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Privacy Statement

.PROMO PRIVACY STATEMENT

Effective Date: August 1, 2013

This Privacy Statement (“Privacy Statement”) explains how .PROMO International Oü (“.PROMO”) uses personal information (“Personal Information”) and applies to all new users who participate to campaigns Organized by .PROMO or any companies in the same business group ("Campaigns") possibly including games, discounts, prizes or premiums from our Content Providers on or after the Effective Date. If you do not agree to our practices, please do not interact with Dotpromo.me services at www.dotpromo.me ("Dotpromo.me") (or the mobile version) ("Sites").

Your legal relationship with .PROMO is governed by (i) campaign specific rules and conditions, (ii) this Privacy Statement, (iii) the terms of service of Dotpromo.me and (iv) the permissions, if any, you have given to .PROMO. Any other documents or statements are not of legal nature, and therefore non-binding.

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can reach us by email at privacy@dotpromo.me. You can reach us via postal mail at the following address:

.PROMO International Oü
Attention: Privacy Office
Roosikrantsi 2,
Tallinn 10119
Estonia

Our Privacy Statement is organized as follows:

1. Types of Personal Information We Collect

2. How .PROMO Collects Personal Information

3. How .PROMO Uses Personal Information

4. When and Why .PROMO Discloses Personal Information

5. Cookies and Related Technologies

6. Referring Friends to Dotpromo.me

7. Your Choices

8. Checking, Correcting and Removing Personal Information

9. Security of Personal Information

10. Notice to Residents of Countries outside the European Union

11. Privacy Practices of Third Parties

12. Communities

13. Facebook Connect

14. Changes and Amendments to this Privacy Statement

15. Register Name and Data Controller

1. Types of Personal Information We Collect

Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. We collect the following types of Personal Information:

  • Contact Information that allows us to communicate with you, such as your name, user-ID, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of .PROMO.
  • IP address and similar identification to help identify your internet connection
  • Relationship Information that helps us to understand who you are and what types of campaigns you might like. This includes lifestyle information; location information related to your state/province, city, or neighborhood; areas of interest, the types of deals that interest you, information collected from social media interactions (such as via Facebook Connect); demographic information (e.g., birth date, age, gender); information about persons whom you invited to Campaigns or who have invited you to Campaigns; and information about friends who refer you or who you have referred.
  • Transaction Information about how you interact with .PROMO, such as the Campaigns you participate to; other information about how you use our Sites, email, other communications, and applications; and how you interact with our Partners, our Content Providers and our service providers.
  • Financial information as needed to processing your orders such as your credit worthiness status or to processing payments for incentives that you may win, such as your bank account number.
  • Mobile Location Information to help us enable you real-time campaigns available nearby, if you have activated one of our mobile applications and permitted your mobile or other location-aware device to transmit location data.

2. How .PROMO Collects Personal Information

We ask you for Personal Information (including Contact Information, Relationship Information, and Financial Account Information) when you register, subscribe, create an account, participate to Campaigns, or otherwise interact with the Sites or contact .PROMO.

By entering information to our Site or our Partners’ sites you accept that we collect information about you and you authorize us to store, process and use this information according to this Statement. If you separately elect so (opt-in), we may send you messages suggesting Campaigns or products from for you, based on collected information.

The condition for registering into the service is the acceptance of the following permissions:

  • 1) The permission for .PROMO to contact the user or to send information on their own or their partners’ services, benefits or campaigns to the user’s valid email address by email and to a mobile phone by SMS.
  • 2) The permission for telemarketing, organized by .PROMO, by phone for the marketing of the following products and/or services: mobile subscriptions and mobile phones, mobile broadband subscriptions and mobile broadband devices, broadband subscriptions and broadband devices, pay-TV subscriptions and pay-TV devices, magazines, and banking, insurance and public utilities with regard to “Telemarketing permission”.
  • 3) The permission, based on the above mentioned Telemarketing permission, for the transfer of nonrecurring telemarketing permissions, which are valid for 30 days at a time (“Nonrecurring Telemarketing Permission”) to .PROMO’s partners or other companies offering the products and services belonging to the product/service ranges specified above and for their use of the said permission; and
  • 4) The permission for the above mentioned Nonrecurring Telemarketing Permission to be immediately transferred to the partners related to the product ranges selected by the user, however, only on a condition that a Nonrecurring Telemarketing Permission, which is related to a single product range, can only be transferred to a single partner. If a participant has not selected any product ranges when participating or if there has not been an opportunity to select a product range, the transferable Nonrecurring Telemarketing Permission will be attached to the product range of mobile subscriptions and devices.
  • 5) The permission for the email contact by .PROMO, which takes place after the above mentioned Nonrecurring Telemarketing Permission has been transferred, where .PROMO offers the user an opportunity to decline the transfer of the Nonrecurring Telemarketing Permission by using the link in the email during twenty-four (24) hours calculated from the reception of the email message.

Each transferred Nonrecurring Telemarketing Permission includes the right to one (1) telephone conversation at most with the user who has given the permission during sixty (60) days calculated from the date when the permission was transferred or from the date when the user’s right to decline the transfer has ended, as defined in section 5. The user can always cancel the Telemarketing Permission or Nonrecurring Telemarketing Permissions. However, the cancellation will never have retroactive effects.

After the Nonrecurring Telemarketing Permission has been transferred, the cancellation must be addressed to the receiver, whose identity is indicated in the email message mentioned in section 5. After the Nonrecurring Telemarketing Permission has been transferred, .PROMO is not able to use the Telemarketing Permission by themselves nor transfer the related Nonrecurring Telemarketing Permissions to other parties before thirty (30) days have passed calculated from the date when the user’s right to cancel the transfer has ended. After the said period of thirty (30) days, as well as when the transfer has been cancelled, .PROMO may continue using the Telemarketing Permission and/or transfer the related Nonrecurring Telemarketing Permissions to other parties.

If a Nonrecurring Telemarketing Permission is not transferred, .PROMO agrees on the practice of not using the Telemarketing Permission more often than for one telephone conversation within thirty (30) days calculated from the date when the permission was given or calculated from the date of the previous telephone conversation realized on the basis of the Telemarketing Permission.

One (1) telephone conversation shall mean reaching the user by telephone and the subsequent telephone conversation, which lasts at least for nine (9) seconds.

The Partners include among others Telekom Deutschland GmbH in Germany for mobile subscriptions and mobile phones as well as for mobile broadband subscriptions and mobile broadband devices, and Saunalahti Oy for mobile subscriptions in Finland.

No collected information shall be handed over to third parties without the participant’s permission with the exception to other companies within the EEA if they belong to the same group with .PROMO.

We collect Transaction Information when you use our Site. For example, we may track the Campaigns you view or participate to, and the comments you make to the forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or through the Site from time to time (collectively “Communities”), or to those related to our social media pages or accounts. We use cookies and related technologies to collect information about your computer and your interaction with the Site and our Partner's websites. You can read more about cookies and other technologies in the Cookies and Related Technologies section.

We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.

We collect information that you provide us about other people when you invite them to Campaigns, including those persons’ Contact Information and Relationship Information.

If you use a social media platform or your mobile device (or other method of communication) to interact with .PROMO or the Sites, the application may have a specific privacy statement that governs the use of Personal Information related to that application. For example, if you use a Dotpromo.me mobile application and your mobile device’s settings allow it, we may collect Mobile Location Information from your device. Our application may be designed to collect information even if you are not logged into the Dotpromo.me application or the Sites. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

We may receive additional Personal Information from third parties. We may use this Personal Information to enhance other information we have about you to help us better understand you and to otherwise enhance the Sites or .PROMO services.

3. How .PROMO Uses Personal Information

.PROMO uses Personal Information to:

  • Fulfill our obligations defined in various user agreements between you and .PROMO;
  • Fulfill requirements of mandatory provisions of applicable laws and regulations;
  • Operate and improve our Sites and Campaigns;
  • Facilitate prize, premium or rebate claims related to Campaigns;
  • Evaluate eligibility of customers for certain campaigns, offers, products or services;
  • Evaluate the types of offers, products or services that may be of interest to customers;
  • Track participation to Campaigns and perform other analytics;
  • Provide customer support;
  • Fulfill requests for Campaign participation related services;
  • Provide advertisements to you through the Sites, as a part of the services;
  • Communicate in way of email messages, text messages, applications and other methods and provide additional information that may be of interest to you about .PROMO and its related services, such as .PROMO news, special offers and coupons, announcements, and marketing materials if you do not deny such communications (opt-out);
  • Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
  • Provide advertisements relating to our Partners or non-related .PROMO services through email messages, text messages, applications, or other methods of communication if you consent to receive such communications (opt-in);
  • Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our Partners or our Content Providers, if you consent to receive such communications (opt-in);
  • Administer surveys in relation to our services or campaigns to which you have participated, if you do not deny such communications (opt-out), and
  • Manage our everyday business needs such as Site administration, forum management, fulfillment, analytics, fraud prevention and enforcement of our corporate reporting obligations, Terms of Use or to comply with the law.

Notwithstanding the above statements on consent, we will nevertheless send you communications if the applicable laws or regulations permit us to do so.

We process your information only within the EEA (European Economic Area) region. However, we do not restrict you to access the services from elsewhere, which may result to some portions of the information to pass through or be stored (depending on the actions of the intermediaries, not .PROMO) in other countries. In any other cases, transfer of information outside of the EEA is only possible with your explicit consent

4. When and Why .PROMO Discloses Personal Information

We will not disclose your Personal Information to third parties except to:

  • Affiliated companies (e.g., subsidiaries and other companies owned by or controlled by .PROMO) who may only use the Personal Information for the purposes described in Section 3 above.
  • The transfer of a nonrecurring telemarketing permission as defined in section 2 of this Privacy Statement.
  • Our service providers that provide services for us such as sending emails on our behalf and fulfilling prize, premium or rebate claims and processing payments. Our service providers are bound by law or contract to protect the Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them.
  • Our Partners, but mainly to the extent it is necessary to do so in order to fulfill your requests, such as requesting our Partners to call you (opt-in) or placing an order for a product or service of our Partners. We may also provide Partners with Personal Information about the individuals who have participated to campaign sponsored by our Partners, to send customized offers, to fulfill prize, premium or rebate claims, to aid and troubleshoot redemption, to combat fraud, as part of legal proceedings affecting .PROMO and the Partner, and to facilitate a direct relationship between Partner and customers and enable Partners to communicate electronically with customers who participated to campaigns sponsored by the Partner.
  • Our Partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with .PROMO and its business Partners and in which you have elected to participate. For example, if you are referred to Dotpromo.me from a Partner's website or through an invitation facilitated by or in conjunction with a .PROMO Partner, .PROMO may provide that business Partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between .PROMO and the business Partner, which may allow such business Partner to contact you directly and to advertise to you.
  • Effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the European Union countries and other countries where we operate. If .PROMO is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

We encourage our Partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control.

We may also use information about you and our other users that is not personally identifiable. For example, we may provide our Partners, or other third parties with reports that contain aggregated and statistical data about our users.

5. Cookies and Related Technologies

When you use our Sites, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Sites and applications, your browser and devices communicate with servers operated by us, our Partners and services providers to coordinate and record the interactivity and fill your requests for services and information.

The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Sites by your computers or mobile devices. These servers are operated and the cookies managed by us, our Partners or our service providers.

For example, when you visit our Sites, .PROMO and our Partners may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return, track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Sites. Some cookies contain serial numbers that allow us to connect your Site activity with other information we store about you in your profile or as related to your interactions with the Sites.

Some cookies are temporary, whereas others may be configured to last longer. “Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. "Persistent" cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Sites, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Sites. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Site and the website you visit after you leave our Site, if this information is supplied to us by your browser.

In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about Site users to optimize our Sites and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Statement governs how we use that information.

Additionally, if the settings on your location-aware device allow us to receive Location Information, we will collect that automatically. If we associate Location Information with other Personal Information, this Privacy Statement governs how we would use that information too.

6. Referring Friends to Dotpromo.me

Dotpromo.me enables you to refer friends to Dotpromo.me. You may be eligible to earn benefits for referring friends (subject to Terms and Conditions for referring a friend and details available on our Sites). If you wish to refer friends to Dotpromo.me, we provide you a unique referral link, which you can share directly with others via email, social media websites, or other communications methods. If someone clicks your link and takes a qualifying action, we may attribute that referral to you for purposes such as awarding a benefit. .PROMO does not collect Personal Information about the persons with whom you share your link until the persons click the link and engage directly with .PROMO.

7. Your Choices

We think that you benefit from a more personalized experience when we know more about you and the kinds of Campaigns you like. However, you can limit the information you provide to .PROMO, and you can limit the communications that .PROMO sends to you.

You can manage your email preferences by logging into your account through the Sites, entering the “My Account” section, and by editing your subscription settings. You can also manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may update your subscription preferences from time to time. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account. For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you participate to Campaigns.

You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

You may manage how your mobile device and mobile browser share Location Information with .PROMO, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

You may also manage the sharing of certain Personal Information with us when you connect with us through a social media platform or application, such as through Facebook Connect. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between .PROMO and your social media account or your mobile device.

8. Checking, Correcting and Removing Personal Information

A registered user always has the right to check and correct her Personal Information in .PROMO’s customer register. Keeping Personal Information about you current helps ensure that we offer you the best campaigns available from us and our Partners. You can do several things to help keep Personal Information about you current. You can access, update and delete your Contact Information, Financial Account Information, and the other information you provided to use in your profile by logging into your account and accessing the “My Account” section of the Site or sending us an email at privacy@dotpromo.me.

If you want to close your account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, closing your account, and removing your active profile, we cannot always delete records of past interactions and transactions.

Should you wish us to remove your Personal Information, we will do so. However, we will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. If you wish to cancel your account or request that we no longer use your information to provide you services please email us at privacy@dotpromo.me. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements and as allowed under applicable laws and regulations.

9. Security of Personal Information

.PROMO has implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. For example, we use industry-standard encryption technology to secure Financial Account Information when it is being transmitted over the Internet.

We store the collected information in our databases according to our information management policy and applicable laws in secured locations and servers within the EEA (European Economic Area). The security policy is as follows:

  • Our premises are physically protected with mechanical and electrical locks and other anti-theft devices.
  • .PROMO applies electronic security systems.
  • The data connections apply firewalls, protection against malware, spam filters, and other devices and software built to increase the security of the data connections.
  • Only named persons and a limited number of .PROMO personnel have access to the information. Our personnel has been trained to take data security into account in their work.
  • We subject ourselves to random security reviews by a third party.
  • The data traffic for the maintenance traffic of .PROMO services is encrypted.

10. Notice to Residents of Countries outside the European Union

.PROMO International Oü is headquartered in Estonia that is part of the European Union. Personal Information may be accessed by us or transferred to us in the European Union or to our affiliates, Partners, or service providers elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to our Privacy Statement, regardless of where it is processed or stored.

11. Privacy Practices of Third Parties

This Privacy Statement only addresses the use and disclosure of information by .PROMO through your interaction with the Sites. Other websites that may be accessible through links from our Sites may have their own privacy statements and personal information collection, use, and disclosure practices. Our Partners may have their own privacy statements, too. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of an offer or promotion.

12. Communities

Our Sites may contain Communities and other areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. All the information you post will be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your email address along with a public review of a campaign, you may receive unsolicited messages from other parties. Please avoid publicly posting Personal Information. If you have questions about Personal Information posted in our Communities, please contact us at privacy@dotpromo.me.

13. Facebook Connect

.PROMO offers Facebook users the opportunity to interact with friends and to share on Facebook using Facebook Connect. If you are logged into both Dotpromo.me and Facebook, when you use the Site’s Facebook connection functions, we will link your Facebook account with your Dotpromo.me account if the email addresses match. If the email addresses do not match, we ask you if you want to link them and you must validate that you control the accounts. If you are already logged into Dotpromo.me but not logged into Facebook, when you use the Site’s Facebook connection functions, you will be prompted to enter your Facebook credentials or to sign up for Facebook. By proceeding through any of these scenarios, you grant .PROMO permission to access your Facebook profile information and to use it in accordance with the Facebook terms of use and this Privacy Statement.

If you are not currently registered as a .PROMO user and you use the Site’s Facebook connection functions, you will first be asked to enter your Facebook credentials and then be given the option to register and join .PROMO. Once you register to Dotpromo.me and connect with Facebook, you will be able to automatically post recent Dotpromo.me activity back to your Facebook wall. Please refer to the privacy settings in your Facebook account to manage the performance of your Facebook account.

14. Changes and Amendments to this Privacy Statement

.PROMO may change or amend this Privacy Statement from time to time. In such case, we will provide notification to you through our service allowing you to review, if you so wish, the changed Statement. We will provide the notification at least 30 days prior to it becoming effective and you will have the possibility to review the changed Statement when you access the service next time after such notification. Any change or amendment is valid from the date of effectiveness issued together with such change, and if nothing is stated, after 30 days from the publication of the changed Statement.

15. Register Name and Data Controller

1. This register is the Customer Register of Dotpromo.me -service

2. The data controller is .PROMO International Oü (business-id 12085800) “.PROMO”, having its address at Roosikrantsi 2, Tallinn 10119, Estonia, email: privacy@dotpromo.me.