Effective Date: May 24th 2018 Notice Version: 1.0
Data Controller Contact Information
IMS Internet Marketing Solutions SARL
Rte Matagasses 54.
CH-1268 Burtigny, Switzerland
This document governs the privacy notice of our websites.
Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect from you, how we collect it, how we protect it, how we may share it, how you can access and change it, and how you can limit our sharing of it. Our privacy notice also explains certain legal rights that you have with respect to your personal data. Any capitalized terms not defined herein will have the same meaning as where they are defined elsewhere on our website.
When using our website and submitting personal data to us, you may have certain rights under the General Data Protection Regulation (GDPR) and other laws. Depending on the legal basis for processing your personal data, you may have some or all of the following rights:
The right to be informed
You have the right to be informed about the personal data we collect from you, and how we process it.
The right of access
You have the right to get confirmation that your personal data is being processed and have the ability to access your personal data.
The right to rectification
You have the right to have your personal data corrected if it is inaccurate or incomplete.
The right to erasure (right to be forgotten)
You have the right to request the removal or deletion of your personal data if there is no compelling reason for us to continue processing it.
The right to restrict processing
You have a right to ‘block’ or restrict the processing of your personal data. When your personal data is restricted, we are permitted to store your data, but not to process it further.
The right to data portability
You have the right to request and get your personal data that you provided to us and use it for your own purposes. We will provide your data to you within 30 days of your request. To request your personal data, please contact us using the information at the top of this privacy notice.
The right to object
You have the right to object to us processing your personal data for the following reasons:
- Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling); and Processing for purposes of scientific/historical research and statistics.
- Rights in relation to automated decision-making and profiling.
- Automated individual decision-making and profiling
- You will have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Filing a complaint with authorities
You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the General Data Protection Regulation. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
For details about your rights under the law, visit https://goo.gl/F41vAV
‘Non-personal data’ (NPD) is information that is in no way personally identifiable.
‘Personal data’ (PD) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. PD is in many ways the same as Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.
A “visitor” is someone who merely browses our website. A “member” is someone who has registered with us to use or buy our services and products. The term “user” is a collective identifier that refers to either a visitor or a member.
Topics Covered in Our Privacy notice
- Information We Collect
- How Your Information Is Used
- Retaining and Destroying Your PD
- Updating Your PD
- Revoking Your Consent for Using Your PD
- Protecting the Privacy Rights of Third Parties
- Do Not Track Settings
- Links to Other Websites
- Protecting Children’s Privacy
- Our Email Policy
- Our Security Policy
- Use of Your Credit Card
- Transferring PD from the European Union
- Changes to Our Privacy Notice
Information We Collect
Generally, you control the amount and type of information that you provide to us when using our website.
Our Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing your PD when you buy our products or services is based on and the necessity for the performance of a contract or to take steps to enter into a contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter and information about our products and services through our website opt-in forms is based on consent.
What Happens If You Don’t Give Us Your PD
If you do not provide us with enough PD, we may not be able to provide you with all our products and services. However, you can access and use some parts of our website without giving us your PD.
We Collect Your PD in the Following Ways:
We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our website, if any, as well as the name of the website you’ll visit when you leave our website. This information also includes the IP address of your computer/the proxy server you use to access the Internet, your Internet service provider’s name, your web browser type, the type of mobile device, your computer operating system, and data about your browsing activity when using our website. We use all this information to analyze trends among our users to help improve our website.
When Entering and Using Our Website
When you enter and use our website and agree to accept cookies, some of these cookies may contain your PD.
At User and Member Registration or When Buying Products or Services
When you register as a user, member, or when buying our products or services, we may collect some or all of the following information: your first and last name, email address, physical address, company name, credit card or other payment information, phone number, user name, password, and other information listed.
Website Chat and Support Software
Our website contains chat software and support software that enable visitors to communicate with us live online or offline by email. In some cases, visitors can communicate with us without becoming a member or buying our products and services. When you use this chat software, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to provide to us. You should limit the information you provide to us that is only necessary to answer your questions.
Strictly Necessary Cookies
These cookies collect information about the use of the website, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
These cookies enable the website to remember a user’s choices – such as their language, user name, and other personal choices – while using the website. They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos on the website.
These cookies can be used to improve a website’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies
These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website. Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.
- Identifying the areas of our website that you have visited
- Personalizing content that you see on our website
- Our website analytics
- Remarketing our products or services to you
- Remembering your preferences, settings, and login details
- Targeted advertising and serving ads relevant to your interests
- Affiliate marketing
- Allowing you to post comments
- Allowing you to share content with social networks
We may also use a technology called web beacons to collect general information about your use of our website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.
Google Analytics Privacy Notice
Our website uses Google Analytics to collect information about the use of our website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our website, what pages they visit, and what other websites they have used before coming to our website. We use the information we get from Google Analytics to analyze traffic, remarket our products and services to users, improve our marketing, advertising, and to improve our website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Google Analytics collects only the IP address assigned to you on the date you visit our website, not your name or other identifying information. We do not combine the information collected using Google Analytics with PD. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our website, the cookie cannot be used by anyone but Google. Google also uses specific identifiers to help collect information about the use of our website. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/
You can prevent Google Analytics from using your information by opting out at this link:
To opt out of Facebook’s collection and use of information for ad targeting visit:
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our website and Hotjar’s use of tracking cookies on other websites by following this by visiting:
How Your Information Is Used
We use the information we receive from you to:
- Provide our products and services you have requested or purchased from us
- Personalize and customize our content
- Make improvements to our website
- Contact you with updates to our website
- Resolve problems and disputes
- Contact you with marketing and advertising that we believe may be of interest to you
Communications and Emails
When we communicate with you about our website, we will use the email address you provided when you registered as a member or user. We may also send you emails with promotional information about our website or offers from us or our affiliates unless you have opted out of receiving such information.
You can change your contact preferences at any time through your account or by sending us an email with your request to: Privacy@promotelabs.com
Sharing Information With Affiliates and Other Third Parties
We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation purposes we may use your NPD, which might be sold to other parties at our discretion. Any such data aggregation would not contain any of your PD. We may provide your PD to third-party service providers we hire to provide services to us. These third-party service providers may include but are not limited to: payment processors, web analytics companies, advertising networks, call centers, data management services, help desk providers, accountants, law firms, auditors, shopping cart and email service providers, and shipping companies.
We may share your information with third parties by using an Application Program Interface “API” or other similar software. Such third parties may include companies who process information on our behalf (processors). This sharing of information helps us provide you with our services and a better experience.
Sharing Information With Facebook and Google for Marketing Purposes
We may share your PD with third parties for similar audience marketing purposes. Similar audience marketing is also called lookalike audience marketing. The third parties we share your PD with for this type of marketing include Facebook and/or Google. Using your PD, for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours, this helps us improve our marketing services. Your PD is only shared with Facebook and Google for this type of marketing. By using our website and agreeing to our privacy notice, you are giving your consent for your PD to be used for the marketing purposes described within this section.
Legally Required Releases of Information
We may be legally required to disclose your PD if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users or members; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates.
Disclosures to Successors
If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PD to the new business. The new business would retain the right to use your PD according to the terms of this privacy notice as well as to any changes to this privacy notice as instituted by the new business.
We also retain the right to transfer your PD if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Community Discussion Boards
Our website may offer the ability for users to communicate with each other through online community discussion boards or other mechanisms. We do not filter or monitor what is posted on such discussion boards. If you choose to post on these discussion boards, you should use care when exposing any PD, as such information is not protected by our privacy notice nor are we liable if you choose to disclose your PD through such postings. Also, PD you post on our website for publication may be available worldwide by means of the Internet. We cannot prevent the use or misuse of such information by others.
Retaining and Destroying Your PD
We retain information that we collect from you (including your PD) only for as long as we need it for legal, business, or tax purposes. Your information may be retained in electronic form, paper form, or a combination of both. When your information is no longer needed, we will destroy, delete, or erase it.
Updating Your PD
You can update your PD using services found on our website. If no such services exist, you can contact us using the contact information found at the top of this notice and we will help you. However, we may keep your PD as needed to enforce our agreements and to comply with any legal obligations.