Last Updated April 16, 2020
The current focus of the Service is to help Brands develop and share with their Retailers their marketing campaigns online (each, a “Campaign”) and to help Retailers participate in, customize (as permitted by the respective Brand), and share with consumers (including through online channels, such as Facebook, Twitter, and websites, and via email) the Campaigns of their associated Brands. As used herein, a “Brand” means an individual or entity (or a regional retailer sales and marketing group, sales representative, agency, or distributor acting on such individual or entity’s behalf) that is associated with, and whose goods and/or services are identified by, a distinctive name, trademark, and/or service mark or a collection thereof; a “Retailer” means an individual or entity that sells or makes available the goods and/or services of a Brand. Our Service is intended to be used by Brands and Retailers, which are generally businesses and are collectively referred to here as our “Customers.” We do not intentionally collect data from consumers.
What information about me is collected through the Service?
Does Promoboxx collect information from children under 13 years of age?
What does Promoboxx do with the information it collects?
When does Promoboxx disclose information to third parties?
Is the information collected through the Service secure?
Could my information be transferred to other countries?
What choices do I have regarding the collection, disclosure and distribution of personally identifiable information?
Can I update or correct my personally identifiable information?
Are there special rights for California or EU residents?
Whom do I contact if I have any privacy questions?
WHAT INFORMATION ABOUT ME IS COLLECTED THROUGH THE SERVICE?
Depending on your use of the Service, we may collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information
Personally identifiable information is information that identifies you or can be used to identify or contact you. Such information may include your name, address, email address, telephone number, and billing and credit card information, if applicable.
Non-Personally Identifiable Information
Non-personally identifiable information is information that any single item of which, by itself, cannot be used to identify or contact you, such as demographic information (like, age, profession, gender, current location, zip code, birth date, or year of birth), IP addresses, browser types, domain names, and other statistical data involving the use of the Service. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it is combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences).
As you browse www.Promoboxx.com, advertising cookies will be placed on your computer so that we can understand what Promoboxx products and services you are most interested in. Our display advertising partners, Google Adwords, and AdRoll, then enable us to present you with retargeting advertising on other sites based on your previous interaction with www.Promoboxx.com. Our partners do not collect personally identifiable information such as your name, email address, postal address, or telephone number. You can visit this page to opt out of Google AdWords’, AdRoll’s and their partners’ targeted advertising.
We may also receive personally identifiable information about you from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service.
Registering to Use the Service and in the Course of Using the Service.
You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information) such as name, postal address, email address, birth date, and credit card and billing information. We may also receive personally identifiable information about you from third parties providing credit and debit card authorization and fraud screening services as part of the registration process. In addition, we may obtain your personally identifiable information from you if you identify yourself to us when you contact us (such as by reaching out to firstname.lastname@example.org or contacting Promoboxx through various support or other channels). Also, we will have access to any personally identifiable information that you choose to share through the Service (such as your name if you include it in content you post to the Service).
Cookies, Log Files and Action Tags.
We may collect non-personally identifiable information passively using cookies, log files and action tags.
In addition to cookies that we place on your computer or mobile device, cookies may also be placed on your computer or mobile device by third parties that we use to display or serve advertisements or to collect non-personally identifiable information in order to provide advertising-related services. In the course of serving advertisements, our third-party advertisers may place or recognize unique cookies on your browser.
We also collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.
“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including advertisements, or email sent on our behalf, may contain action tags.
By using cookies and action tags together, we are able to gain valuable information to improve the Service and measure the effectiveness of our advertising and marketing campaigns. We do not disclose any of your personally identifiable information to our advertising partners.
DOES PROMOBOXX COLLECT INFORMATION FROM CHILDREN UNDER 16 YEARS OF AGE?
We are committed to protecting the privacy of children. The Service is designed for adults and is not designed for or directed to children under the age of 16. We do not knowingly collect personally identifiable information from any person we actually know is under the age of 16. To the extent that we are informed that we’ve inadvertently collect information from a person under 16, we will take reasonable steps to remove that information from our records.
WHAT DOES PROMOBOXX DO WITH THE INFORMATION IT COLLECTS?
Promoboxx is a service provider as that term is understood under the CCPA and a data processor as that term is understood under the GDPR. That means that Promoboxx will only use data as directed by our customers and we don’t sell or otherwise transfer information except as directed by our customers to provide the Service.
In general, we use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, to facilitate the delivery of advertising, and so that we and third parties can contact you about products and services that may be of interest to you.
We may use your information to send you a welcoming email that may confirm your username and password. With your permission, we may send you electronic newsletters, contact you about the Service products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences. In addition, if you identify yourself to us by sending us an email with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments for future reference. We may also use the information collected to send you important service announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these service announcements and updates as they contain important information relevant to your use of the Service.
We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service.
WHEN DOES PROMOBOXX DISCLOSE INFORMATION TO THIRD PARTIES?
Promoboxx may share with the respective Brand(s) associated with a Retailer’s account all information and data concerning such Retailer, and that of such Retailer’s consumers, as such information and data pertains to such respective Brand(s), on or in connection with the Service. In addition, Promoboxx may show a Brand its respective performance benchmarked against other Brand(s) using the Service.
Promoboxx may share with the respective Retailer(s) associated with a Brand’s account campaign information that the Brand has approved for distribution to its Retailer(s), the analytical ranking of respective Retailer(s) in comparison to other Retailer(s) associated with a Brand’s account (assuming the Brand has enabled the Retailer(s) to view these analytics), divisional analytics (assuming the Brand has enabled the Retailer(s) to view these analytics), and aggregate Brand(s) performance benchmarking.
Laws and Legal Rights.
Third Parties Generally.
We may provide to third parties aggregated, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. For clarification but not limitation, we reserve the right to collect, retain, use, copy, modify, publicly perform, publicly display and create derivative works of all aggregate data concerning your activity (and that of your consumers) on or in connection with the Service (without reference to your name or that of the entity on whose behalf you are acting) for any lawful purposes, including without limitation, benchmarking, development of best practices, product and services development, and research and statistical purposes without reimbursement or notification to, or consent or authorization from you. We may also provide to third parties personally identifiable information. For example, we might share our users’ e-mail addresses and responses to questionnaires with third parties in order for third parties to contact users about products and services that may be of interest. The third parties to which we may provide or who may independently directly collect this personally identifiable and non-personally identifiable information may include potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties. For clarification, but not limitation and for the avoidance of doubt, any data or information provided, sourced, input, and/or created by Promoboxx with respect to any Brand or Retailer may be freely used by Promoboxx and shared with any third party. Promoboxx shall remain liable under the Privacy Shield Principles if any of its agents processes such information in a manner inconsistent with the Privacy Shield Principles, unless Promoboxx proves that it is not responsible for the event giving rise to the damage.
Third Party Sellers.
Sale of Business.
Any information you share in a Public Area (including personally identifiable information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. WE HAVE NO RESPONSIBILITY OR LIABILITY IF YOUR INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF YOU SUFFER HARM AS A RESULT OF YOUR VOLUNTARY DISCLOSURES. As with any public forum on any website, the information you post may also show up in third-party search engines such as Google, Yahoo, MSN, and Bing. If you mistakenly post personal information in a Public Area you can send us an email to request that we remove it by contacting us at email@example.com. You should understand that in some cases, we may not be able to remove your personal information from a Public Area.
IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?
We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with industry standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.
Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.
COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?
Personally-identifiable information collected through the Service is generally stored in the United States.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Promoboxx is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Promoboxx’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Promoboxx remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Promoboxx proves that it is not responsible for the event giving rise to the damage.
Promoboxx has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?
CAN I ACCESS, UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?
You have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by accessing My Profile or contacting firstname.lastname@example.org
To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identify before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.
ARE THERE SPECIAL RIGHTS FOR CALIFORNIA OR EU RESIDENTS?
California. The California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, (i.e., the right to know), b) the right to delete the data we have about you, (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, to certain third parties (i.e., the right to opt-out from sales of your information). Promoboxx does not “sell” consumer information.
You may access those rights by accessing My Profile or contacting email@example.com. We will take steps to confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days. Promoboxx does not discriminate against you if you exercise any of the above rights. Please note that we may not be able to honor one or more of these rights if doing so would violate applicable law. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.
The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. We may require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
The European Union. Individuals located in the European Economic Area (“EEA”) are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”) and similar data protection laws. For example, an EU individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their Personal Information, should send us an email at firstname.lastname@example.org.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
With respect to EU data subjects, Personal Data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID.
WHOM DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By postal mail or courier:
Attn: Privacy Agent
500 Harrison Avenue, Studio 3R
Boston, MA 02118