Last updated: February 25, 2021
This Privacy Policy (“Policy”, “Privacy Policy”) governs the processing of personal information that the promobox.cc service administration (“we”, “Administration”) may collect about Users (“User” or “you”) in connection with your use of the promobox.cc service (“Service”), including the types of information collected, the ways and methods of collecting information, the purposes, measures to ensure the protection of information, as well as the rights of the User in relation to the User's personal information (“Personal Information”), which refers to any information about a specific or identifiable individual who, in accordance with the Agreement, is a User of the Service.
The User hereby agrees to the processing of their Personal Information under the terms of this Privacy Policy. The User's actions aimed at using the Service mean the User’s unconditional acceptance of the terms of this Policy and the terms of their Personal Information processing specified therein. We urge you to read this Policy and make sure that you fully understand and agree to it before you start using our Service. If you have not read the entire text of the Privacy Policy, do not understand or accept the terms of this Privacy Policy, you shall immediately stop using the Service.
The User guarantees that in accordance with the User's jurisdiction, they have reached the age that allows them to independently agree to the processing of their Personal Information (but not younger than 16 years old) or the User can confirm they have got the corresponding permission from the legal representatives in accordance with the established procedure and form.
Please note that you are not required by applicable law to provide us with any personal information, however, providing such information is a prerequisite for using our Service. You hereby confirm, guarantee, and agree that any information you provide to us is provided of your own free will, is accurate, unambiguous, and in accordance with your actual desire to use your data for the purposes described in the Policy.
You can withdraw your consent to the processing of your Personal Information at any time, as we guarantee to make the procedure for withdrawing consent as well as providing it as simple as possible. Withdrawal of the consent does not affect the legitimacy of the Personal Information processing that took place prior to the consent withdrawal.
1.1. In our activities, we are guided by the current legislation of the Russian Federation in the field of personal data processing, as well as by the Directive of the Council of Europe on the collection and storage of personal data (GDPR), and its principles.
1.2. According to the principle of data minimization, we collect as much Personal Information as is sufficient for the use of the service and accomplishing the objectives of its collection.
1.3. In the process of using the Service by the User, we collect two types of Personal Information: Personally Identifiable Information and Non-Personally Identifiable Information.
1.3.1. Personal Information. Such information includes individual data that identifies a particular User and which the User provides us with in the process of the Registration.
Personal information is received by the Service when the User connects a social media account available for entering the system. The service receives the following types of information from the social media account:
If any of the above types of information is missing from the social media account, this information is not received by the Service.
1.3.2. Non-Personally Identifiable Information. Non-Personally Identifiable Information is data that does not identify a particular User, and is collected automatically during the process of the Registration and usage of the Service.
The Non-Personally Identifiable Information may include:
1.4. The User understands and agrees that in some cases, we are entitled to request additional information about the User as well as scanned copies of the User’s documents for confirming the provided information, and to make any other requests when this is necessary based on reasonable assumptions and legitimate interests.
2.1. The legal basis for collecting Personal Information is the User's consent to collect their personal information.
2.2. Personal information is collected by us at the moment the User registers with the Service. The Registration with the Service is made through the User’s account on social media when Personal Information is automatically transferred from the social media page.
2.3. The Non-Personally Identifiable Information is collected by us in the process of using the Service by you.
3.1. We use Personal Information for the following purposes:
3.2 By registering with the Service, the User/Advertiser guarantees:
3.1.1. To provide access to the Service for its further use.
3.1.2. To improve the Service, make its use and adjustment of the necessary settings more convenient based on general or individual preferences, experience of use or difficulties encountered by the Users.
3.1.3. To provide technical support, feedback, including sending notifications, requests and information regarding the use of the Service (update notifications, security information, changes to our rules and terms of use of the Service).
3.1.4. To generate statistics summary reports which include analytics and monitoring of trends in the use of the Service and the Users actions in the Service.
3.1.5. To send advertising newsletters to your email address and to show advertising materials inside the Service about products, services, promotions, events and other news and information which, in our opinion, might be interesting to the User. You can withdraw from receiving advertising messages by selecting the “Unsubscribe” option offered in these messages.
3.1.6. To prevent fraud or violation of the applicable law, in particular, to detect, investigate and prevent fraudulent transactions and any other illegal activities, and to protect the rights and property, as well as the right and property of other users and third parties.
3.1.7. To comply with any applicable law.
3.1.8. To fully and independently order the Services in lieu of the funds paid in advance and transferred to the Advertiser's Account and/or the Ad Balance.
3.2. Personal Information of the User will not be used for purposes other than the above.
3.3. The User confirms that the objectives of using their Personal Information correspond to their interests, and the consent to the processing of the Personal Information by us expressed by the User at the beginning of the use of the Service is given for each purpose of the processing specified in clause 3.1 of the Agreement.
4.1. We undertake not to disclose the User's Personal Information to third parties, unless:
4.1.1. The User expressed the explicit consent to the disclosure of their Personal Information.
4.1.2. The information disclosure is necessary for the use of the Service by the User, as well as for the fulfillment of the User Agreement or any other binding documents that regulate the relationship between us and the User.
4.1.3. When the information disclosure is necessary for the work of the Service and its functionality (information transfer to hosting, communications and content delivery networks (distribution), data protection and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, distribution of emails and monitoring the status of the Service, including measuring performance and data optimization, marketing and advertising services), third parties (recipients of Personal Information) can receive or have access to the User’s Personal Information in full or in part, depending on the role and objectives of each such person in maintaining the operability of the Service or in improving it; in addition, they can use the received information only for the purposes specified in this Policy.
4.1.4. Personal Information is passed in accordance with the applicable law on requests of the entities authorized for the receipt of such information (inquiries made by juridical authorities and law enforcement bodies) when we are obliged to disclose such information if in good faith we reason from what the law requires of us and act accordingly.
4.1.5. Ownership of or control over all parts or a part of the Service is transferred to the new owner.
4.1.6. Personal Information is disclosed in order to ensure the protection of our rights and legitimate interests, or the rights and interests of third parties in case the User violates this Privacy Policy or other binding documents regulating the relationship between us and the User, and the applicable law. The above cases cannot be regarded as an unauthorized disclosure of Personal Information as these actions are aimed at fulfilling the objectives of processing Personal Information.
4.2. We shall never sell Personal Information of the Users to third parties.
4.3. Information can only be disclosed to third parties strictly in accordance with this Privacy Policy and under the applicable law.
5.1. The storage and processing of the User's Personal Information is carried out either directly by us or with the help of third parties specializing in the information storage that are obliged to protect and preserve Personal Information in accordance with this Privacy Policy.
5.4. In the event that we and the User are located in different jurisdictions, the User agrees to the processing and transborder transfer of Personal information to the country of our registration by accessing or using the Services or providing us with their Personal Information in any other way, whereas we guarantee that we will take appropriate measures to protect the User’s Personal Information in accordance with this Privacy Policy, and the applicable law.
5.3. We strive to ensure the User's Personal Information is protected and preserved in accordance with the internal industry standards regardless of any lesser legal requirements as compared to those that may apply in the User’s jurisdiction.
6.1. We use certain monitoring and tracking technologies in order to maintain, provide and improve the operation of our Service on an ongoing basis, and in order to provide a comfortable usage of the Service’s environment for the User. By default, we use several such technologies in order to identify the User and the start of the session, to provide security, to save the User’s preferences (for example, with respect to the default language and settings), to ensure the connection stability, to monitor the performance of our Service and marketing campaigns, and to provide and improve our Services.
7.1. In accordance with this Privacy Policy, each User has the following rights with respect to their Personal Information:
7.1.1. The right of access to the User’s Personal Information. To ensure this right, the Service provides a special section in the User’s Account where all Personal Information we received about the User is indicated. The User can go to the Personal Information section and see the Personal Information of theirs which we currently have. At the request of the User, we provide a complete list of the Personal Information we have collected about the User, the legal basis and purpose of the processing, the Personal Information categories, the list of third parties to whom their Personal Information has been or will be disclosed, the period during which the Personal Information will be stored, measure of the Personal Information protection. The answer to the User’s request shall be given within a reasonable time in accordance with the applicable law.
7.1.2. The right to have inaccurate Personal Information rectified. The User has the right to correct their Personal Information through their Account at any time, in case the User has problems with correcting their Personal Information for some reason, they can send a corresponding request to us, we will make corrections within a reasonable time. Taking into account the purposes of Personal Information processing, the data Subject has the right to provide incomplete Personal Information specifying only the obligatory types of Personal Information that are necessary to access the Service.
7.1.3. The right to withdraw consent to the processing of Personal Information. The User has the right to withdraw their consent at any time. The consent withdrawal does not affect the legality of the processing that was made on the basis of the consent prior to its withdrawal. The Service provides the possibility to withdraw the consent as easily as it is given. Thus, the User can forward us a request to delete their account at any time, and we will delete the account within a reasonable time after receiving the request.
Please note that you can correct, update or delete certain pieces of your Personal Information on your own.
In case the User makes corrections to their Personal Information or revokes the consent, we shall notify all third parties that have access to the User's Personal Information about this.
7.1.4. The right to erasure ("the right to be forgotten"). The User has the right to demand their Personal Information to be removed, and we are obliged to do so without undue delay, if:
7.1.5. The right to data transfer. The User has the right to receive their Personal Information in a structured, commonly used and machine-readable format. The User can receive all their Personal Information, that was ever received by us, in a structured form by sending a corresponding request to the Support Team. The User has the right to have their Personal Information transmitted directly from one controller to another, where technically feasible.
8.1. We store your Personal Information during the entire period the Service is used by you (according to the actions in your account), or until we no longer need this data to provide the Service, or if it is required for a longer period (if we are required to store it for a longer period by virtue of applicable law, or it is done to resolve disputes in relation to our Users, to prevent fraud and abuse, and/or to protect our legitimate interests).
9.1. We hereby guarantee that we take all necessary and sufficient organizational and technical measures in accordance with the applicable law to protect the User's Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions with it by third parties. We act in accordance with the generally accepted industry standards to protect the User’s Personal Information and strive to protect and ensure the confidentiality of Personal Information to the greatest extent possible. The protection of Personal Information is implemented in the Service by default at the stage of its development. The security measures include firewalls, pseudonymization, data encryption, data minimization, robustness of the processing systems, the ability to timely restore availability of and access to Personal Information in case of a physical or technical incident, control of physical access to data centers, as well as control of the authority to access data. We regularly monitor our systems for possible vulnerabilities and attacks, evaluate the effectiveness of technical and organizational measures to ensure the security of Personal Information, and are constantly looking for new ways and service providers to further enhance the security of our Service and protect the privacy of our Users. All third parties that can access Personal Information and take part in the process of providing access to the Service for the User take the same strict measures to ensure the security of Personal Information.
9.2. However, we can not guarantee absolute protection, and therefore we urge you to be cautious, create a strong password for your account and avoid providing any sensitive data, disclosure of which can cause you significant harm.
In the event of any violation of the Personal Information confidentiality, we take all possible measures to eliminate or minimize possible negative consequences, and also ensure that the authorized supervisory bodies and the User are immediately notified of the incident and provided with all available information on the confidentiality breach. The facts of such incidents are recorded in a special register of incidents, which we are obliged to keep in accordance with the applicable law.
9.4. The violation of the Personal Information confidentiality is understood in this Policy as a security breach resulting into the accidental or unlawful destruction, loss, change, unauthorized disclosure or access to the transmitted or processed Personal Information.
10.1. This Privacy Policy, its interpretation, and any claims and disputes related to it are regulated, interpreted and carried out solely in accordance with the laws of our incorporation, without giving effect to the conflict-of-law provisions.
10.2. You hereby agree that any arising disputes shall be resolved solely by the courts at the territory of our incorporation.
10.3. The Privacy Policy may be changed by us at any time. In case we consider the changes significant (at our own discretion), we shall notify you before the changes take effect. Otherwise, we are under no obligation to provide such notice.
10.4. We recommend that you regularly review this page for up-to-date information about our Privacy Policy. Unless otherwise expressly provided, our latest version of the Privacy Policy applies to all information that we have about you.
11.1. If you have any questions about this privacy Policy and the use of your personal information, please contact us at [email protected].
11.2. We will respond to your request within a reasonable time or the period specified by the applicable law.
11.3. In cases when this Privacy Policy or applicable law requires us to supply you with copies of information or documents of any kind, we will provide you with a single copy, provided that you cover the cost of producing and delivering such documents. If you make a request by electronic means, and unless otherwise requested by you, we will provide the response in a commonly used electronic format upon our sole discretion.
11.4. If the User's requests are without a valid reason or excessive, in particular due to their repetitive nature, we may refuse to act on the request.
11.5. In the event that we have reasonable doubts about the identity of the person making a request, we can ask to provide additional information necessary for verifying the identity of the User.
