Version App 1.1, December 2023

Promoaccro APPLICATION PRIVACY POLICY

This Privacy Policy is intended to explain how information about you is collected and used when you enter Promoaccro app (further as the ‘App’).

  1. GENERAL INFORMATION

    Our App allows you to browse the current offers and advertisements of selected retailers in a personalized manner, contact us directly or otherwise interact with us.

    The App also allows you to:

    • organize your favorite content in a suitable manner;
    • receive personalized notifications about new offers;
    • contact us via e-mail;
    • make a custom shopping list;
    • rate and recommend our App.

    When you install and use our App we may collect certain information about you which may be considered personal data. Below you will find detailed information about what information we may have about you and how we use it, as well as how to control your preferences with regard to such use.

  2. WHAT DATA DO WE COLLECT

    We may collect two main groups of data in connection with your use of the App:

    • Information you provide us with voluntarily when you manually enter your location, contact us directly e.g. by means of email, as well as otherwise interact with the content we publish (likes, shares, opinions on our App etc.).

      The scope of such information will depend on the type of interaction and may include: your name, e-mail address, content of messages you send us, entered location etc.

    • Information collected automatically by our App e.g. by means of tracking technologies.

      Such information is recorded under a unique identification number (mobile advertising ID) assigned to your device and include: (1) data related to your activity in the App along with timestamps recording the moment of particular events, (2) technical information about the device you are using, (3) IP address indicating your non-specific geographic location e.g. country or region, (4) precise geolocation if you decide to disclose it.

      This data does not directly disclose your identity – it only identifies the device you use in order to run our App and allows us to measure the use of our App and personalize its content and our ads to that device, as described below.

      Our App allows to connect with our social media platforms. We describe our use of data collected there in a privacy policy published on such platform. Please note though that those platforms may also collect other data independently. Please consult their privacy policies to learn more.

  3. HOW DO WE USE YOUR DATA

    We use the collected data to:

    • Answer your queries

      For this purpose we use the data you provide us voluntarily. For example, if you send us an email via the App, we will process your contact data and the content of such message to handle your query, provide you with relevant information and remember what the query was about.

    • Create profiles to personalize content, use profiles to select personalized content and use limited data to select content

      We may use information collected about you to adjust the content of the App. We may for instance select relevant retailers’ offers based on your location data. If you do not permit us to detect your precise location and do not enter your location manually, we will only detect your non-precise location letting us know in which city you use the App (basing on your IP address). To do this, we are using the Ipstack solution.

    • Measure advertising and content performance

      We may use the collected information concerning your interactions with the content we publish, so that we may monitor the App’s functionalities. Such information may include e.g. time, duration of your visit and its details such as items you clicked etc.

      To conduct these analyses, we may also use other third party analytics tools providers which track your actions in the App, namely: Google Firebase and Appsflyer. We use the following Google Firebase features: Real time-overview, Reports, Events, Explore and Configure. We also use Clevertap for measurement purposes.

      You can opt out from Google Firebase analytic activities by sending the opt out inquiry to our email address together with your Firebase Instance ID (you can find this ID by clicking Device Information button, placed in our App’s settings). Click here to opt out from Appsflyer analytic activities.

    • Develop and improve our App

      The data collected about your usage of the App can be used to improve it and to develop new products based on that data.

    • Create profiles for personalized advertising, use profiles to select personalized advertising, use limited data to select advertising

      We will record information concerning your use of our App (e.g. which retailers’ offers you browsed) and based on the data collected this way we will conduct advertising campaigns of our App either using our own technology or by tools provided by third parties. It will allow us to define our audience for ad personalization and measure the effectiveness of the ads displayed by conversion tracking. This will allow us to personalize your experience in browsing the App for the offers that suit you.

      Third parties’ technology we use to conduct advertising activities include:

      You may allow the delivery of push notifications to your device delivered to you based on Clevertap solution. Once you agree to receive notifications, we will send you regular notifications with current offers of selected retailers or other marketing materials. You can always change the notification settings on your device and disable them directly in the App.

    • Allow third-party partners to advertise in our App

      We cooperate with Google (Admanager), to display third-party vendors’ ads in the App in the scope of purposes they declare. These vendors will collect certain non-personally identifiable information about your device’s operating system and the page you are entering in order to place an ad there, as the App page is loading. For more information on how digital advertising works, please: (1) check Google Privacy Policy where you can disable (opt out from) such personalized advertising; (2) review ad partners' identities and privacy policies which you can access via the ‘consent banner’ that was presented to you upon opening the App.

    4. We may also process your personal data to:

    • Understand audiences through statistics or combinations of data from different sources, for example when we will want to present the ad campaigns’ results to our advertising clients.

    • Defend our rights or pursue claims

      This may happen e.g. if you file a complaint regarding the operation of the App, or in case we discover an external attack in our App.

    • Ensure security, prevent fraud, and debug the App

      Your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely.

    • Deliver and present advertising and content

      Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to your device.

  4. WHAT IS THE LEGAL BASIS FOR PROCESSING

    In order to lawfully process your personal data we need to have legal basis for such processing.

    The legal basis will depend on the particular operation of processing. It may be: (i) performing a contract with you, (ii) our legitimate interests (such as developing functionalities of the Website), or (iii) your consent for data processing.

    If you need further information concerning the legal basis for collection and use your personal information, please contact our Data Protection Officer at: dpo.promotons@rtbhouse.com.

  5. WITH WHOM WE SHARE YOUR DATA

    In order to pursue the purposes indicated above your data may be shared with the following categories of third party recipients:

    • affiliated companies

      We share data collected in the App with our affiliated companies who are responsible for securely running the App.

    • third party contractors

      For analytical and advertising purposes, we use tools provided by third parties. Please see section 3 to learn about the purposes of processing and find useful links.

      The data we process is stored in third party data centers.

    • competent authorities

      Your personal data may also be disclosed also to authorities which are competent by the applicable laws to receive such data, including law enforcement authorities.

    We carefully select third parties to whom your data may be disclosed, in particular we make sure they grant an appropriate level of privacy security to your data and process your data only for the intended purposes as well as in compliance with this Privacy Policy and the applicable laws.

    We will not transfer or permit any of your personal data to be transferred to a territory outside of the European Economic Area unless we have taken measures necessary to ensure the transfer is in compliance with applicable laws. Such measures are either transferring the personal data to a recipient in a country that the European Commission has decided provides adequate protection for Personal Data as referred to in Article 45 GDPR or conclusion of standard contractual clauses, as referred to in Article 46.2 (c).

  6. FOR HOW LONG WILL YOUR DATA BE STORED

    We implement the following retention periods with regard your data:

    • 3 years for queries submitted to us by means of an App,
    • up to 26 months for data collected automatically via tracking technologies.

    After the expiry of the following retention periods, and in any case upon your request, we will either delete or anonymize your personal data.

  7. HOW CAN YOU EXERCISE YOUR PRIVACY RIGHTS

    To the extent provided by the applicable data protection laws, in particular the GDPR, you have the right to:

    • access your personal data,
    • rectify your personal data,
    • request erasure of your personal data,
    • object to data processing,
    • restrict processing of your personal data,
    • receive a copy of your data in a structured, commonly used and machine-readable format or to request transmission of the data to another controller,
    • lodge a complaint with a competent supervisory authority,
    • withdraw consent for data processing you gave at any time (without affecting the lawfulness of processing based on consent before its withdrawal).

    We have appointed Data Protection Officer to assist you in any privacy-related matters, in particular to help you exercise the above rights. You may contact our DPO at dpo.promotons@rtbhouse.com.

  8. CHILDREN’S PRIVACY

    We do not knowingly collect or solicit any information from anyone under the age of 16. Our App is not directed to children under the age of 16. In case we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible.

  9. AMENDMENTS

    We keep this privacy policy under regular review to make sure it is up to date and accurate. We will notify about its changes in advance.

  10. CONTACT US

    The operator of the App and the controller of personal data collected on the App:
    RTB Marketing & Tech Services Ltd.,
    Kyriakou Matsi 18, 2nd Floor,
    Egkomi, Nicosia 2408, Cyprus
    dpo.promotons@rtbhouse.com

    You may file a complaint regarding the operation of this App to the above address or to contact@promotons.com.

    Please contact our Data Protection Officer at: dpo.promotons@rtbhouse.com in any matters regarding this Privacy Policy.