Privacy Policy

Last updated: July 4, 2023
Effective date: July 4, 2023

When you start using PromoPilot services, you trust us with your personal information. We respect and protect your privacy and understand the importance of this responsibility, so we will do our best to protect your information.

This Privacy Policy is designed to help you understand the types of information PromoPilot collects, why we collect it, how we use and share it, and how you can update, manage, and delete your information. This Privacy Policy applies to all partners or visitors using PromoPilot services (as detailed below).

1. Scope of this Policy

This Privacy Policy applies to PromoPilot services, as well as the PromoPilot official website, promo-pilot.org domain-related websites, other customized off-site services not on the promo-pilot.org domain, and services provided on third-party websites, such as advertising services. However, this Privacy Policy does not apply to services that have separate privacy policies and are not covered by this Privacy Policy.

This Privacy Policy does not apply to the following:

• 1.1 Information processing mechanisms adopted by companies and organizations that create advertisements for PromoPilot services;
• 1.2 Services provided by other companies or individuals, including third-party products or websites that may include PromoPilot services.

2. PromoPilot Services List

PromoPilot services are listed as follows:

• 2.1 EDM Email Marketing Platform
• 2.2 SMS Messaging Platform
• 2.3 PromoPilot Website Display

3. Information Collected by PromoPilot

We collect information to provide better services to all users; this information helps us analyze content, such as the most useful advertisements for you or content you might like. The types of information collected and the purposes of this information depend on how you use PromoPilot services and your privacy settings.

3.1 Information you provide to us when you register for PromoPilot services

If you register to use PromoPilot services or sign a cooperation agreement with PromoPilot, you must provide personal information including your name, email address, and password.

When you register to use PromoPilot services to create a PromoPilot account, PromoPilot will require you to provide personal information, including your name, password, and email address. We will treat the information you provide to us as personal information.

3.2 Information we collect when you use PromoPilot services as a general visitor

We collect information about the browser and device you use to access PromoPilot services. The information we collect includes audience identification codes (Audience ID), geographic location, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application and version numbers.

In addition, we also collect information about how your applications, browsers, and devices interact with PromoPilot services, including addresses, system activity, and the date, time, and referrer URL of your requests.

If PromoPilot services on your device connect to our servers, we will collect this type of information. Your device may periodically provide information about the device itself to PromoPilot. This information includes your device type and carrier name.

3.2.1 Cookie

We use audience identification codes linked to your browser or device to store the information we collect. PromoPilot services use Cookies from the "promo-pilot.org" domain to identify partners and store website preferences. We also use Cookies on partner webpages to display advertisements to anonymous visitors. The audience identification codes within Cookies are used to track visitor behavior, including webpage browsing history, items purchased, and duration of stay on a page. PromoPilot utilizes this collected information to analyze visitors' online behavior, aiming to improve the effectiveness of online advertising delivery.

The audience identification code is an anonymous tracking code. Visitors browsing the website anonymously do not provide personal data. Consequently, we cannot link this audience identification code to any private information, such as email addresses, mobile phone numbers, or physical addresses. We explicitly state that we cannot determine a person's true identity through this audience identification code.

Our partners can track user behavior using "Tracking Code." This "Tracking Code" utilizes Cookies from the client's domain, which are also referred to as "First-party Cookies."

3.2.2 Device Information

In addition to Cookies, we will also collect the following information:

• 3.2.2.1 URL visited by the visitor;
• 3.2.2.2 Visitor's source address (IP Address);
• 3.2.2.3 Brand, model, and operating system of the visitor's connected device;
• 3.2.2.4 Browser type of the visitor's connected device;
• 3.2.2.5 Geographic location information of the visitor's connection source (e.g., indirectly obtained via GeoIP reverse lookup);
• 3.2.2.6 Telecommunications ISP provider of the visitor's connection source (e.g., indirectly obtained via GeoIP reverse lookup).

3.2.3 Your Location Information

We will collect your location information when you use PromoPilot services, and will determine your location based on the following items, with accuracy varying depending on the situation:

• 3.2.3.1 GPS;
• 3.2.3.2 IP address;
• 3.2.3.3 Sensor data on your device;
• 3.2.3.4 Information about things near your device, such as access points, base stations, and devices with Bluetooth enabled.

3.2.4 Your Activities

We will collect information related to your activities when you use PromoPilot services, in order to recommend videos you might like or provide similar functions. The collected activity information may include:

• 3.2.4.1 Videos you watch;
• 3.2.4.2 Number of views and interactions with content and advertisements;
• 3.2.4.3 Transaction activities;
• 3.2.4.4 Activities on third-party websites and applications that use PromoPilot services.

3.3 Information from trusted partners

In some cases, we may also collect your relevant information from trusted partners. These partners include publishers, marketing partners who provide PromoPilot services and potential customer information to us, and security protection partners who provide abuse prevention information to us. In addition, we will also accept information provided by advertisers to provide advertising and research services on their behalf.

3.4 Technologies used to collect and store information

We use various technologies to collect and store information, including:

• Cookie
• Pixel ad tags
• Local storage (such as browser web storage or application data cache)
• Databases
• Server logs

4. Reasons for PromoPilot's Data Collection

To achieve our goals, we may integrate information collected from various PromoPilot services and your devices, employing diverse information processing technologies. We use automated system analysis to provide personalized advertisements or other functions tailored to user behavior.

If we need to use your information for purposes not explicitly stated in this privacy policy, we will seek your prior consent.

4.1 Provide, Maintain, and Improve PromoPilot Services

We will use your information to both provide PromoPilot services and ensure their normal operation.

4.2 Develop New Services

We will utilize information collected from existing PromoPilot services to develop new services.

4.3 Provide Personalized Services, Including Content and Advertisements

We will use collected information to create personalized services for you, which includes offering recommendations and personalized content. Depending on your settings, we may display personalized advertisements based on your interests.

• 4.3.1 We will not display personalized advertisements tailored to sensitive categories such as race, religion, sexual orientation, or health status.
• 4.3.2 We will not share your personally identifiable information, such as your name or email, with advertisers, unless you actively request to share it.

4.4 Evaluate Effectiveness

We analyze and evaluate data to understand the usage of PromoPilot services. We specifically analyze website visit data, with the results being used to improve product design and other applications. Additionally, we use data related to user interactions with advertisements to help advertisers understand the effectiveness of their campaigns.

4.5 Protect PromoPilot, PromoPilot Service Users and Visitors

We utilize relevant information to enhance the safety and stability of PromoPilot services.

4.6 Provide PromoPilot Customers with More Information

PromoPilot customers can use First-party Cookies to understand users' traffic sources, device types, and geographical locations. This information is then used to analyze users' dwell time, visit events, behavioral events, and consumption information (collectively referred to as "user information"). This "user information" helps PromoPilot customers improve advertising effectiveness, understand ad budget allocation, and make marketing decisions.

4.7 Provide PromoPilot Customers with More Marketing Channels

PromoPilot customers can upload CRM (Customer Relationship Management) data. This CRM data can be used for traditional marketing solutions, such as EDM (Electronic Direct Mail) and SMS (Short Message Service). Furthermore, the CRM data can be imported into other advertising systems for online marketing purposes.

5. Remove and Delete Your Information

You can also, according to applicable laws, request PromoPilot to remove your information from PromoPilot services. PromoPilot primarily collects anonymous visitor data, but you still retain the following rights:

5.1 Delete Data

Visitors can clear their connected device's browser cookies themselves. Partners can contact us to request deletion of account-related data.

5.2 Change or Correct Data

Partners can edit some personal data through their applied PromoPilot service accounts. In some cases, especially when data is incorrect, you can also request us to change, update, or correct your data.

5.3 Object to or Restrict Data Use

You can request us to stop using all or part of your personal data (e.g., if we no longer have a legal right to use it) or restrict our use (e.g., if your personal data is inaccurate or was obtained illegally).

6. Right to Stop Tracking

Visitors have the right not to be tracked. If you wish for PromoPilot to stop tracking your behavior via cookies, please click the "Opt-Out" link for further settings.

7. Information Sharing

Unless one of the following conditions is met, we will not share your personal information with companies, organizations, or individuals outside of PromoPilot.

7.1 For External Processing

We will provide personal information to PromoPilot's affiliated enterprises and other businesses or personnel trusted by PromoPilot for processing. This processing must follow our instructions and comply with our privacy policy and any other appropriate confidentiality and security measures. For example, our customer service is assisted by relevant service providers.

7.2 For Legal Reasons

If we believe that accessing, using, retaining, or disclosing personal information is reasonably necessary for the following purposes, we will provide personal information of PromoPilot partners to third parties other than PromoPilot:

• 7.2.1 To cooperate with any applicable laws, regulations, legal warrants, or legitimate government requests. We will provide information on requests made by various governments to PromoPilot in our public information report.
• 7.2.2 To enforce applicable terms of service, including investigating possible violations.
• 7.2.3 To detect, prevent, or address fraud, security, or technical issues.
• 7.2.4 To provide protection for PromoPilot, PromoPilot service users, and visitors, ensuring their rights, property, or safety are not harmed, as required by law or within legal limits.

7.3

We may publicly disclose information that does not contain personally identifiable content, or provide such information to partners such as publishers, advertisers, developers, or rights holders. We also allow specific partners to use their own cookies or similar technologies to collect information from your browser or device for the purpose of delivering advertisements and evaluating various data.

7.4

If PromoPilot is involved in a merger, acquisition, or asset sale, we will continue to maintain the confidentiality of your personal information. PromoPilot will notify affected users in advance before personal information is transferred or becomes subject to another privacy policy.

8. Defending Cybersecurity

Our services include security measures to protect your information. If we detect a security risk and believe we need to notify you, we will post a notice on the PromoPilot official website. All personal data collected by PromoPilot services, excluding temporary files during network transmission, is stored in Microsoft Azure cloud storage, adhering to international information security standards. Network communications involving personal data transmission occur within the internal network, via SSL VPN, or through HTTPS network connections.

We are committed to protecting user information and PromoPilot service-related information from unauthorized access, alteration, disclosure, or damage. Specific measures taken include:

• 8.1 Employing encryption technology during data transmission to ensure privacy.
• 8.2 Reviewing information collection, storage, and processing practices, including physical security measures, to prevent unauthorized system access.
• 8.3 Limiting personal information access to PromoPilot employees, contractors, and agents based on processing needs. These personnel are bound by strict contractual confidentiality obligations, with non-compliance leading to disciplinary action or contract termination.

9. Complying with Laws and Cooperating with Regulatory Authorities

We regularly review our privacy policy to ensure information processing complies with its provisions.

10. Data Transfer

Data protection laws vary by country and region in terms of completeness and strictness. Personal data collected by PromoPilot services is for internal use only. Due to cloud service data center locations, original log files will be stored in a data center in Singapore. We will implement the protection measures outlined in this policy and comply with specific data transfer legal frameworks, such as EU-US and Swiss-US Privacy Shield Frameworks.

Upon receiving a formal written complaint, we will contact the complainant in accordance with legal or contractual agreements. We will cooperate with appropriate regulatory authorities, including local data protection authorities, to resolve data transfer-related complaints that cannot be resolved directly with the user.

11. Privacy Rights of Minors

We will not knowingly collect personal data from minors under thirteen (13) years of age, or as otherwise stipulated by local laws or regulations, without the guardian's informed consent. We recommend that guardians accompany minors throughout their use of the service.

If you are a minor, you must seek your guardian's consent. You may only provide data to us after we confirm that you have obtained your guardian's consent. Your guardian may, at any time, withdraw any expression of consent, and request updates, access, or deletion of data.

12. Special or Sensitive Personal Data

We will not ask you for, and request that you do not provide, special or sensitive personal data to us. Examples of such data include your medical history, healthcare information, political views, religious beliefs, sexual orientation, sex life, criminal records, or genetic information.

13. Amendments and Inquiries Regarding the Privacy Policy

We may revise this privacy policy from time to time. In the event of significant changes, you will be notified through PromoPilot services or other means, giving you the opportunity to review the changes in detail before they take effect. The revised terms will be published on the website. If you choose to continue using PromoPilot services, it will signify your agreement to the updated privacy policy. If you have any questions regarding your privacy on this website, please contact us via [email protected].