PRIVACY AND COOKIE POLICY

Overview
The policies below are applicable to ctrlpromo.com ("Website") our mobile and desktop apps (the “Apps”) and all related sites, players, widgets, tools, apps, data, software, APIs and other services (the “Services”) produced and maintained by Ctrl Promo (“Ctrl Promo”) (collectively "Company" or "we", "us", or "our"). The Website, Apps and Services shall be collectively referred to as the “Platform” within this Privacy Policy.
The Company operates a “business to business” rights management service. Prior to being accepted by the Company and executing a contract for services, the Company will collect and stores certain types of data in order to determine whether a business relationship can be established. The manner of the data collection will be set out in this Privacy Policy. Once a services contract has been executed between you and the Company all data submitted by you will be subject to the terms of that contract, this Privacy Policy and our Terms and Conditions. Please read these documents carefully and check them regularly as we may amend the Privacy Policy and Terms and Conditions from time to time.
By using or interacting with our Platform, you are accepting the practices described in our Privacy Policy and you are providing specific, informed and unambiguous consent to the use of your information in the manner set out in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use any part of the Platform. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of our Platform and our affiliate sites following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively, we will provide you with notice of the modifications or amendments.
If you have any questions about this Privacy Policy or don't see your concerns addressed here, you should contact us by email at support@ctrlpromo.com.

Information Collected and Stored
We collect information and data about you and your usage when you use our website, our systems and mobile apps.
When you are using the Platform to complete an application for a services contract with Company, we collect the data requested in the fields found as part of the application process. Those fields may change from time to time. We retain that data in our system to facilitate your application process (e.g.: if you log out mid-way through the application process, your data will still be there when you log back in to further the application process). If you commence the application process but for any reason decide not to complete it and if you wish as to delete the data submitted by you, please contact us at support@ctrlpromo.com. Please be advised we may need to retain portions of the data as set out below.
Once a services contract has been executed between you and the Company all data submitted by you will be subject to the terms of that contract. You will know the types of data we collect as you will be the party submitting that data.

Information we collect automatically
There is certain information that we collect automatically as the result of your use of the Platform, or through the use of web analytics services as described in our Cookies Policy forming part of this Privacy Policy. This information includes but is not limited to:
the Internet Protocol (IP) address of the device from which you access the Platform (this can sometimes be used to derive the country or city from which you are accessing the Platform)
the site that you visited immediately prior to visiting the Website
any search terms that you may enter on the Platform
the time, frequency and duration of your visits to the Platform
your browser type and operating system
the nature of the device from which you are accessing the Platform, for example, whether you are accessing the Platform from a personal computer or from a mobile device and its device-ID
your location data (e.g. IP address) when using the Apps
information collected through cookies and similar technology, as described in our Cookies Policy forming part of this Privacy Policy
information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message

How We Use Your Information
The data we collect automatically helps us to improve our site and services by monitoring how you use it. It also allows us to respond to any feedback and rectify issues quickly to ensure that we always deliver the best products and services possible. These actions include the Company doing the following things:
To operate and maintain your Company account, and to provide you with access to the Platform that you may request from time to time. Your user name and password are used to identify you when you sign into the Platform. Your device-IDs are used to ensure that you are in control of the devices that have access to your Subscription.
To seek your participation in surveys, and to conduct and analyze the results of those surveys if you choose to participate.
To provide you with technical support.
To respond to you about any comment or enquiry you have submitted.
To prevent or take action against activities that are, or may be, in breach of our Terms of Use or applicable law and to otherwise track your compliance with the Platform's rules and regulations.
To customize your account page: Any additional information that you provide as part of your Platform account profile, such as your real name, (but not your email address), will be published on your profile page. This information will NOT be publicly accessible.
To process payment for your use of the Services: If you purchase Services, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment. All payment verification information is transmitted using industry-standard SSL (Secure Socket Layer) encryption.
To service your account: Your email address will be used to send you service updates and account action confirmations/notifications, and (if you have elected to receive them using your account setting) newsletters, marketing messages and certain email notifications. For information about how to change your settings, and to unsubscribe from newsletters, marketing messages and email notifications, please see the “SUBSCRIPTIONS” tab in your Account on the Platform.
To help us personalize and continually improve your experience on the Platform.
To enable third parties to carry out technical, analytical, logistical or other functions on our behalf
Except as disclosed in this Privacy Policy, we do not use or disclose information about your individual visits to the Platform or your personal information collected online to any companies not affiliated with us.
In the event we plan to publicly post any of your personal information on a Website (as, for instance, a letter or a testimonial quote), we will request your permission to provide such posting.
Again, as a company, Ctrl Promo highly respects the privacy of your information and as such will never sell, rent, disclose or loan any information or data collated by our sites and services in anyway.
All of the information and data that you enter into the Platform is dealt with in the strictest confidence at all times. This also extends to telephone calls, instant messages, social networks or good old-fashioned emails. Your privacy is extremely important to us and your personal information will never be used in ways that you have not consented to.

Payment Data
Ctrl Promo utilizes various methods for payments. For payments using Stripe, we store the last four digits of the credit card being used in order to identify the cards. All other billing info in connection with Stripe is stored by Stripe and is subject to their Terms of Use and Privacy Policy. In connection with any payments via PayPal, while PayPal handles all payment transactions on our behalf and collects and stores your data , we only store your PayPal email address. For further information regarding PayPal please read their Terms of Service.

Use Of Cookies And Spyware
We never use or install spyware on your computer, nor do we use spyware to retrieve information from your computer. Like many other third party websites, we use "cookies", which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences. We use cookies to track use of our Platform and online services. We may also use cookies to monitor traffic, improve the Platform and make it easier and/or relevant for your use. You may occasionally get cookies from trusted third-party companies advertising on our behalf. We do not control these cookies, and these cookies are not subject to this cookie policy. If you do not consent to the use of cookies or other technologies, you have the ability to accept or decline them. Most web browsers automatically accept cookies or other technologies, but, if you prefer, you can usually modify your browser setting to decline them or you can use the opt-out links identified in this policy, or the settings within our Apps. Your choice to use the Platform without blocking or disabling cookies or opting out of other technologies indicates your consent to our use of these cookies and other technologies and to our use, in accordance with this Privacy Policy, of any personal information that we collect using these technologies.

Security
We take the security of all data we hold seriously. The following outlines some of the precautions taken to ensure the security of data held by us but is not an exhaustive list:
All client systems are protected by SSL encryption
Sensitive data (such as passwords and payment details) stored on Ctrl Promo servers is encrypted before storage
Client data will not be transferred to 3rd parties unless prior written consent is given by the client, it is required by law, or is required to undertake business activities as previously agreed with by the client
Data should only be accessible to those who are authorised to view it, in most cases this is achieved via username and password access restrictions e.g. to databases and client systems.
All data used as part of the operation of client systems is stored on servers hosted within the US and operated by companies who comply with current UK and EU data protection laws.

Information Collected From Children
This Platform is not directed at those persons under the age of 16 and who are located in the European Union (“EU”) countries and is not directed to children under the age of 13 in countries that are not part of the EU (a “Restricted Person”). Company does not knowingly collect personal information from persons specified in the first sentence of this section. If you are under 16 years of age and are located in an EU country or are under 13 years of age and located in a country outside the EU you must not use the Platform, and under no circumstance should you provide personally information to Company. If Company discovers that a Restricted Person has provided Company with personal information, Company will immediately delete that Restricted Person's information from the Platform. Your use of the Platform is your warranty to us that you are not a Restricted Person.

Third-Party Agents
We have third party agents, subsidiaries, affiliates and partners, that perform functions on our behalf, such as hosting, billing, marketing, analytics, providing customer service, fraud protection, etc. These entities have access to the Personal Information needed to perform their functions and are contractually obligated to maintain the confidentiality and security of that Personal Information. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Platform.

Emergency Situations
We may also use or disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Platform; (b) protect and defend our rights or property, the Platform or our users, and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Platform or the public.

Governing Law/Assignment
The Platform is published in the United Kingdom. We make every effort to protect the personal identifiable information of all users of the Platform. We attempt to comply with local data protection and consumer rights laws to the extent they may apply to the Company services. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personal information to Company.
We may change its ownership or corporate organization while providing the Platform and services. As a result, please be aware that we may transfer your information to another Company that is affiliated with us or with which we have merged. Under such circumstances Company would to the extent possible require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time.

Changes to This Policy
We are committed to maintaining our position as a leading digital services platform on the internet. As our Platform continues to develop, we may add new services and features to our Platform. In the event that these additions affect our Privacy Policy, this document will be updated appropriately. We will post those changes prominently so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We do, however, recommend that you read this Privacy Policy each time you use our Platform in case you missed our notice of changes to the Privacy Policy. We will never, however, materially change our policies and practices to make them less protective of customer information we have previously collected without your express consent.

Withdrawing Consent, Opting Out or Correcting Information
You can withdraw your consent to the manner in which your data is used by the Company at any time prior to entering into a services contract with us. To do so, please send us an email at support@ctrlpromo.com. Please be advised that certain data is required to operate your account and if you seek to withdraw consent you may be disabling our ability to manage your account and as a result your account may be terminated. You may always opt out of receiving future e-mail messages and newsletters from Company. Please visit the Profile tab found at your user account to withdraw consent or to update or correct your personal information.

Length of Time Your Data will be Stored
We will keep and use your data as described in this Privacy Policy for (i) as long as your account is in use, is open, or is active; (ii) as long as is necessary to comply with any tax, legal, and/or other regulatory requirements; and (iii) to protect and defend against potential legal claims. If you would like to request the deletion of your personally identifiable information or request that it be returned to you, please contact us at support@ctrlpromo.com. By deleting your data from the Platform, you understand that you will no longer be able to use our Services. We will retain your anonymized, aggregated, depersonalized data after it has been deleted from the Platform.