PRIVACY POLICY
This privacy notice for THE PROME PVT LTD (doing business as THE PROME ) ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you: Visit our website at theprome.com, or any website of ours that links to this download and use our mobile application (THEPROME), or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns?
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@theprome.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with
us and the Services, the choices you make, and the products and features you use.
Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information?
We process your information to provide,improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn
more about when and with whom we share your personal information.
How do we keep your information safe?
We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by visiting, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.Want to learn more about what we do with any information we collect? Review the
privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT
FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register
on the Services, express an interest in obtaining information about us or our products
and Services, when you participate in activities on the Services, or otherwise when
you contact us.
Personal Information Provided by You. The personal information that we collect
depends on the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we collect
may include the following:
names
phone numbers
email addresses
mailing addresses
job titles
usernames
passwords
contact preferences
contact or authentication data
billing addresses
debit/credit card numbers
Sensitive Information.
We do not process sensitive information.
Social Media Login Data.
We may provide you with the option to register with us using your existing social media
account details, like your Facebook, Twitter, or other social media account. If you
choose to register in this way, we will collect the information described in the section
called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.
Application Data.
If you use our application(s), we also may collect the following information if you choose
to provide us with access or permission:
Geolocation Information. We may request access or permission to track location-based
information from your mobile device, either continuously or while you are using our
mobile application(s), to provide certain location-based services. If you wish to change
our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from
your mobile device, including your mobile device's camera, microphone, reminders,
social media accounts, storage, calendar, contacts,and other features. If you wish to
change our access or permissions, you may do so in your device's settings.
Push Notifications.
We may request to send you push notifications regarding your account or certain
features of the application(s). If you wish to opt out from receiving these types of
communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and reporting
purposes.
All personal information that you provide to us must be true, complete, and accurate,
and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically when you visit our
Services.
We automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about how
and when you use our Services, and other technical information. This information is
primarily needed to maintain the security and operation of our Services, and for our
internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar
technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic,
usage, and performance information our servers automatically collect when
you access or use our Services and which we record in log files. Depending on
how you interact with us, this log data may include your IP address, device
information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated with your usage, pages
and files viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error reports
(sometimes called 'crash dumps'), and hardware settings).
Location Data. We collect location data such as information about your
device's location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device you use
to access the Services. For example, we may use GPS and other technologies
to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by
refusing access to the information or by disabling your Location setting on your
device. However, if you choose to opt out, you may not be able to use certain
aspects of the Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners,
social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to
you and update our records, we may obtain information about you from other
sources, such as public databases, joint marketing partners, affiliate programs, data
providers, social media platforms, and from other third parties. This information
includes mailing addresses, job titles, email addresses, phone numbers, intent data
(or user behaviour data), Internet Protocol (IP) addresses, social media profiles,
social media URLs, and custom profiles, for purposes of targeted advertising and
event promotion. If you interact with us on a social media platform using your social
media account (e.g. Facebook or Twitter), we receive personal information about you
such as your name, email address, and gender. Any personal information that we
collect from your social media account depends on your social media account's
privacy settings.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on
how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage
user accounts. We may process your information so you can create and log
in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process
your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your
information to respond to your inquiries and solve any potential issues you
might have with the requested service.
To send administrative information to you. We may process your
information to send you details about our products and services, changes to
our terms and policies, and other similar information.
To fulfil and manage your orders. We may process your information to fulfil
and manage your orders, payments, returns, and exchanges made through the
Services.
To enable user-to-user communications. We may process your information
if you choose to use any of our offerings that allow for communication with
another user.
To request feedback. We may process your information when necessary to
request feedback and to contact you about your use of our Services.
To send you marketing and promotional communications. We may
process the personal information you send to us for our marketing purposes, if
this is in accordance with your marketing preferences. You can opt out of our
marketing emails at any time. For more information, see 'WHAT ARE YOUR
PRIVACY RIGHTS?' below.
To deliver targeted advertising to you. We may process your information to
develop and display personalised content and advertising tailored to your
interests, location, and more.
To protect our Services. We may process your information as part of our
efforts to keep our Services safe and secure, including fraud monitoring and
prevention.
To identify usage trends. We may process information about how you use
our Services to better understand how they are being used so we can improve
them.
To determine the effectiveness of our marketing and promotional
campaigns. We may process your information to better understand how to
provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interest. We may process your
information when necessary to save or protect an individual’s vital interest,
such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS
YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary
and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like
with your consent, to comply with laws, to provide you with services to enter into or
fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate
business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information. As
such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission
(i.e. consent) to use your personal information for a specific purpose. You can
withdraw your consent at any time. Learn more about withdrawing your
consent.
Performance of a Contract. We may process your personal information when
we believe it is necessary to fulfil our contractual obligations to you, including
providing our Services or at your request prior to entering into a contract with
you.
Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those
interests do not outweigh your interests and fundamental rights and freedoms.
For example, we may process your personal information for some of the
purposes described in order to:
Send users information about special offers and discounts on our
products and services
Develop and display personalised and relevant advertising content for
our users
Analyse how our Services are used so we can improve them to engage
and retain users
Support our marketing activities Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services so we can improve user
experience
Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with
a law enforcement body or regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence in litigation in which we are
involved.
Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a third party,
such as situations involving potential threats to the safety of any person.
In legal terms, we are generally the 'data controller' under European data protection
laws of the personal information described in this privacy notice, since we determine
the means and/or purposes of the data processing we perform. This privacy notice
does not apply to the personal information we process as a 'data processor' on
behalf of our customers. In those situations, the customer that we provide services to
and with whom we have entered into a data processing agreement is the 'data
controller' responsible for your personal information, and we merely process your
information on their behalf in accordance with your instructions. If you want to know
more about our customers' privacy practices, you should read their privacy policies
and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e.
express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e. implied consent). You
can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to
assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next
of kin
If we have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise
the availability or the accuracy of the information and the collection is
reasonable for purposes related to investigating a breach of an agreement or a
contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or
rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business,
or profession and the collection is consistent with the purposes for which the
information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section
and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing,
or acquisition of all or a portion of our business to another company.
When we use Google Analytics. We may share your information with Google
Analytics to track and analyse the use of the Services. The Google Analytics
Advertising Features that we may use include: Google Analytics Demographics
and Interests Reporting. To opt out of being tracked by Google Analytics
across the Services, visit https://tools.google.com/dlpage/gaoptout. You can
opt out of Google Analytics Advertising Features through Ads Settings and Ad
Settings for mobile apps. Other opt out means include
http://optout.networkadvertising.org/ and
http://www.networkadvertising.org/mobile-choice. For more information on the
privacy practices of Google, please visit the Google Privacy & Terms page.
When we use Google Maps Platform APIs. We may share your information
with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).
We obtain and store on your device ('cache') your location for six (6) months.
You may revoke your consent anytime by contacting us at the contact details
provided at the end of this document.
Other Users. When you share personal information (for example, by posting
comments, contributions, or other content to the Services) or otherwise interact
with public areas of the Services, such personal information may be viewed by
all users and may be publicly made available outside the Services in
perpetuity. If you interact with other users of our Services and register for our
Services through a social network (such as Facebook), your contacts on the
social network will see your name, profile photo, and descriptions of your
activity. Similarly, other users will be able to view descriptions of your activity,
communicate with you within our Services, and view your profile.
Offer Wall. Our application(s) may display a third-party hosted 'offer wall'.
Such an offer wall allows third-party advertisers to offer virtual currency, gifts,
or other items to users in return for the acceptance and completion of an
advertisement offer. Such an offer wall may appear in our application(s) and be
displayed to you based on certain data, such as your geographic area or
demographic information. When you click on an offer wall, you will be brought
to an external website belonging to other persons and will leave our
application(s). A unique identifier, such as your user ID, will be shared with the
offer wall provider in order to prevent fraud and properly credit your account
with the relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with
third parties that we may link to or who advertise on our Services, but are not
affiliated with, our Services.
The Services, including our offer wall, may link to third-party websites, online
services, or mobile applications and/or contain advertisements from third parties that
are not affiliated with us and which may link to other websites, services, or
applications. Accordingly, we do not make any guarantee regarding any such third
parties, and we will not be liable for any loss or damage caused by the use of such
third-party websites, services, or applications. The inclusion of a link towards a third-
party website, service, or application does not imply an endorsement by us. We
cannot guarantee the safety and privacy of data you provide to any third parties. Any
data collected by third parties is not covered by this privacy notice. We are not
responsible for the content or privacy and security practices and policies of any third
parties, including other websites, services, or applications that may be linked to or
from the Services. You should review the policies of such third parties and contact
them directly to respond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store
your information.
We may use cookies and similar tracking technologies (like web beacons and pixels)
to access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie Notice.
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a social media
account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social
media account details (like your Facebook or Twitter logins). Where you choose to do
this, we will receive certain profile information about you from your social media
provider. The profile information we receive may vary depending on the social media
provider concerned, but will often include your name, email address, friends list, and
profile picture, as well as other information you choose to make public on such a
social media platform.
We will use the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for, other uses of your
personal information by your third-party social media provider. We recommend that
you review their privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on their sites
and apps.
8. IS YOUR INFORMATION TRANSFERRED
INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other
than your own.
Our servers are located in. If you are accessing our Services from outside, please be
aware that your information may be transferred to, stored, and processed by us in
our facilities and by those third parties with whom we may share your personal
information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?' above), in and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or
Switzerland, then these countries may not necessarily have data protection laws or
other similar laws as comprehensive as those in your country. However, we will take
all necessary measures to protect your personal information in accordance with this
privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by
using the European Commission's Standard Contractual Clauses for transfers of
personal information between our group companies and between us and our third-
party providers. These clauses require all recipients to protect all personal
information that they process originating from the EEA or UK in accordance with
European data protection laws and regulations. Our Standard Contractual Clauses
can be provided upon request. We have implemented similar appropriate safeguards
with our third-party service providers and partners and further details can be provided
upon request.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfil the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements). No purpose
in this notice will require us keeping your personal information for longer than the
period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information. Although
we will do our best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United
Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater
access to and control over your personal information. You may review, change, or
terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain
rights under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal information; (iv)
if applicable, to data portability; and (v) not to be subject to automated decision-
making. In certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by contacting
us by using the contact details provided in the section 'HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data
protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your Member State
data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your
personal information, which may be express and/or implied consent depending on
the applicable law, you have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the contact details
provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'
below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the processing of your
personal information conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, or by contacting us using the details
provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?'
below. You will then be removed from the marketing lists. However, we may still
communicate with you — for example, to send you service-related messages that are
necessary for the administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your
account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our legal terms and/or comply with applicable legal
requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies
by default. If you prefer, you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our Services. You may also opt out of
interest-based advertising by advertisers on our Services.
If you have questions or comments about your privacy rights, you may email us at info@theprome.com.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ('DNT') feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognising and
implementing DNT signals has been finalised. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia,
you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve
(12) months:
Contact details, such as real name, alias,postal address, telephone or mobile
A. Identifiers contact number, unique personal identifier, NO
online identifier, Internet Protocol address,
email address, and account name
B. Personal information as Name, contact information, education,
defined in the California employment,
employment history, and NO
Customer Records statute financial information
C. Protected classification characteristics under state Gender and date of
Birth or federal law Transaction information, purchase history, NO
D. Commercial information financial details, and payment informatio NO
E. Biometric information Fingerprints and voiceprints NO
Browsing history, search history, online
F. Internet or other similar behaviour, interest data, and interactions NO
network activity
with our and other websites, applications,
systems, and advertisements
G. Geolocation data Device location NO
H. Audio, electronic, visual, Images and audio, video or call recordings
thermal, olfactory, or similar created in connection with our business NO
information activities Business contact details in order to
I. Professional or provide you our Services at a business
employment-related level or job title,
work history, and NO
information
professional qualifications if you apply for
a job with us
J. Education Information Student records and directory information NO
Inferences drawn from any of the collected
K. Inferences drawn from personal information listed above to create
collected personal a profile or summary
about, for example, YES
information an individual’s preferences and
characteristics
L. Sensitive personal Information
We will use and retain the collected personal information as
needed to provide the Services or for:
Category K - As long as the user has an account with us
We may also collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in the
context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, 'HOW DO WE
PROCESS YOUR INFORMATION?'
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Learn more about how we
disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?'
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This
is not considered to be 'selling' of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We will not sell
or share personal information in the future belonging to website visitors, users, and
other consumers.
California Residents
California Civil Code Section 1798.83, also known as the 'Shine The Light' law
permits our users who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information (if any)
we disclosed to third parties for direct marketing purposes and the names and
addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact
information provided below.
If you are under 18 years of age, reside in California, and have a registered account
with the Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact us
using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We will
make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g. backups, etc.).
CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer
Privacy Act (CCPA), you have the rights listed below.
The California Code of Regulations defines a 'residents' as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as 'non-residents'.
If this definition of 'resident' applies to you, we must adhere to certain rights and
obligations regarding your personal information.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a
business purpose;
the categories of third parties to whom the personal information was sold,
shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal
information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to re-
identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g. phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if we cannot
verify your identity from the information already maintained by us, we may request
that you provide additional information for the purposes of verifying your identity and
for security or fraud-prevention purposes. We will delete such additionally provided
information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
You can designate an authorised agent to make a request under the CCPA on
your behalf. We may deny a request from an authorised agent that does not
submit proof that they have been validly authorised to act on your behalf in
accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal
information to third parties. Upon receiving an opt-out request, we will act upon
the request as soon as feasibly possible, but no later than fifteen (15) days
from the date of the request submission.
To exercise these rights, you can contact us by visiting __________, by email at
info@theprome.com, or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your data, we would like to
hear from you.
Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act
(CPA), you have the rights listed below. However, these rights are not absolute, and
in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ('profiling')
To submit a request to exercise these rights described above, please email
info@theprome.com or visit __________.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at info@theprome.com. Within forty-five (45) days of
receipt of an appeal, we will inform you in writing of any action taken or not taken in
response to the appeal, including a written explanation of the reasons for the
decisions.
Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data
Privacy Act (CTDPA), you have the rights listed below. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ('profiling')
To submit a request to exercise these rights described above, please email
info@theprome.com or visit __________.
If we decline to take action regarding your request and you wish to appeal our
decision, please email us at info@theprome.com. Within sixty (60) days of receipt of
an appeal, we will inform you in writing of any action taken or not taken in response
to the appeal, including a written explanation of the reasons for the decisions.
Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act
(UCPA), you have the rights listed below. However, these rights are not absolute, and
in certain cases, we may decline your request as permitted by law.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising or the sale of personal data
To submit a request to exercise these rights described above, please email
info@theprome.com or visit __________.
Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):
'Consumer' means a natural person who is a resident of the Commonwealth acting
only in an individual or household context. It does not include a natural person acting
in a commercial or employment context.
'Personal data' means any information that is linked or reasonably linkable to an
identified or identifiable natural person. 'Personal data' does not include de-identified
data or publicly available information.
'Sale of personal data' means the exchange of personal data for monetary
consideration.
If this definition of 'consumer' applies to you, we must adhere to certain rights and
obligations regarding your personal data.
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance of decisions
that produce legal or similarly significant effects ('profiling')
Exercise your rights provided under the Virginia VCDPA
You may contact us by email at info@theprome.com or visit __________.
If you are using an authorised agent to exercise your rights, we may deny a request if
the authorised agent does not submit proof that they have been validly authorised to
act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to
verify you and your consumer's request. If you submit the request through an
authorised agent, we may need to collect additional information to verify your identity
before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be extended once by
forty-five (45) additional days when reasonably necessary. We will inform you of any
such extension within the initial 45-day response period, together with the reason for
the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision
and reasoning behind it. If you wish to appeal our decision, please email us at
info@theprome.com. Within sixty (60) days of receipt of an appeal, we will inform you
in writing of any action taken or not taken in response to the appeal, including a
written explanation of the reasons for the decisions. If your appeal is denied, you may
contact the Attorney General to submit a complaint.
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020
(Privacy Act).
This privacy notice satisfies the notice requirements defined in both Privacy Acts, in
particular: what personal information we collect from you, from which sources, for
which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their
applicable purpose, it may affect our ability to provide our services, in particular:
offer you the products or services that you want
respond to or help with your requests
manage your account with us
confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?'
If you believe we are unlawfully processing your personal information, you have the
right to submit a complaint about a breach of the Australian Privacy Principles to the
Office of the Australian Information Commissioner and a breach of New Zealand's
Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?'
If you are unsatisfied with the manner in which we address any complaint with regard
to our processing of personal information, you can contact the office of the regulator,
the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form
5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
15. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated 'Revised' date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
info@theprome.com or contact us by post at:
THE PROME PVT LTD
128, City Road,
LONDON, LONDON EC1V 2NX
United Kingdom
If you are a resident in the European Economic Area or Switzerland, we are the 'data
controller' of your personal information. We have appointed SAJID HANIF to be our
representative in the EEA and Switzerland. You can contact them directly regarding
our processing of your information, by email at info@theprome.com,
or by post to:
If you are a resident in the United Kingdom, we are the 'data controller' of your
personal information. We have appointed Sajid Hanif to be our representative in the
UK. You can contact them directly regarding our processing of your information, by
email at info@theprome.com, or by post to:
128, City Road,
London EC1V 2NX
England
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE
DATA WE COLLECT FROM YOU?
Privacy PolicyYou have the right to request access to the personal information we collect from you,Terms Of Use Disclaimer Cookie Policy Support Limit the use of my sensitive personal information
Do not sell or share my personal informationchange that information, or delete it. To request to review, update, or delete yourConsent Preferences
personal information, please visit our Terms and Conditions Page.
