Privacy Policies

Services Privacy Policy

Promotion Trust Services Privacy Policy

Last Updated: December 5, 2017

CONTENTS

INTRODUCTION

Promotion Trust is a division of Pacific Digital Industries, Inc. which also does business under the following names: Hail Agency, SweepstakesPros, Sweepstakes Monkey, Promotion Trust and Site Systems (collectivly "PDI" or "Promotion Trust"). This services privacy policy discloses the privacy practices for Promotion Trust, related to services provided to our clients. For information related to Promotion Trust data collection practices on our corporate website, please refer to our website's Corporate Privacy Policy.

Internet user privacy is of paramount importance to Promotion Trust and our clients. Since personal privacy integrity is at the very core of our business, Promotion Trust success depends implicitly upon our ability to maintain the trust of the people using and viewing our services.

Promotion Trust works with our clients to create online, offline and mobile promotions, marketing campaigns and permission-based email marketing programs that achieve superior results. Promotion Trust is a third party vendor that provides solutions that enable companies to create and deliver highly successful marketing programs that drive revenue and deepen customer relationships.

Promotion Trust Services Privacy Policy is designed to ensure that users understand how and why Promotion Trust may collect and use information. The following document thoroughly explains our privacy policy related to services we provide to our clients. Please read it carefully.

CROSS BOARDER 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 transfered 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. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov and search for our parent company name, Pacific Digital Industries, Inc. in the Privacy Shield List.

ONWARD TRANSFERS

Promotion Trust takes steps to protect the confidentiality, privacy and security of personal information communicated to third parties. We will only transfer your personal information to third parties as set forth herein or, in the case of personal information collected by us on behalf of clients, as directed by the client who owns the personal information. For personal information owned by Promotion Trust, 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 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.

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on Promotion Trust.

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

ACCESSING YOUR PERSONAL INFORMATION

You may access the personal information Promotion Trust holds about you in order to correct, amend, or delete inaccurate information by sending an email to with "Personal Information Correction" written in the subject line and the request or the correct information written in the body of the email. We will respond to your request within forty-five (45) days.

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 https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

WHO WE ARE

Promotion Trust is the premier provider of technologies for online marketing. Promotion Trust is a third party vendor that provides solutions that enable companies to create and deliver highly successful marketing campaigns that may include registration forms, sweepstakes, email programs, ads and other marketing programs that drive revenue and deepen customer relationships. Promotion Trust solutions provide deep customer insight and powerful campaign execution through a combination of web-based applications, hosted technology infrastructure and professional services.

These services include the collection and management of customer information. Customers provide this information in two ways: by what they say and by what they do. Promotion Trust helps clients collect and manage customer information from a variety of online, mobile and offline sources in a securely hosted database, including customer-provided profile data from sweepstakes, contests and registration forms, plus behavioral data such as click history. This technology enables Promotion Trust and our clients to better understand the effectiveness of marketing campaigns and to deliver individualized messages to customers.

Promotion Trust is a third party that collects and processes data only on behalf of our clients for the completion of stated purposes. The client, not Promotion Trust, owns data collected by Promotion Trust on behalf of the client. Promotion Trust is contractually bound to keep clients' customer data private and this data is never shared among clients.

CLIENT WEBSITE PRIVACY POLICIES

Clients retain the sole and exclusive right to use any data, which they have obtained through explicit permission from a user. Promotion Trust relies on our clients' consumer privacy policies, and we urge consumers to check the privacy policy of a site before they voluntarily provide information to or do business with a site regarding:

  1. What personal information is collected about the consumer
  2. How that information is used
  3. With whom the information may be shared
  4. What options are available to Web users regarding the accumulation, use and distribution of the information
  5. What security procedures are in place to protect the data
  6. How a consumer can correct inaccuracies in the data

INFORMATION COLLECTION AND USE

Promotion Trust collects information for a client from online registration forms, mobbile applications, sweepstakes, banner ads, telephone, fax, mail, hosted web pages, website tracking, emails sent on behalf of the client to its customers, and other methods. At a client's request, Promotion Trust may also collect information for a client from a variety of methods, such as its website, its ecommerce site, mobbile applications or offline data provided by the client or by 3rd parties. Some clients use all of our services while other clients use only one service.

Providing these services, Promotion Trust acts as a service provider for our clients. This means that Promotion Trust is a third party that processes data only on behalf of our clients for the completion of stated purposes. The client, not Promotion Trust, owns data collected by Promotion Trust on behalf of the client. Promotion Trust is contractually bound to keep clients' customer data private and this data is never shared among clients.

Below are descriptions of what information is collected and how this information is used. For information on the collection technology, please see the section below on how this information is collected.

What kind of information does Promotion Trust collect?

For some clients, Promotion Trust hosts data collection pages. These data collection pages may include surveys, sweepstakes entries or profile pages, where a user knowingly provides data such as name, email address, physical address, and product preferences. These data collection pages will usually appear to the user as a page that resides on the client website. If the client uses a Promotion Trust-hosted data collection page, the client website links to a page that resides on a different server. However, the information is still owned by the client.

Information such as information about the computer system and click stream data are automatically collected and logged when the user browsers the site, but the data is not personally identifiable. Personally identifiable information ("PII") provided by the user, such as Name, Email Address, Postal Address or Phone Number information, is optional and is done in order to participate in activities like sweepstakes, contests, games, surveys, forums, subscription registrations, content or suggestions you submit, chats, bulletin boards, or because users want to be furnished with products, services or information. On those occasions when we obtain PII from a third party, we use only reputable sources of such information.

Promotion Trust is a service provider and provides clients with a website tracking and analysis service. This service uses cookies to measure the effectiveness of a client's marketing campaigns.

Why is this information collected?

The profile data as well as tracking and analysis information are gathered to facilitate a client's ability to provide relevant offers to customers and determine the effectiveness of marketing campaigns.

Under most circumstances, the user has knowingly provided the personally identifiable information to the client website. For more information on the information collection practices of a client, users may refer to the privacy policy for the client website where the information was submitted.

What kind of information does Promotion Trust collect on behalf of clients using our email delivery service?

Promotion Trust sends permission-based email on behalf of clients to their customers. Promotion Trust includes a coded sensor in all of its HTML-based email messages to determine the user's ability to receive HTML-based email messages. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages. The web sensor does not function in a text-only email.

The technology is a web sensor, which is described in detail below, under the section "HOW DO WE COLLECT THIS INFORMATION?"

If a user does receive HTML-based email messages, Promotion Trust collects data on the email client utilized by the user and whether the user opens an email. Promotion Trust collects this information on behalf of the client who sent the email.

Promotion Trust may gather information to determine the success of an email campaign by recording which offer links a user clicks on and which web pages the user visits. Promotion Trust may use information collected to analyze click-through rates to various offers delivered in an email campaign, or use the information collected to deliver individualized (“one to one”) email campaigns.

In addition, many emails sent by Promotion Trust on behalf of clients include a link that enables users to forward a copy of the email to a friend. Also known as referral marketing, this application is completely optional for email subscribers (the user). Unless the user opts to forward an email, no additional information is collected.

If a user opts to forward the email, the only information the user is required to enter is the user's friend's email address. Once the email is sent on behalf of the user to the user's friend, the email address of the friend is not used to contact the friend again, unless the friend visits the client website and subscribes to receive email from the client.

Promotion Trust stores the friend's email address and maps this email address to the email address of the original user (the "forwarder"), in order to provide any promised incentive or to track complaints.

Why is this information collected in email?

Promotion Trust includes technology within the emails to determine a user's ability to receive HTML-based email messages and to track which links they click on inside the email.

HOW DO WE COLLECT THIS INFORMATION?

Use of cookies

Promotion Trust collects the information described in the previous sections through the use of various technologies, including one called "cookies." A cookie is a piece of data stored on the user's hard drive containing information about the user.

For the tracking and analysis services provided on a client website, Promotion Trust sets the cookie when a user clicks on a specifically coded link in an email to the user from the client website. The cookie is set every time a user clicks on the coded link. The cookie is read by the client website wherever the website wishes to identify traffic on its website generated by a marketing campaign.

The cookie set is a persistent cookie. "Persistent" means that the cookie remains on the user's hard drive after the browser is closed.

Simple data collection pages may use per-session only cookies to allow users to log on and access secure areas of the site. These cookies are destroyed when the user closes their browser.

Users can set their browsers to notify them before a cookie is read, giving them the chance to decide whether to accept it. Users can also set their browsers to turn off cookies. However, if they do so, some areas of some sites may not function properly.

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 websites or use our services.

Use of web sensors for tracking and analysis

Promotion Trust and some clients also use web sensor technology. A number of pages across client websites and ads may have these sensors. When a user accesses these pages, notice of that visit is generated. As described above, this "notice" may or may not be tied to personally identifiable information, depending upon the purpose of the data collection.

If users turn off cookies, web sensor technology will still detect visits to the client website pages where web sensors are located. However, the notices the sensors generate cannot be associated with other cookie information and will be counted in the aggregate.

Web sensors in email messages

In order to determine a user's ability to receive HTML-based email messages, Promotion Trust includes a coded sensor in all of its HTML-based email messages. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages.

This capability helps Promotion Trust to send the e-mail in a format users can read. If the user cannot receive HTML, the user will not receive a functioning sensor.

In addition, the sensor provides Promotion Trust with information on how many users open an email. This information is used to compile aggregated statistics about an email campaign for our client.  

WHO HAS ACCESS TO THIS INFORMATION?

For information collected by us on behalf of clients, the client for whom we are providing the service has access to the data collected. The client owns the information and once the data is transferred to the client, the client controls who has access to this information.

Prior to this transfer, Promotion Trust limits access to the data to employees responsible for receiving, storing and transferring the data to the client. Promotion Trust is bound by contract to maintain client data in a secure environment.  

HOW LONG IS THE INFORMATION RETAINED?

Promotion Trust retains data collected for as long as each client requires it and as required by law. This time period varies for each client. Web log data may be retained for an indefinite period of time.  

DO USERS HAVE ACCESS TO THEIR INFORMATION?

Promotion Trust requires that all clients include an unsubscribe link in every marketing email sent to users through Promotion Trust systems. Promotion Trust also requires that all clients honor unsubscribe requests in a timely manner. For specific information on how to access information users have provided to a client website, users should consult the privacy policy of the client website where they submitted the information.

Promotion Trust only provides the information collected to the client for whom it is collected. Users may have access to certain information collected by the client and should consult the client's website privacy policy for more specific information.

Promotion Trust does not currently provide a mechanism that allows individuals to opt out of the use of information for a particular purpose. However, the user should be able to access profile pages and unsubscribe from email messages at any time. The client may provide users access to this information.

In addition, a user can opt out of an email list managed by Promotion Trust by sending an email to . Users should include:

  • A copy of the email that was received
  • The company name and email list from which they would like to be unsubscribed, and
  • The email address where they receive the messages.

SPECIAL NOTE ABOUT CHILDREN

Promotion Trust promotions are not available to anyone under the age of thirteen (13), unless otherwise specifically indicated.  We do, however, manage promotions on behalf of our clients which may collect personally identifiable information from children under the age of thirteen (13). In each such instance, for U.S based promotions, Promotion Trust and our clients fully comply with all aspects of the Children's Online Privacy Protection Act ("COPPA") in the operation of the promotion, in the collection of the information itself and in the subsequent use of the data collected. Personally identifiable information will not be collected in the U.S. from children under the age of thirteen (13) without parental consent in compliance with the COPPA guidelines.

OTHER PRIVACY INFORMATION

Sites may include links to other websites and Promotion Trust 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.

Websites may also include social media features such as the social sign-on services, 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 a web site. Your interactions with these features are governed by the privacy policy of the company providing it.

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.

ANTI-SPAM STATEMENT

Promotion Trust practices permission-based email marketing. Promotion Trust does not send unsolicited email or work with companies who do so, and the transmission of unsolicited commercial email is expressly forbidden through any of our systems.

If you have received unwanted, unsolicited email sent via this system or purporting to be sent via this system, please forward a copy of that email, the email address to which the email was sent and any comments to for review.

NOTIFICATION OF CHANGES TO THIS POLICY

From time to time Promotion Trust may revise this Servivces 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 our this policy occurs, we will post a notification at the top of this Services Privacy Policy notifying users when it is updated.

CONTACT US

If you have any privacy related questions or issues, please contat us at:

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

Phone: (888) 900-4240
International: +1-310-649-0900
Email:
Website: www.promotrust.com