Privacy Policy
Updated October 11, 2024
iPromo ("Company" or "We") respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or your business or that you may provide when you visit our website, and our practices for collecting, using, maintaining, protecting, and disclosing this information.
This policy applies to information we collect:
- On this website.
- In email, text, and other electronic messages between you and the Company.
- Through mobile and desktop applications you access our website, which provides dedicated non-browser-based interaction between you and our website.
- At trade shows, exhibitions, conferences, networking, industry, or similar events ("events").
- Directly from you while providing our products and services to you or your business.
This policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on our website. This policy also does not apply to information related to Company employees, which is covered by internal policies.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using this website, using our products or services, or otherwise providing us with your information, you agree to this privacy policy. This policy may change periodically (see Changes to Our Privacy Policy) and we will update the date at the top of the policy to reflect when it was last updated. Your continued use of this website after we make changes is deemed as acceptance, so please check the policy periodically for updates.
Information We Collect About You and Our Purpose for Collecting it
We collect several types of information directly from you or automatically from your use of our website and services. The information we collect from you may include:
- Personal information, which includes information that identifies, relates to, describes, or is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular individual, such as your name, e-mail address, telephone number, business address, business affiliation, or any other identifier by which you can be identified online or offline ("personal information").
- Customer information, which includes information we collect from our customers or potential customers including contact information, business association, invoicing information such as primary billing contact and payment status, and information about which Company products or services you use or are interested in using. This also includes information collected using Company products. Some of this information may constitute personal information, per the above definition.
- Transactional information, which includes information we collect from and about customers who place an order for our services or using our services including order details such as item descriptions, quantities, colors, sizes, and quantity of item(s) ordered.
- Device information, such as your IP address, information about your internet connection, operating system, browser type, the equipment you use to access our website, and usage details.
- Activity information and analytics information, such as whether you open an email we send you, information about how you use our products, or details of your visit to our website including traffic data, location data, logs, and other communication data, as well as the resources that you access and use on the website.
The types of information we collect from you depend on your interaction with us. For example, we collect different information from you when you visit our website, than when you become our customer and use our products or services. Accordingly, we may not collect all the above types of information from everyone who interacts with us.
We collect information from or about you for the following purposes:
- To provide you with products and services that you request from us.
- If you are an existing customer or have otherwise provided your information directly to us, to send you information about our products and services.
- To improve our website, products, and services.
- To monitor activity on our website, including trends, usage patterns, analytics information, potentially fraudulent activity, and cybersecurity threats.
- To respond to your inquiries.
- To enforce our legal rights.
- Any other purpose that is disclosed to you at the time we collect your information.
How We Collect Your Information
We collect information from you directly when you provide it to us, as well as automatically when you navigate through the site, including through our use of cookies and other tracking technologies. How we collect information from or about you depends on your interaction with us.
Direct Collection
The information we collect directly from you may include:
- Information that you provide to us when you subscribe to our services, request information about a product or service, fill out a form on our website, or become a client of the Company. This includes information such as contact information and information about your business or organization for us to provide products and services to your business. This also includes payment and billing information, so that we can bill you for using our products and/or services.
- Information we collect from you through your use of our products and services. This includes customer information, transactional information, and personal information as listed above, including how you use our products, and details about the orders you place including the transactional information described above, preferences, activity information, log information, and device information.
- Information we collect by interacting with you at in-person events. This includes information you provided to the event organizer as part of your participation in the event, and information you provide directly to us at the event, including when you fill out a form, scan your badge at our booth or similar mechanism, or provide us with your business card.
- Records and copies of your correspondence if you contact us.
- Other information you voluntarily provide to us through our course of providing you with products and services, visiting our website, or otherwise interacting with us.
The Company does not collect any sensitive personal information or any special category data from you.
Automatic Collection
As you navigate through and interact with our website, we may use automatic data collection technologies, including cookies, to collect certain information about your equipment, browsing actions, and patterns. For more information on our use of cookies, please see the Cookies section below. The information we collect automatically through our website may include:
- Your search queries on the website.
- Analytics information regarding your use of our website.
- Information about your device, including your IP address and equipment information.
Industry Groups and Publicly Available Sources
We may also collect information about you from industry groups and partners, such as trade associations and other groups that you join. We collect information from industry groups when you provide your information to them and permit them to share it with us. At times, we also collect information from publicly available sources.
Combining Information
We may maintain or associate information we collect automatically through our website with other information we collect or maintain about you, including personal information. For example, if you fill out a form on our website or directly provide us with your information by interacting with us, we may associate the information you directly provide us with additional information we collect automatically on our website. This helps us improve our website and deliver a better and more personalized service to you, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our website according to your individual interests.
- Speed up your searches.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
- Present our website and its contents to you.
- Provide our products and services to you. This may involve sharing your information within the Company.
- Provide you with information about products or services that you request from us.
- Contact you directly about goods and services that may be of interest to you, but only if you are an existing customer or if you have provided your information directly to us at an event or through an online form.
- Market our products and services to you, including through cookies and other tracking technologies, as described below.
- Notify you about changes to our website or any products or services we offer or provide.
- To comply with our legal obligations, to enforce our rights, and to protect the rights and property of the Company and others.
- Fulfill any other purpose described to you when you provide the information.
- For any other purpose you consent to.
Cookies
We use cookies (or browser cookies) and similar technologies to automatically collect data from you. A cookie is a small file which asks permission to be placed on your computer's hard drive. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
Disclosure of Your Information
We may disclose personal information that we collect, or you provide, to the following categories of third parties and for the following purposes:
- To our contractors, service providers, vendors, and other third parties we use to support our legitimate business purposes (collectively, "service providers"). This includes third party payment processors who process payments on our behalf and assist us with billing. These service providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- To assist in our marketing efforts to provide you with more relevant advertisements.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which personal information held by the Company about our website users is among the assets transferred.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our subscription agreement, terms and conditions or terms of use, and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may disclose aggregated information about our users and de-identified or pseudonymized information that does not identify any individual without restriction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being set. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
- Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our products or services to you, you can opt out by sending us an email stating your request to sales@ipromo.com. If we have sent you a promotional email, you may unsubscribe by using the link in the email.
- Revoking Consent to Disclosure. If you wish to revoke your consent to our disclosure of your personal information, you may do so by sending us an email stating your request to sales@ipromo.com. Please note that we may be required to disclose certain information about you to provide you with products or services, and we may be compelled to disclose information about you in certain circumstances, so you may not be able to opt-out of all disclosures of your personal information. We will notify you of these required disclosures if you make this type of request.
We do not control third parties' collection or use of your information to serve interest or behavior-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Additional Rights Regarding Your Information
You may send us an email at sales@ipromo.com to request access to, correct, or delete any personal information that you have provided to us. You may also express your objection to our processing of your personal information if our processing is based on your consent. We will take steps to verify your request, including steps to verify that you are the individual making the request. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will not discriminate against you for exercising any of these rights.
Data Security
We have implemented physical, technical, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. This includes using encryption and other techniques to secure passwords and other information. Only those who need access to your information in our organization can access it.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.
Data Retention
Unless otherwise required by law, we retain your information only if necessary to fulfill the purpose for which your information was provided. When it is no longer necessary to retain your information, we will, as applicable, erase, destroy, de-identify, return, delete, aggregate, or pseudonymize your information.
Children Under the Age of 16
Our website, products, and services are not directed towards or intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, do not use our website or provide any information to us. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete this information. If you believe we might have any information from or about a child under 16, please contact us at sales@ipromo.com.
GDPR and State Consumer Privacy Law Notice
If you are a resident of certain states, the EEA, or UK, laws in your jurisdiction may afford you with certain rights regarding your personal information, or "personal data." This section is intended to provide notice to consumers and residents of jurisdictions with such consumer privacy laws, and only applies to consumers in jurisdictions with consumer privacy laws. We are a small business, so even if you believe your state has a consumer privacy law, the law may not apply to us. If you have questions about whether you live in a state with a consumer privacy law that applies, please contact us at sales@ipromo.com.
Categories of Personal Information We Collect
We have collected the following categories of Personal Information from consumers and Site visitors in the last twelve (12) months.
Category | Examples | Collection Sources | Purpose |
---|---|---|---|
A. Identifiers. | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | Yes, directly from consumers, from third party sources, automatically from website visitors. | To provide you with products and services you request from us, to communicate with you, to fulfill your requests, to market to you (including targeted advertising), any other purpose you direct or consent to, our legitimate business interests. |
B. Personal information categories listed in state statutes, including the California Customer Records statute (Cal. Civ. Code 1798.80(e)). Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | ||
C. Protected classification characteristics under state or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | ||
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | ||
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No. | Not applicable. |
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | Physical location or movements. | |
G. Geolocation data. | Physical location or movements. | ||
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | ||
I. Professional or employment-related information. | Current or past job history or performance evaluations. | ||
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | ||
K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
We may not collect each of the above categories of information from individuals who interact with us. We also may not collect each of the types of information listed in the "examples" column from or about you.
Our "legitimate business interests" includes improving our product and service offerings, complying with our legal obligations, maintaining the security of our website, mobile app, or online service offerings, protecting, detecting, investigating, and preventing fraudulent transactions or illegal activities in connection with our products, websites, and services, and other purposes you direct when you disclose your information to us.
We retain each of the above categories of information for as long as reasonably necessary for the purpose for which the information was collected or that you consent to, consistent with our data retention policies and practices.
Disclosures of Personal Information for a Business Purpose
We disclose personal information to third parties, including service providers, vendors, consultants, partners, and investors, for business purposes. When we disclose information to a service provider, we enter into a contract that describes the purpose for our disclosure of personal information, and which requires the recipient to both keep the information confidential and not use it for any purpose other than providing services to us or our affiliates pursuant to the contract.
We disclose your personal information to the following categories of third parties:
- Service providers, which we refer to as service providers, vendors, and consultants in this Privacy Notice.
- Investors, including any organization, fund, or venture who owns a majority stake in our organization.
- Businesses that we partner with to provide products or service offerings.
- Pursuant to court orders, in response to judicial process or to provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, to protect or enforce our rights or otherwise as required by law.
We have disclosed all the categories of information that we collect, as indicated above in the "Categories of Personal Information" chart, for a business purpose to the above categories of third parties within the last twelve (12) months.
Sales and Sharing of Personal Information, and Personal Information Used for Targeted Advertising
We do not "sell" personal data in exchange for monetary value. However, California's privacy law defines "sale" more broadly than the traditionally understood use of the word, and based on this, some of our personal information processing activities may constitute a "sale" of personal information under California law.
Based on California's definition of the terms, we have "Sold," or "Shared" the following categories of your personal information to the following categories of recipients, or used the following categories of personal information for "targeted advertising" in the last twelve (12) months.
Categories of Personal Information "Sold" to or "Shared" with Third Parties | ||
---|---|---|
Category | Examples | Categories of Recipients |
A. Identifiers. | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
|
B. Personal information categories listed in state statutes, including the California Customer Records statute (Cal. Civ. Code 1798.80(e)). | Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | |
C. Protected classification characteristics under state, or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Not sold, shared, or used for targeted advertising. |
D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | |
E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | |
F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | |
G. Geolocation data. | Physical location or movements. | |
H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | |
I. Professional or employment-related information. | Current or past job history or performance evaluations. | |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | |
K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Your State Consumer Privacy Law Rights
In addition to the foregoing, depending on the jurisdiction in which you reside, you may have the following additional rights and choices regarding your personal information. While we use the term personal information throughout this Notice, we intend for this to include "personal information" where that is the term used under applicable law. If you have questions about whether you live in a jurisdiction that affords privacy rights, please contact us using one of the methods listed below.
Right to Request Access or Right to Know
You have the right to request that we disclose information to you about our collection and use of your personal information over the past 12 months. You have the right to request the following:
- The categories of personal information we collected about you.
- The specific pieces of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- The business or commercial purpose for collecting your personal information.
- The categories of third parties with whom we have disclosed your personal information in the preceding twelve (12) months.
- The categories of personal information we sold or shared about you, and the categories of third parties to whom the personal information was sold or shared by category of personal information.
Right to Portability
After you make a request to access or know your personal information, you have the right to request to obtain a copy of this information in a portable, readily usable format that allows you to transmit the information to another party, to the extent it is technically feasible. You may also have the right to request that we transfer your data to another organization, under certain circumstances.
Right to Deletion or Right to Erasure
You have the right to request that we delete any of the personal information that we collect or retain about you, subject to certain exceptions. After we receive and verify your request, we will delete (and direct any of our service providers that hold your personal information on our behalf to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining your personal information is necessary for us or our service providers, as permitted by law.
Right to Limit Certain Uses and Disclosures of your "Sensitive Personal Information"
You have the right to limit our use and disclosure of your "sensitive personal information," as that term is defined in applicable statutes, where we have collected it to use as necessary to perform the services or provide the goods reasonably expected by you, and as otherwise authorized by the statute and regulations. We do not collect sensitive personal information from consumers.
Right to Correct Personal Information if the Information is Inaccurate
If you believe or discover that personal information we have collected about you is inaccurate, you may contact us to request that we correct and update the information so that it is accurate. Where applicable, you may also log into the "My Account" or "Settings" page of the Services to update your information.
Right to Withdraw Consent
If you have previously consented to the use of your personal information for direct marketing or targeted marketing, you may withdraw your consent at any time.
Right to Restrict or Object to Processing
You may have the right to restrict certain processing of your personal information, or to object to certain processing of your personal information, including where our legal basis for the processing is your consent, where the processing involves Special Category Personal Data or sensitive personal information, or where it involves automated decision making technologies. This right is subject to certain restrictions.
Right to Appeal
If you are a resident of certain jurisdictions, you have the right to file an appeal with us if we deny your request to exercise your rights. Requests to appeal can be communicated through the same means by which your request was submitted. If we deny your appeal, you may have the right to appeal to your state regulator. We will provide you the information of the applicable regulator if we deny your appeal.
In addition to the above rights, you also have the right to:
- Appoint an individual to exercise your rights on your behalf, or to exercise rights on behalf of your minor child, if we have collected their information.
- Access information about automated decision making (as applicable).
- Opt-out of automated decision making (as applicable).
- To not be discriminated against for exercising your rights.
Right to Lodge a Complaint
You may have the right to make a complaint with the supervisory authority for your country of residence. If you are an EU Resident, details can be found here.
Exercising your Rights
If you believe you reside in a jurisdiction that affords consumer privacy rights to its residents and you wish to exercise any of the rights described above, please submit a request to us using the information in the "Contact Us" section below.
We may only process your request if the law under which you are making the request applies to us. If you make a request, we will take steps to verify your request, including that you are a resident of the jurisdiction in which you indicate and that jurisdiction affords the rights you seek to exercise, that you are the person making the request, or that the person making the request on your behalf has your legal authority to make the request. Additionally, in order to verify your request, the request must include sufficient information that allows us to reasonably verify that you are the person the personal information we have collected relates to (or you are authorized to act on that person's behalf), and you must describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We will only use the information you or your agent provides when making a request to respond to your request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Response Timing and Format: We endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination: We will not discriminate against you for exercising any rights you have under applicable law. Unless permitted by applicable law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by state law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal Data's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Changes to Our Privacy Policy
We will post any changes we make to our privacy policy on this page and update the "last updated" date at the top of the policy so that you are aware of the date the policy was last changed. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the website home page. If you are an existing client or customer, we may also endeavor to provide you with notice of material changes via email, if we have an email address on file for you or your business. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes. Continued use of our services after updates to our Notice will be deemed consent to the changes.
Contact Information
If you have any questions or concerns about this privacy policy or our privacy practices, you may contact us by emailing us at sales@ipromo.com, calling us toll-free at (888) 994-7766 or by writing to us at:
iPromo
25 N High Street
Canal Winchester, OH
United States, 43110