effective date May 2023
Owner and Data Controller:
360 Promos Limited
50 Brighton Road,
London, N16 8EG
Company Number 13515481
Owner contact email: email@example.com
- 360 Promos and its Affiliates (collectively, “360 Promos,” “Company,” “we,” or “us”) are aware that you (as referred to 360 Promos visitors, customers, and website license owners) care about the way your personal data is used and shared and take your privacy seriously. This policy sets out how we handle your personal information if you are a 360 Promos user or visitor to our Sites. It shall collectively refer to www.360promos.co.uk and other websites operated by the 360 Promos Group (the “Sites”) and links to the given policy.
- We may revise this Policy from time to time but never in a manner that compromises our commitment to respect the privacy of individuals.
Information We Collect
Information from buyers
The most common types of information we collect include things like: – username, email address, telephone number, information about your computer, visits, and use of www.360 Promos.com (these are information about your browser, IP address, general location as determined by your IP address and provided by your browser), responses to surveys/forms that we might ask you to complete for research purposes, payment information such as payment agent details, transactional details, support queries, web analytics data, information that you provide when you fill in forms on our Sites.
We use this information (I) to respond to your requests or correspondence; (II) to provide customer service; (III) for statistical purposes and analysis; (IV) for management purposes to administer the website or improve our services; (V) to send you technical notices, updates, security alerts, information regarding changes to our policies, support and administrative messages; (VI) to prevent and address fraud, breach of policies or terms, and threats or harm.
Information from partners and service providers
We collect your name, company name, website, phone number(s), address, business type, email address, and billing information, including but not limited to payment details, billing address, etc. We use this information to work with you, confirm your identity, contact you, pay you, and screen for risk, fraud, or other similar types of issues, to send technical notices, updates, security alerts, information regarding changes to our policies, and support or administrative messages.
Information from website visitors
We collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device, support queries, and web analytics data.
Information sourced from third parties
Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
- third-party service providers (like Google and Facebook), which may provide information about you when you link, connect, or log in to your account with the third-party provider, and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider;
- other third-party sources and/or partners, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification services.
How We Collect Personal Information
- We start collecting required information as soon as you visit our Sites for the first time and start saving the optional data once you confirm the receipt of cookies on our Sites.
- We collect personal information when you provide it to us, when you complete registration and buy items or services on our Sites, subscribe to a newsletter or email list, submit feedback, enter a contest, fill out a survey, or seek technical assistance from us.
- We collect personal information automatically as you navigate through the Sites or when you use services associated with the Sites on third-party sources.
- You may be asked to provide personal information while working with our service providers, like server access details, etc.
How We Use Information
We will use your personal information as follows:
- To fulfill a contract or take steps linked to a contract: in particular, to facilitate and process transactions taking place on the Sites, like when you subscribe to a service.
- Where this is necessary for purposes, which are in our or third parties’ legitimate interests. These interests include:
- operating the Sites;
- providing you with services described on the Sites;
- verifying your identity when you sign in to any of our Sites;
- providing support services;
- updating you with company news and information about our Sites and services, e.g., to notify you about changes to our Sites, website disruptions, or security updates;
- carrying out technical analysis to determine how to improve the Sites and services we provide;
- monitoring activity on the Sites, e.g., to identify potential fraudulent activity and ensure compliance with the user terms that apply to the Sites;
- managing our relationship with you, e.g., by responding to your comments or queries submitted to us on the Sites, asking for your feedback, or suggesting to participate in a survey;
- managing our legal and operational affairs (including without limitation managing risks relating to content and fraud matters);
- training 360 Promos staff for optimal service provision to our user community;
- improving our products and services;
- providing general administrative and performance functions and activities.
- Where you grant us consent to:
- provide you with marketing information about products and services which we feel may interest you;
- For purposes that are required by law.
- To respond to requests by the government, a court of law, or law enforcement authorities conducting an investigation.
When We Disclose Information
- We make your personal information accessible only by those who need to perform their tasks and duties and by third parties who have a legitimate purpose for accessing it. We may share your personal information with third parties in the following cases:
- the relevant customer has consented to the disclosure;
- the information is disclosed to contractors or other parties to the extent necessary to achieve the intended purposes explicitly indicated to the relevant customer (for support purposes and license validation);
- subcontractors and service providers who assist us with how we use personal information. Note that our subcontractors and service providers may also transfer and access such information from other countries in which they operate;
- We reserve the right to disclose any personal information as required by law and when we believe, at our sole discretion, that disclosure is necessary to protect our rights, protect someone from injury, and/or to comply with a judicial proceeding, court order, or legal process served on the Company.
Where We Store Information
360 Promos is located in UK and Spain. This means your data will be processed in UK and Spain. We store and process your data based on your consent to this policy. To protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain a high standard of data security compliance.
How Long We Keep Information
How We Keep Information Secure
- We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- sharing and providing access to your information only to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information before granting them access to it;
- using Secure Sockets Layer (SSL) software or other similar encryption technologies to protect the transfer of data and information.
- You must also ensure that your information is safe and secure. We are not responsible if you circumvent any privacy settings or security measures on our Sites. Even if we give you (or you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping that password confidential. Do not share your password with anyone.
How You Can Access and Manage Information
- You can access your personal information that we collect by logging in to your account. You also have the right to request access to other personal information we hold about you and ask for corrections of any errors in that data. Furthermore, you can close the account you have with us for any of our Sites at any time. To make an access or correction request, contact us at support@360 Promos.com. You also retain the right to discontinue your account and remove all personal data by submitting a request form and contacting the support team directly.
- These rights are limited in some situations; for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent. Where we require your personal information to comply with legal or contractual obligations, then the provision of such data is mandatory. If such data is not provided, we will be unable to manage our contractual relationship with you or to meet obligations placed on us. In all other cases, the provision of requested personal information is optional. If you have unresolved concerns, you also have the right to complain to data protection authorities.
- The relevant data protection authority will be the data protection authority of the country:
- of your habitual residence;
- of your place of work;
- in which you consider the alleged infringement has occurred.
- Where we have your consent to do so (e.g., if you have subscribed to one of our email lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can “opt-out” of such communications if you would prefer not to receive them in the future by using the “unsubscribe” option provided via newsletter or contacting us via marketing@360 Promos.com.
- You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies, some parts of our Sites may not work properly in your case.
- Bear in mind that there are the so-called required (essential) cookies, which will apply regardless of your browser preferences. These cookies may come from the following sources:
- Additionally, there are optional (non-required) cookies enforced by such entities as Meta (formerly Facebook) and Microsoft Advertising (formerly Bing).
- For further information about cookies, including how to change your browser settings and other ways in which you can reject cookies, please visit www.allaboutcookies.org.
- Web Beacons
- 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
- This website uses Google Analytics, a web analytics service provided by Google, Inc. (hereinafter, “Google”). Google Analytics uses “cookies,” which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the Country of your website. Google will use this information to evaluate your use of the website, compile reports on website activity for website operators, and provide other services relating to website activity and Internet usage.
Public Information and Third-Party Websites
- We may display customer testimonials on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name and photo. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
- Blog and user-generated content
- We have public blogs and user-generated content on our website. Any information you include in a comment on our blog or forms may be read, collected, and used by anyone.
- By submitting, posting, or otherwise creating user-generated content on our Sites, you entitle us to use, display, modify, and publish such content anywhere and in any way we deem appropriate, with no restriction and further payment to you. You also grant us a license to make your user-generated content available to other individuals and 360 Promos users for any purpose, including but not limited to content distribution, publication, and promotion. You also authorize us to file a lawsuit for copyright infringement against anyone who uses your user-generated content without obtaining permission from you and/or 360 Promos first.
- If your user-generated content appears on our website and you want it removed, contact us directly at email@example.com. If we are unable to remove it, we will provide you with a reason.
- Social media platforms and widgets
- Our Sites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you visit on our website, and they may set a cookie to ensure the feature functions properly. Social media features and widgets are hosted either by a third party or directly on our website. We also maintain a presence on social media platforms, including Facebook, Twitter, and Instagram.
- The act of submitting any information, communications, or materials to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
- Links to other websites
- If you click on a link to a third-party website, you will leave our Sites and go to the website you selected. Because we cannot control the activities of third parties, we can neither accept responsibility for any use of your personally identifiable information by such third parties nor guarantee that they will adhere to the same privacy practices as us. We encourage you to review the privacy statements of any other service provider from whom you request services.
- Please acknowledge that we may include affiliate/referral links to the website content as previously agreed upon with associated service providers. In case you choose to follow such links and make a purchase on the affiliated third-party website, 360 Promos may be entitled to a referral commission.
Data Protection Policy
360 Promos is operating within UK and Spain and commonly accepted data protection
standards based on the following principles:
- In case you want to access, update, or request a correction or deletion of your personal information, you can do so at any time by sending a request to firstname.lastname@example.org.
- To implement your rights for personal information deletion under the GDPR, you can submit a request at https://360promos.co.uk. All account data will be erased within thirty (30) days.
- Furthermore, you have the right to object to your personal data processing, ask us to restrict its processing, or request data portability. To exercise these rights, please email email@example.com.
- You have the right to issue complaints to a data protection authority concerning our collection and use of your personal information. For more details, please contact your local data protection authority.
- In case you receive our marketing communication as per your prior consent, it is your sole right to opt-out of such communications at any time. You can do so by clicking on the “unsubscribe” link in the marketing emails we send you or contacting us directly at firstname.lastname@example.org.
- Similarly, if you have consented to our collecting and processing of your personal information, you have the right to withdraw your consent at any time. Consent withdrawal will affect neither the lawfulness of any processing conducted by us earlier nor the processing of your personal information executed in relation to lawful processing grounds other than consent.
Our Sites and Services are not intended for children under thirteen (13) years old. No one under the age of 13 years old may provide any personal information to or on the Sites and Services. We do not knowingly collect personal information from children under 13 years old. If you are under 13 years old, do not (I) use or provide any information on our Sites or Services, including on or through any of their features; (II) register on the Sites or Services; (III) make any purchases through the Sites or Services; (IV) use any of the interactive or public comment features of our Sites or Services; or (V) provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 years old, we will delete that information without undue delay. If you believe we might have any information from or about a child under 13 years old, please contact us using the information in the “Contact Information” section below.