Privacy Policy

This policy discloses Promosis’ information gathering and dissemination practices for our websites and for our company in serving our clients. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Promosis Promotions

As a full service motivational marketing agency, Promosis operates Promotions on behalf of its clients. As part of those services, Promosis receives, collects, stores and processes personally identifiable information of both salespeople and consumers on behalf of its clients by use of both online and offline technologies. Promosis collects your personal data fairly and lawfully and in accordance with any applicable law, including the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016. Uses of such data may include notification of potential winners, fulfillment of prizes, client email list generation, required government tax form filing and marketing analysis. Promosis strictly limits access to all personally identifiable information within its organization, and data is never shared outside of the company for any reason whatsoever (with the exception of our clients and relevant government or legal requirements). Personally identifiable information collected by us on behalf of a client belongs to the client, only, and will be used only in accordance with that client’s respective Privacy Policy. An individual’s request to “opt-out” of receiving marketing or other information from a client will be handled in accordance with the respective client’s Privacy Policy and should be directed to that promotion sponsor. Promosis requires its clients, by contract, to use the data which Promosis collects on its behalf in accordance with generally accepted privacy standards for both offline and online data, which includes an “opt-out” method for individuals who have provided personally identifiable information. Promosis is not responsible for data collected on behalf of its clients when such data is in its client’s possession.

Information Collection and Use

Visitors to our web sites and the Promotion web sites developed for our clients may provide to us contact information and other personally identifiable information, such as their name, telephone numbers and email address. This information is used by us to enter the visitor in a Promotion, and select and contact potential winners and other site visitors via phone, fax, email, mail, and other couriers.

When we receive, collect and process participants’ personally identifiable information on behalf of our clients when we administer their promotions, we may also require sensitive information, such as social security number or date of birth. We only use this personally identifiable information to operate the promotion for our client, in order to select winners, award prizes or for the other purposes of the promotion. We retain the information only as long as necessary to verify and conduct the promotion and to provide redundancy for our clients. We do not provide this information to any entity other than our client and others involved in the operation of the promotion. Our clients’ privacy policies govern the use of these data and they remain their property. Any exceptions to these procedures will be announced in the promotion for which the change is made.

Promosis also collects personally identifiable information it receives directly from its’ clients. In these cases, Promosis has no direct relationship with the 3rd party individuals whose personal data it collects. An individual who wants to correct, amend, delete inaccurate data or withdraw consent to further contact should direct his or her request to Promosis’ client. If the client requests Promosis to remove the data, we will do so within 30 days.

It is Promosis’ policy to retain client data, including personal data necessary for the selection, notification and awarding of prizes in promotions and any tax forms that are legally required to be completed for awarding those prizes, for only as long as legally required or as requested by the client, whichever is longer. No personal data is collected other than that required to select, notify and award a prize winner per applicable law. All physical documents are shredded and disposed of by a secure data disposal service. All requests from clients for data to be retained longer than legally required or transferred to them or another vendor must be made in writing and in advance.

We use security measures in accordance with this Privacy Policy, to protect Promosis, Inc., You and the Users against any unauthorized access and modification, disclosure or destruction of the data we hold.

We also collect certain information, not personally identifiable, on our website and in connection with administration of promotions. Promosis may collect information about your computer configuration such as your browser type, operating system, or ISP domain name. Promosis may collect information about the site you last visited prior to the Promotion or about your activity during your visit to the Promotion site. Promosis may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, YouTube, Google or Twitter. By using these services you allow Promosis to access the available information from your third-party social network profile such as your name, age, gender, location, email address and list of friends. This information may be used by Promosis to administer the technical and operational aspects of the site, and may include using your IP address to help diagnose problems with our server. Your IP address may also be used to gather broad demographic information for aggregate use. This enables us to safeguard the promotion and diagnose problems in the operation of a promotion.

Promosis may also use cookies. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A session cookie might be used to track a user through a multi-page registration process so they would not have to reenter information multiple times during the registration process. A persistent cookie remains on your hard drive for an extended period of time. For example, we may set a persistent cookie for a day to prevent a user from returning to a site and trying to enter a Sweepstakes more than once a day. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. Each browser has a function which enables the user to disable cookies if so desired, but in that case, the participant may not be able to participate fully in a promotion, and certain aspects of our site may be limited. We also gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, track anonymous users’ movements and to gather demographic information about the user base of both our client’s promotions and our website. We do not link this automatically-collected data to personally identifiable information.

In addition to our own methods of anonymous data collection, our clients may use other types of tracking technologies. Unless otherwise stated, the use of cookies and other tracking technologies by our clients for the purpose of administering a promotion is not covered by our privacy policy. We do not have access or control over these cookies, nor the data collected in these methods

Sharing your Information

We will share your personal information with third-parties only in the ways that are described in this privacy policy. We do not sell your personal information to third-parties.

We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Provided you indicated your specific approval to do so, we may also provide your personal information to our clients’ marketing partners, who may utilize your information to contact you regarding products and services about which you may have interest. Promosis requires such third-parties to take, in accordance with applicable regulations, all appropriate technical and organizational measures to safeguard the security and confidentiality of personal data and, in particular, conditions allowing to ensure adequate protection of your personal data. You may opt-out of receiving these communications at any time.

We may also disclose your personal information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; to any other third party with your prior consent to do so. If Promosis is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Access and Choices Regarding Your Data

You may view and have inaccuracies corrected in contact information or other personally identifiable information, by sending us an e-mail at service@promosis.com with “Personal Information Update” in the subject line and the correct information written in the body of the email. You may also mail us your request to the address below. We will respond to your request to access within 30 days.

If you have provided us with contact information or other personally identifiable information and do not want to receive e-mail from Promosis in the future and wish to delete such information, please let us know by sending an e-mail to service@promosis.com with “Remove” in the subject line, or you may mail us your request to the address below.

When you provide personal information to us through our website, we will retain your information as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

When sensitive information (such as a social security number) is entered in our promotion and sweepstakes forms, we encrypt the transmission of that information.

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at service@promosis.com.

Other Privacy Information

Our Site may include links to other Web sites and we may develop Web sites on behalf of our Clients whose privacy practices may differ from those of Promosis. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Our Web site also includes Social Media Features such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Our Web site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at service@promosis.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Changes to This Privacy Policy

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you through email or prominent notice on our site before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses. The changes will also be noted in revisions to this privacy policy.

Special Note about Children

We abide by the Children’s Online Privacy Protection Act (“COPPA”). We will not knowingly allow anyone under 13 to provide to us, or to any of our clients on their behalf, any personally identifiable information.

Your California Privacy Rights (As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business made a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

Contact Us

If you have any questions about this privacy policy, the practices of this site or our company, or your dealings with this website, you can contact:

Privacy Policy
Promosis, Inc.
18 Prospect St.
Marblehead, MA 01945
Phone: 781-639-1937

We can be reached via e-mail at service@promosis.com