Privacy Policy

This Privacy Policy explains how Promoji ("Promoji", "us", "our", and "we"), collects and uses information when you interact with us. This Privacy Policy applies to all users of Promoji's website published at www.promoji.co (and any other websites with "Promoji" branding that link to this Privacy Policy, including, without limitation, m.promoji.co) and any mobile-device applications we offer, such our iOS and Android applications, that are branded "Promoji" and link or reference this Privacy Policy (collectively, the "Services").

Please read this Privacy Policy carefully. This Privacy Policy replaces and supersedes the last version of this Privacy Policy for all users (including for those users that registered prior to the Effective Date). If you do not agree to our practices, please do not register, subscribe, create an account, or otherwise interact with the Services. Your use of the Services is also subject to our Terms of Use.

Our Privacy Policy is organized as follows:
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
Your Choices
Accessing and Correcting Personal Information
Security of Personal Information
Notice to Residents of Countries outside Indonesia
Privacy Practices of Third Parties
Changes to this Privacy Policy
Children's Privacy

1. Types of Personal Information We Collect

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.

2. How Promoji Collects Personal Information

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 collect Transaction Information when you use our Services. For example, we may track the promos you view, submit or redeem, and the comments you make to the forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or through the Services from time to time (collectively, "Communities"), or to those related to our social media pages or accounts. We use cookies and related technologies to collect information about your computer and your interaction with the Services and our business partner websites. You can read more about cookies and other technologies in the Cookies and Related Technologies section.

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.

3. How Promoji Uses Personal Information

Promoji uses Personal Information to:

  1. Operate and improve our Services;
  2. Provide users with advertisements for products and services from merchants, including promos based on variables such as stated and anticipated user interests, personal characteristics, and location;
  3. Evaluate eligibility of users for certain promos, products or services;
  4. Evaluate the types of promos, products or services that may be of interest to users;
  5. Track redemption of promos and perform other analytics;
  6. Provide user support, including to merchants or business partners;
  7. Fulfill requests for Promoji services;
  8. Communicate and provide additional information that may be of interest to you about Promoji and featured merchants and business partners, such as Promoji news, special offers and promos, announcements, and marketing materials;
  9. Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
  10. Provide commercial notifications when you arrive at, linger near or leave places;
  11. Infer the location of the places you visit most often, determine your frequency at these locations, and send notifications when you arrive at or leave those places;
  12. Provide advertisements to you through the Services, third-party sites, email messages, text messages, mobile-push notifications, or other methods of communication;
  13. Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
  14. Create user profiles that may contain inferences about users such as age range, income range, gender, and interests;
  15. Manage our everyday business needs such as website administration, forum management, analytics, fraud prevention, Terms of Use or to comply with the law;
  16. Allow you to apply for a job, post a video or sign up for special offers from third parties through the Services; and
  17. Carry out other purposes that are disclosed to you and to which you consent.

4. When and Why Promoji Discloses Personal Information

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

Otherwise with your consent. We encourage Promoji merchants and business partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control. When you choose to interact with a Promoji merchant or business partner, we encourage you to read any privacy policy they may have posted on their website. We may also disclose information about you that is not personally identifiable. For example, we may provide merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.

5. Cookies and Related Technologies

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.

In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about users to optimize our Services and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.

Additionally, if you have visited one of our mobile websites or activated one of our mobile-device applications, and if the settings on your location-aware device allow us to receive Location Information, we will collect that automatically. If we associate Location Information with other Personal Information, this Privacy Policy governs how we would use that information too.

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.

The third parties collect information using cookies, clear gifs and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Services and the other websites tracked by these third parties. This Privacy Policy does not cover the collection methods or use of the information collected by these third parties, and Promoji is not responsible for cookies or clear gifs in third party ads. We encourage you to review the privacy policies or statements of these third party advertising companies to learn more about their use of cookies and other technologies.

6. Your Choices

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.

Email

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.

Mobile

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

You may manage the sharing of certain Personal Information when you register with us through a social media platform or application, such as through Facebook Connect. Please refer to the privacy settings of the social media platform or application to determine how you may adjust our permissions and manage the interactivity between Promoji and your social media account. By registering with Promoji through a social media platform, you grant Promoji permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network's terms of use and this Privacy Policy.

7. Accessing and Correcting Personal Information

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.

8. Security of Personal Information

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.

9. Notice to Residents of Countries outside Indonesia

Promoji is headquartered in Jakarta, Indonesia. Personal Information may be accessed by us or transferred to us in Indonesia or to our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with Personal Information, you consent to such access and transfers. You also acknowledge and agree that Personal Information may be subject to access requests from governments, courts, law enforcement officials, and national security authorities in Indonesia in accordance with Law of Indonesia. We will protect the privacy and security of Personal Information according to our Privacy Policy, regardless of where it is processed or stored.

10. Privacy Practices of Third Parties

This Privacy Policy only addresses the use and disclosure of information by Promoji through your interaction with the Services. Other websites that may be accessible through links from our Services may have their own privacy statements and personal information collection, use, and disclosure practices. Merchants and business partners may have their own privacy statements, too. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of an offer or promotion.

11. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features to our Services. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Services prior to the change becoming effective. Your continued access or use of the Services after any such changes become effective constitutes your acceptance of the Privacy Policy as revised. We encourage you to periodically review this page for the latest information about our privacy practices.

12. Children's Privacy

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