTION 6 - COOKIES
We, and third parties we utilize, use cookies and other similar technologies. Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a consumer’s hard drive to keep records of the consumer’s visit to a website. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:
Some cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
We use Google Analytics to measure how you interact with our website and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en. Google also provides a complete privacy policy and instructions on opting out of Google Analytics at https://tools.google.com/dlpage/gaoptout.
Targeted Advertising. We use cookies to compile information on our users’ interactions with our website. We use this information to serve ads to you off of our website.
There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies, or notify you when receiving a new cookie. Please note that if you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. The Network Advertising Initiative also offers a means to opt out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more.
SECTION 7 – ONLINE STORE / THIRD-PARTY SERVICES
Our Website store utilizes Shopify as our third-party e-commerce and payment partner, which allows us to sell our products and services to you. Your Data is stored through these databases and applications. They store your Data on a secure server behind a firewall. If you choose a direct payment through our store to complete your purchase, then our partner stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as necessary to complete your purchase transaction. Once complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS, as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
When you click on links on our Website, they may direct you away from our Website. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Once you leave our Website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.
SECTION 8 - DISCLOSURE OF YOUR INFORMATION
We do not sell, trade, rent or disclose your Data to third parties, except as provided herein:
(a) We will disclose Data (i) if it is required by law enforcement or judicial authorities, or to cooperate with a law enforcement investigation; (ii) if we have a good faith belief that we are required or permitted to do so by law or legal process; (iii) to protect our rights, reputation, property, or the safety of us or others; (iv) to defend or enforce our rights or your obligations; (v) if the disclosure is required by mandatory professional standards; (vi) to a third party with your prior consent; (vii) if we are under a duty to disclose or share your Data in order to enforce or apply any contracts or agreements that may exist between you and us, including this Privacy Policy; and/or (viii) if we are required to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
(b) We obtain support through third-party service providers to maintain our Website, offer our products for sale, process customer orders and deliver products. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Website and we provide order information to third parties that may package and deliver your product order including your address, name, phone if required for delivery, order totaled, and what was ordered.
(c) In the event we sell our stock or assets to an acquiring entity or merge with another entity, we reserve the right to provide your Data to the acquiring or surviving entity.
SECTION 9 - DATA SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. We follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Data, you acknowledge that: (a) there are security and privacy limitations of the Internet that are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through our Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe the security of your data in our control may have been compromised, we will try to notify you. To the extent you have provided us with your email address, we may notify you by email and you agree to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact us using the information contained in Section 3, above, with the alternative contact information you wish to be used.
SECTION 10 – DO NOT TRACK DISCLOSURES
Some websites have “do not track” features that allow users to instruct a website not to track them. These features are not all uniform. We do not currently respond to those signals; however, our marketing partners may be members of the Network Advertising Initiative or the Digital Advertising Alliance, which have agreed to honor consumers’ opt-out preferences submitted through those organizations’ websites. To learn more about your choices regarding this type of data collection or to opt-out of interest-based advertising by members of the NAI or the DAA, please visit the choices websites of the NAI and DAA at https://www.aboutads.info) You also may locate Google Analytics’ currently available opt-outs for the web here: https://tools.google.com/dlpage/gaoptout/. You can obtain more information about how to opt out of Adobe Analytics here: http://www.adobe.com/privacy/opt-out.html.
SECTION 11 - AGE OF CONSENT
We are not a site targeted at children or those under the age of 18. By using our Website, you represent that you are at least the age of majority in your country, state, or province of residence, or that you are the age of majority in your country, state, or province of residence and you have given us your consent to allow any of your minor dependents to use our Website.
SECTION 12 - CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on our Website. If we make material changes to this Privacy Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
SECTION 13 – CONTACT US
If you have any questions, comments, or concerns about our privacy practices or this Policy, please contact us at: support@thepromen.com
The Promen Support Team