Privacy Policies

Corporate Privacy Policy

Promotion Trust Corporate Privacy Policy

Last Updated: April 16, 2020



Promotion Trust is a division of Pacific Digital Industries, Inc. which also does business under the following names: Hail Agency, Promotion Trust, Sweepstakes Monkey, Promotion Trust and Site Systems (collectively "PDI" or "Promotion Trust"). This privacy policy covers collection and use of information by Promotion Trust.

Promotion Trust respects and is committed to protecting your privacy. We have adopted and implemented this privacy policy as part of our commitment to protecting your personal information from misuse. Promotion Trust makes the same firm commitment to privacy for our web site visitors as we deliver to customers using InSite, our suite of online marketing technologies.

The following discloses our information gathering and dissemination practices for our corporate website For information related to the services utilized by Promotion Trust and provided to our clients, please view our Services Privacy Policy.

By using our website, you consent to the collection and use of this information as outlined in this privacy policy. From time-to-time Promotion Trust may revise this Privacy Policy to reflect changes in the law, technology or industry initiatives. Therefore, you should review it periodically so that you are up to date on our most current policies and practices.

Cross Border Transfers

Promotion Trust collects information globally from many countries and we have developed data security practices designed to ensure that your personal information is appropriately protected. Please note that personal information may be transferred, accessed and stored globally as necessary in accordance with this policy.

Promotion Trust complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. Promotion Trust has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In any matters relating to the EU-U.S. Privacy Shield Framework, Promotion Trust is subject to the investigatory and enforcement powers of the Federal Trade Commission. To learn more about the Privacy Shield program, and to view our certification, please visit and search for our parent company name, Pacific Digital Industries, Inc. in the Privacy Shield List.

Onward Transfers

Because your privacy is important to us, Promotion Trust will not sell, rent or trade your personal information collected on this site except as outlined in this privacy policy.

Promotion Trust may provide your personal information to Promotion Trust contractors who provide support services to Promotion Trust in its execution of its services, but only to perform such functions on our behalf and for our purposes under confidentiality agreements or other appropriate confidentiality assurances. In such cases, Promotion Trust will share only the minimum personal information necessary and maintain liability for those data processors.

Promotion Trust takes steps to protect the confidentiality, privacy and security of personal information communicated to third parties. We shall ensure that any third-party for which personal information may be disclosed subscribes to the Privacy Shield Principles or are subject to law providing the same level of privacy protection as is required by the Privacy Shield Principles and agree in writing to provide an adequate level of privacy protection.

Promotion Trust may 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 the edicts of the law or comply with legal process served on Promotion Trust or its parent company, subsidiaries or affiliates; (b) protect and defend the rights or property of Promotion Trust or the users of, and (c) act under exigent circumstances to protect the personal safety of users of or the public.

In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this website. If Promotion Trust or substantially all of its assets are acquired, personal information will be one of the assets transferred to the acquirer.

Accessing and Choices Regarding Your Personal Information

All individuals, including EU, UK, and Swiss individuals, have the right to know if Promotion Trust maintains personal information relating to you. Upon request, Promotion Trust will provide you with access to the personal information that we hold about you. You may also correct, amend, delete or limit the use and disclosure of the personal information we hold about you. If you have provided Promotion Trust with personally identifiable information, you may access, modify, delete or limit the use and disclosure of the personal information Promotion Trust holds about you by sending an email to with "My Personal Information" written in the subject line. We will respond to your request within thirty (30) days. Promotion Trust, may require proof of identity in order to release/modify personal information.

Promotion Trust acts as a data processor on behalf of its clients. Each of our clients is the data controller for the data they collect in the applicable promotion and is the sole owner of that data. If you contact us regarding personal data collected in connection with a client promotion for which we are a data processor, we will attempt to refer your request to the relevant client, which is the sponsor of the promotion and the data controller. We are not responsible for responding to your request on behalf of the data controller and your request will be directed to the client only. We will process such requests only upon instructions from the data controller that is sponsoring the promotion.

Questions & Dispute Resolution

If you have questions or concerns regarding our compliance with this privacy policy, or if you feel that Promotion Trust is not in compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield principles, you should first contact Promotion Trust by email at . Promotion Trust will respond to any such inquiries or complaints within forty-five (45) days. We will investigate and attempt to resolve questions and any concerns regarding use and disclosure of personal information in accordance with this policy.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third-party dispute resolution provider, (free of charge) at Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Information Collection and Use

Promotion Trust is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. Promotion Trust collects information from our users at several different points on our website. Please view our Services Privacy Policy for more details.

Our website's information request forms may require your name, company, email address, as well as information to help us determine your needs. Promotion Trust uses this information to send updates about our company and to contact you if requested or necessary. You may opt-out of receiving future mailings; see the opt-out section below.

Collection of Personally Identifiable Information ("PII")

Promotion Trust collects "PII" such as Name, Email Address, Postal Address and Phone Number in order to enhance our relationship with you. Such collection is done by you voluntarily submitting the information to us in order to participate in activities like sweepstakes, surveys, registration forums, or because you want us to furnish you with products, services or information. On those occasions when we obtain PII from a third party, we use only reputable sources of such information.

Collection of Children's Information

Promotion Trust is committed to compliance with the Children's Online Privacy Protection Act of 1998 ("COPPA"), including but not limited to verifiable parental consent, choice regarding disclosures to third parties, and parental access to information about online activities that are directed to children under 13.


"Cookies" are small pieces of information that are stored by your browser on your computer's hard drive. They allow us to better analyze our site traffic patterns and to provide improved content and services. They also allow us to refine and enhance visitor registration and to add personalization to our site.

Promotion Trust may use cookies to relate your use of our site to personally identifiable information you have submitted to us. For example, if you've asked us to send you information or updates, cookie information may allow us to limit the materials we send you to items we know match your interests, based on your prior online activities and preferences. By submitting your information to us, you are expressly agreeing that you have "opted-in", and that we may coordinate personal, cookie and click stream information in this manner.

Most web browsers automatically accept cookies, but you may change your browser settings to prevent cookies from being issued if you would prefer not to store this information for future use. If you decide to not accept cookies, you may still be able to use most of the features of our websites, including purchase opportunities.

How We Respond to Do Not Track Signals

Promotion Trust does not process or comply with any web browser's "do not track" signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our website or use our services.

Other Privacy Information

Our website includes links to other websites, and we may develop websites on behalf of our clients whose privacy practices may differ from those of Promotion Trust. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Our website also may include social media features such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. social media features and widgets are either hosted by a third-party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

Behavioral Targeting / Re-Targeting

At times, we may partner with a third-party ad network to manage our advertising on other third-party sites. The ad network partner we utilize may use cookies and web tracking tags to collect non-personally identifiable information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out anytime by deleting your browser's cookies. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Your California Privacy Rights (As provided by California Civil Code Section 1798.83)

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customers' personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.

Security and Privacy

Promotion Trust has made substantial investments in our technologies to ensure security and protection of information which we collect. Promotion Trust takes every precaution to protect against the loss, misuse, and alteration of the information under our control. The servers on which we store personally identifiable information are kept in a secure environment, behind a locked cage.

Periodically, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our customers' information is protected.

Promotion Trust is not responsible for any information submitted in a public forum, such as an online webcast or chat, or for the privacy practices or the content of any other websites to which we link.


All email communications sent by Promotion Trust have clear instructions on how to unsubscribe from future communications. This may be accomplished in several ways including visiting our online Member Center to unsubscribe, clicking on the unsubscribe link within an email or replying to an email indicating you no longer wish to receive communications.

Notification of Changes to our Privacy Policy

From time-to-time Promotion Trust may revise this privacy policy. Therefore, you should review it periodically so that you are up to date on our most current policies and practices. When a change to this policy occurs, we will post a notification at the top of this privacy policy notifying users when it is updated.

Contact Us

Promotion Trust welcomes any suggestions you may have on how to we can improve your experience on our website. If you would like to communicate with us about our website or any privacy related questions or issues, please contact us at:

Privacy Department
Promotion Trust
1175 Branham Lane, No. 18404
San Jose, CA 95158

Phone: (888) 900-4240
International: +1-310-649-0900