Types of Personal Information We Collect
How Promoji Collects Personal Information
How Promoji Uses Personal Information
When and Why Promoji Discloses Personal Information
Cookies and Related Technologies
Accessing and Correcting Personal Information
Security of Personal Information
Notice to Residents of Countries outside Indonesia
Privacy Practices of Third Parties
Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. We collect the following types of Personal Information:
Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of Promoji.
Relationship Information that helps us to understand who you are and what types of stores, products, and advertisements you might like. This includes lifestyle, preference, and interest information; geographic information such as your state/province, city, or neighborhood; the types of promos that interest you; information collected from social media interactions (such as via Facebook Connect); and demographic information (e.g., birth date, age, gender).
Transaction Information about how you interact with the Services, such as the promos you view and redeem and the stores you prefer; other information about how you use our Services, email, other communications, and applications; and how you interact with Promoji's merchants, business partners, and service providers.
Location Information that allows us to periodically determine your geolocation, such as your location relative to nearby merchants or your presence within a mall or store (e.g., near a checkout, aisle, or entrance). Please see the Your Choices section under the heading "mobile" for information on how to limit the Location Information that Promoji may collect from the Services operating on a mobile device.
Analytics Information about your use of our Services, such as your IP address, access time, device ID or other unique identifier (e.g., Android advertising ID), domain name, screen views, language information, device name and model, operating system type, and your activities on our Services. For example, information collection by our Services via a mobile device may include the following: (i) the names of the other applications on your mobile device and, if you use an Android-based mobile device, how you use them (e.g., frequency and duration of use); (ii) if you use an Android-based mobile device, the URL addresses of the webpages you access; (iii) information about your mobile device (e.g., make, model, operating system, and other similar information, but not phone number); (iv) information about your use of features, functions, or clicks on notifications or content; and (v) the strength of signal, temperature, battery level, and unique identifier of a nearby Bluetooth® proximity beacon.
We may ask you for Personal Information when you register, subscribe, create an account, using our app or otherwise interact with the Services or contact Promoji. For example, you may be required to provide us with Contact Information or Relationship Information in order to register for certain services.
We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.
If you use a social media platform, a mobile device or other third-party method of communication to interact with Promoji or the Services, that platform may have a specific privacy statement that governs the use of Personal Information related to that platform. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
If you use the Services on a mobile device and your mobile device's settings allow it, we may collect Personal Information from your mobile device. For example, if you have permitted your mobile device to transmit location data, we may collect your geolocation and time of day. In addition, if you have also enabled Bluetooth® functionality on your mobile device, our Services may determine your presence and duration within a location, such as a mall or store, based on the detection of signals from nearby Bluetooth® proximity beacons. Our application may be designed to collect information even if you are not logged into one of the Services. Please see the Your Choices section under the heading "mobile" for more information on how to limit the Location Information that Promoji may collect from the Services operating on a mobile device.
From time to time, we may also supplement Personal Information with information collected from third parties, including demographic information, information about your interests, and similar information that the third parties have collected from other sources (which may include analytics data from third party websites). For example, we may collect information from third parties to enhance other information we have about you, to help us better understand you, and to otherwise enhance the Services.
Promoji uses Personal Information to:
We may share your Personal Information as required or permitted by law as described below:
With affiliated companies (e.g., subsidiaries and other companies owned by or controlled by Promoji) who may only use the Personal Information for the purposes described in Section 3 above;
With our service providers that provide services for us to assist us in carrying out the purposes described in Section 3 above such as sending emails, push notifications, or SMS messages on our behalf and conducting surveys or sweepstakes on our behalf. Promoji, for example, is a service provider that enables certain geo-location features of our mobile-device applications. Consequently, Promoji and its affiliates collect, store, and process, on Promoji’s behalf, certain Location Information and related data on servers in Singapore. Our service providers are bound by law or contract to protect Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them;
Merchants, but only to the extent you have redeemed a promo offered by the merchant, or participated in an offer, contest or other activity sponsored or offered through Promoji on behalf of the merchant;
Promoji business partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with Promoji and its business partners and in which you have elected to participate. For example, if you are referred to Promoji from a business partner's website or through an invitation facilitated by or in conjunction with a Promoji business partner, Promoji may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between Promoji and the business partner, which may allow such business partner to contact you directly and to advertise to you;
To effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Indonesia and other countries where we operate. If Promoji is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on one or more of our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information; or
When you use our Services, we collect certain information by automated or electronic means, using technologies such as cookies, flash local storage objects, pixel tags, web beacons, browser analysis tools, and web server logs. As you use our Services, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information. Additional information on how to opt-out of certain tracking features is set forth in the Your Choices section below.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Services by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers.
For example, when you access our Services, Promoji and our service providers may place cookies on your computers or mobile devices. These cookies may include means for tracking your Transaction Information with a Merchant and may include tracking technology from third-party affiliate-network operators like LinkShare and Commission Junction. Cookies allow us to recognize you when you return, and track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Services. Some cookies contain serial numbers that allow us to connect your activity with the Services with other information we store about you in your profile or as related to your other interactions with the Services.
Some cookies are temporary, whereas others may be configured to last longer. "Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. "Persistent" cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences.
We also use flash local storage objects ("Flash LSOs") to collect and store Transaction Information and Relationship Information in connection with your use of the Services. For example, we use Flash LSOs to store settings, preferences, and usage information which helps us personalize your visits, whether you are accessing the Services via one of our websites or one of our mobile-device applications. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose "Global Storage Settings Panel" and follow the instructions. To see the Flash LSOs currently on your computer, choose "Website Storage Settings Panel" and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.
We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Services, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol ("IP") addresses of the devices you use to interact with the Services. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Services and the website you visit after you leave our Services, if this information is supplied to us by your browser.
Promoji has relationships with third party advertising technology and analytics companies, such as Google Analytics, Adobe, and Adometry, to place advertisements on our behalf onto other websites, and to perform tracking and reporting functions for our Services and our advertisements. These third parties may automatically collect information about your visit to our Services and other websites, your IP address, web log data, information about your operating system, your ISP and the browser you use to visit our Services. We may share with these third parties certain de-identified demographic or other data linked to data you have provided us, as well as your email address in hashed (non-readable) form.
We think that you benefit from a more personalized experience when we know more about you and the kinds of promos you like. However, you can limit the information you provide to Promoji, and you can limit the communications that Promoji sends to you.
You can manage your email preferences by logging into the application and clicking on the "Account Settings" button at More menu. You can also manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may also update your subscription preferences from time to time. If you wish to opt out of receiving offers directly from Promoji merchants or business partners, you can follow the opt-out instructions in the emails that they send you.
Opting Out of Tracking
Currently, our Services do not recognize browser do-not-track signals. However, you may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
As stated above, to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose "Global Storage Settings Panel" and follow the instructions. To see the Flash LSOs currently on your computer, choose "Website Storage Settings Panel" and follow the instructions to review and, if you choose, to delete any specific Flash LSO. Please note that if you disable cookies and/or Flash LSOs, you may be unable to access some customized features of our Services.
If you access any of our Services through a mobile device or mobile browser, you may manage how your Personal Information is shared with Promoji. You may adjust the settings on your mobile device to allow or prevent the sharing of Location Information. For example, you can disable "Location" (or "Location Services" on iOS-based devices) on your mobile device to prevent sharing of Location Information with Promoji or only disable "Bluetooth" to prevent just the sharing of information collected via nearby Bluetooth® proximity beacons. You may also manage how your mobile device or mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your mobile device and mobile browser settings. Please note that if you disable the sharing of Location Information, you may be unable to access some features of our Services that are designed for mobile devices.
Within iOS-based versions of our mobile-device applications, you may also opt-out of sharing your Location Information by toggling off the "Location" option within the "Settings" menu.
You may opt-out of receiving different types of push notifications or alerts by toggling off the "Notifications" options within the "Settings" menu of our mobile-device applications. This feature is available in the most recent versions of our iOS-based and Android-based applications.
Connecting through Social Networks
Keeping Personal Information about you current helps ensure that we offer you the best promos available for merchants and business partners. You can do several things to help keep Personal Information about you current.
If you want to close your account or have other questions or requests, or if you would like to access or request a correction to any other Personal Information we hold regarding you, please Contact Us.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, Contact Us. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Promoji follows generally accepted industry standards to protect the Personal Information that you provide. For example, we regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. No method of transmission over the Internet, or method of electronic storage, is one hundred percent secure, however. For this reason, there is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you have any questions about our security practices, please Contact Us.
Promoji does not intend that any portion of the Services will be accessed or used by children under the age of eighteen, and such use is prohibited. The Services are designed and intended for adults. By using the Services, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Services. We will promptly delete information associated with any account for which we obtain actual knowledge that the registered user associated with the account is not at least eighteen years old.
Effective Date: June 15, 2015