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Privacy Policy

Effective December 1st, 2020

This Privacy Policy applies to information that Promowise LLC, an Illinois limited liability company ("The Pulse Syndicate",“Promowise”, "TopicPro", “our”, “we”, or “us”) collects on promowise.com (the “Services”).

TopicPro has created this Privacy Policy to state our commitment to privacy and to describe how we manage and protect personal information that is collected, used, and disclosed. We collect information pertaining to businesses and business people (“Business Information”) and all other types of information through our website and online services (the “Site”). This privacy policy pertains to the different means of how we collect your information and describes how your personal information is stored and treated.

We may occasionally modify, alter, or update this Privacy Policy. Any changes will be posted here and take effect as they are posted. We encourage you to review this policy occasionally as we will not provide individual notice when changes to this Privacy Policy are made. By continuing to use our Site or Services you are agreeing to the latest Privacy Policy.

Should you have any questions, contact us at privacy@promowise.com.

Our Site and The Information We Collect

The goal of our Site is to provide B2B business professionals with knowledge and community across a variety of topics of interest. Visitors of our Site have the option to browse without revealing personal information, but we may collect information about visitors that download content, or that subscribe to our newsletters, emails, or services (collectively “you”). We collect the information that you give us directly on our Site, that we capture when you visit, and information from third party sources.  The type of information we collect is Business Contact Information, which may include any of the following: Name, Title, Company Name, Business Email Address, Business phone number, Work address, Public professional profile address, and/or supplementary information such as business role and responsibility designations. We may disclose your personal information to our clients that wish to send you relevant marketing communications, and to partners and providers that support our site and services. This portion of the policy does not apply to any website of any third party, even if the third-party website links to/from the Site. By accessing, using, and/or submitting information through the Site, you consent to the practices described in this policy about the information collected thereby as described herein. If you do not agree with this policy, you must delete all cookies from your browser cache after visiting the website and stop from visiting or using the website.

How we use Cookies

Like most commercial websites, we use “cookies” and other technologies to collect non-personally-identifiable information on Site visitors. Cookies allow web servers to recognize the computer used to access a website, they store information accessed through your browser to streamline activities on related web sites, and they make a better and more personalized the online experience. Information gathered through cookies and web-server log files may include information such as the date of visit, time of visit, duration of visit, number of visits, the pages viewed, IP addresses, and links to/from any page. Information collected from Site submissions will be used for TopicPro’s internal business purposes, including its investigations, sales, and marketing. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address. The Site may include options for visitors to submit information through a form, for example, while requesting information about a topic, content, product, service, etc. Such forms may provide the option of submitting personal information, such as your name, job title, company, email address, or phone number. When submitting information on a Website, your submission will be associated with the IP address you are then using, which is automatically assigned to your computer by your Internet Service Provider (ISP). If you are using one of the common browsers and are uncomfortable accepting cookies from our website, you may erase and/or disable the acceptance of cookies in your browsers administrative tools, however, this may result in an incomplete experience of the Site. We also use cookie data to measure site traffic and usage activity for purposes of improving and enhancing the functionality of the Website, to look for possible fraudulent activity, to better understand the sources of traffic and transactions on the Website, and/or to serve targeted advertisements. We take measures to maintain the security of its website visitor information, does not license or sell such information to anyone, and will only share such information with a third party who has agreed to keep such information confidential and maintain the security thereof, and only for the purposes of facilitating one of the uses described herein on behalf of TopicPro. The use of cookies by our partners, affiliates, tracking utility company, or service providers is not covered by this Policy, as we do not have the ability to access or control over these cookies.

How we Collect & Use Information

Visitors of our Site may choose to submit their name, email address and/or other business information so that they can learn more about a topic, product, service, survey, or event, among other things. To take full advantage of our Site, products, and services, you may be required to subscribe or register as a user. Based on your subscription settings, Topic follows, and interaction with the Site, we may use your email address to send you promotional information that keeps you informed of products and services in which you might be interested. With all emails, you will always be provided with an opportunity to opt out.

Customer Information may be used for business needs in connection with your use of the Services, including to respond to user onboarding, inquiries, requests, customer transactions, provide customer service, communicate administrative info, and to personalize the overall user experience. We may use Customer Information to further understand our users in general and to improve the content and functionality of the Services. We may use Customer Information to contact you in the future to inform you about services, promotions, opportunities, and other general information we believe will be of interest to you. We may also use Customer Information to investigate and prosecute potential breaches of TopicPro security or license agreements.

It is important for you to know that we do not sell, distribute, or share your personal information to any third party without your knowledge and consent except to provide products or services in which you have expressly shown an interest, when you have given TopicPro your permission, or under the following circumstances:

  • When working with contracted outsourcing partners that are subject to strict confidentiality agreements and are not extended any independent right to share this information with their partners.
  • Should we have to respond to a legal action, subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims.
  • Should there be a merger or acquisition of the company, information may be transferred, but with full disclosure of this Privacy Policy and the commitments expressed herein.
  • Should we need to investigate, defend, or act regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Data security is of the highest priority for TopicPro. All access and permissions to systems that contains such data work on a need-to-know basis only. TopicPro may occasionally partner with other third-party companies in web-based promotions. However, TopicPro shall not be liable for any personal information submitted to external vendors or to any website linked to this site. TopicPro also recommends that any visitor accessing the Site as an employee of a company, abide by the privacy practices and security guidelines of the corporations they represent.

TopicPro collects information regarding companies and their employees, including Business Contact Information on company executives, decision makers, and other employees. The information collected is like that which is typically included on a business profile, card, or email signature, for example: Name, Title, Company Name, Business Email Address, Business phone number, Work address, Public professional profile address, and/or supplementary information such as business role and responsibility designations. TopicPro organizes and validates this data for purposes of licensing such information to clients and partners for sales and marketing purposes.

TopicPro obtains data for its database from internal research, including phone interviews, Zoom calls, publicly available resources, third-party licensors, etc. All business contact information that TopicPro obtains through any of the foregoing means is verified by our internal technologies, processes, and research, and any information that is found to be inaccurate or irrelevant to the purposes of the Services is removed and deleted.

The TopicPro’s team recognizes that the receipt,

transmission, distribution, or propagation of unwanted emails (Spam) as a major

concern and abide by all anti-Spam legal regulations when emailing information

out from TopicPro. Should you ever wish to have any collected personal

information deleted, edited, or removed, please send an email to

privacy@promowise.com.

EU Residents - General Data Protection Regulation (GDPR) Compliance

TopicPro complies with GDPR regulation by processing data along the GDPR norms. Under GDPR, there are six grounds to process personal data, two of which are relevant to our B2B marketing business: consent and legitimate interest. As Recital 47 of the GDPR states that “The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” Using legitimate interest as the basis for B2B marketing involves ensuring key conditions are met:

  • “The processing must relate to the legitimate interests of your business or a specified third party, providing that the interests or fundamental rights of the data subject do not override the business’ legitimate interest.”
  • “The processing must be necessary to achieve the legitimate interests of the organization.”

In addition to the above GDPR compliance, TopicPro does not share personal data with customers or partners, records all data processing activities, does not collect any sensitive information such as religion, gender, age, etc., and maintains an explicit Opt-in and Opt-out process.

As a ‘data processor’, TopicPro follows the following data privacy requirements and upholds the GDPR law, Articles 13 and 14. TopicPro provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten.

TopicPro informs individuals about the collection and use of their personal data, retention periods for the data, and who it will be shared with. This is a key transparency requirement under the GDPR, provides privacy information to individuals at the time of collecting their personal data. When TopicPro obtains personal data from other sources, we provide individuals with privacy information within a reasonable period of obtaining the data and no later than a month. If any EU resident information is sourced in TopicPro database then TopicPro will provide such individual with a notice detailing the information TopicPro has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information TopicPro possesses on them, to correct such information, or to opt-out of data collection entirely. Such persons may opt-out of the TopicPro database by emailing privacy@promowise.com

Information we provide to people is concise, transparent, intelligible, easily accessible, and in clear and plain language. We conduct regular review, and where necessary, update our privacy information. If there are any new uses of an individual’s personal data, we make sure to bring it to their attention before we start processing.

Disclosures of Public Profiles

We may make available any Business Information that our users contribute, that we collect from public web sources, or that we license from third parties to users of the Site or to our strategic partners/customers.

Disclosures to Service Providers

TopicPro may disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose.  

Disclosures for Legal Reasons

We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of TopicPro, its users or the public, or (iv) to allow TopicPro to exercise its legal rights or respond to a legal claim.

Disclosures to a Buyer of the Company

If our company or substantially all our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to TopicPro may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

 

Other Disclosures

If you register for an event through one of TopicPro’s products or services, or with a third-party speaker, your information may be shared with the speaker.

Canadian Residents - Canadian Anti-Spam Policy (CASL) Compliance

TopicPro is committed to compliance with the CASL an anti-spam law that applies to all electronic messages (for example: email, texts, etc.) that organizations send in connection with “commercial activity.” The important CASL requirement is for Canadian and global organizations that send commercial electronic messages (CEMs) within, from or to Canada, to receive consent from recipients before sending messages, but that the CASL does not apply to CEMs that are simply routed through Canada.

A CEM is an electronic message that encourages participation in a commercial activity, such as purchasing a product or service. We ensure our internal policies and procedures prevent our customers and other consumers do not encounter spam, and that all CEMs are CASL compliant.

TopicPro only sends CEMs in the following contexts:

  • You have explicitly opt-ed in to receiving messages through our subscription/signup process;
  • You have provided your e-mail address to us, or have published your e-mail address, without placing any use restrictions, and the CEM is relevant to your business role;
  • You have an existing relationship with a third party who has referred us to you;
  • You have an existing business or non-business relationship with us;
  • To communicate with you about your account, subscription, or similar relationship with us;
  • To provide information about products or services that you have requested from us;
  • To respond to a request for information that you submitted;
  • To fulfill a legal obligation or right.

TopicPro protects you from spam by ensuring that CEMs sent from TopicPro do not:

  • Use or contain invalid or forged headers or non-existent domain names;
  • Employ any technique to otherwise misrepresent or obscure the sender of the message, the point of origin, or the transmission path for the message;
  • Contain false or misleading information in the subject line or otherwise contain false or misleading content;
  • Use a third party’s Internet domain name, or relay from or through a third party’s equipment, without permission of the third party; or
  • Attempt to surprise or confuse you. All CEM’s are verified for relevance to your job title and/or industry.

TopicPro does not knowingly do business with any company that participates in sending spam. TopicPro will not directly provide or exchange your email address information with any other organization.

I no longer want to receive communications

TopicPro’s CEMs provide you with the ability to unsubscribe or opt-out of receiving our CEMs. When you unsubscribe using the links provided in our CEMs, your request will be processed as soon as possible, and no later than 10 business days after you send the unsubscribe request. There are only limited contexts in which you cannot request that TopicPro stop sending you messages, such as when we must communicate with you to enforce TopicPro’s legal rights.

I received a CEM that may violate this policy

If you receive any messages from TopicPro that may be considered spam, email us at privacy@promowise.com and the matter will be investigated. All TopicPro employees are aware of this Anti-Spam Policy, are appropriately trained, and are required to ensure that CEMs receive appropriate approval from the Compliance Officer before being sent to any of our lists.

Appropriate disciplinary action will be taken if this procedure is not followed, not limited to the loss of employment.

Contact Us

We are committed to ensuring that you do not receive unwanted e-mails from us. Should you have any questions about TopicPro’s spam-management processes, contact us at privacy@promowise.com.

California Residents - California Consumer Protection Act (CCPA) Compliance

The CCPA applies to any business, including any for-profit entity that collects consumers’ personal data, which does business in California, and satisfies at least one of the following thresholds:

  • Has annual gross revenues in excess of $25 million;
  • Buys or sells the personal information of 50,000 or more consumers or households; or
  • Earns more than half of its annual revenue from selling consumers’ personal information.

Organizations are required to “implement and maintain reasonable security procedures and practices” in protecting consumer data. TopicPro is compliant with the CCPA by processing data in accordance with the following CCPA norms:

A. Under CCPA the following are the rights of the consumers:

  1. Right to Deletion
  2. The consumer shall have a right to opt for deletion of any unnecessary data as he may deem fit is available with TopicPro. Such Consumer shall send a request to TopicPro for the same mentioning the specific data to be deleted from the database.

2. Right to Opt-out

  • The consumer shall have the right to opt-out or request for deletion of all personal information collected. You may adjust your email subscription settings or email “Opt-out” to privacy@promowise.com.

3. Right to Access and Data Portability

  • The consumer shall have a right to access data used and processed by TopicPro for its business including:
    1. Information Collected
    2. Sources of Collection of Information
    3. Purpose of the Collection of Information
    4. Disclosure of information collected with any other third party.

TopicPro shall disclose the information collected and used upon receipt of a consumer’s verifiable consumer request, by the consumer.

TopicPro informs individuals about the collection and use of their personal data, data retention periods, and who it is shared with. This is an important transparency requirement under the CCPA that provides privacy information to individuals at the time of collecting their personal data.

In addition to the above CCPA compliance, TopicPro does not share personal data with customers or partners, records all data processing activities, does not collect any sensitive information such as religion, gender, age, etc., and maintains an explicit Opt-in and Opt-out process.

4. Privacy Notice

When TopicPro obtains personal data from other sources, we provide individuals with privacy information within a reasonable period of obtaining the data, no later than a month. In the even that information about a US resident is collected in a TopicPro database, then TopicPro will provide such individual with a notice detailing the information TopicPro has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information TopicPro possesses on them, to correct such information, or to opt out of data collection completely.

The Information we provide to people is concise, transparent, intelligible, easily accessible, and in clear and plain language. We conduct regular reviews and update our privacy information when needed. If there are any new uses of an individual’s personal data, we make sure to bring it to their attention before we start processing.

5. Right to opt out

A consumer shall have the right to opt-out of the sale of that consumer’s personal information by submitting a request to remove the consumer’s profile, delete the consumer’s data, or opt-out of the TopicPro database by emailing privacy@promowise.com. If the Consumer decides to opt out, he/she shall be eligible for the same prices and services which are offered to other consumers.

 

B. Disclosures by TopicPro (last twelve months)

1. Disclosures of Public Profiles

  • We may make available any Business Information that our users contribute, that we collect from public web sources, or that we license from third parties, to users of the Site or to our strategic partners/customers.

2. Disclosures to Service Providers

  • TopicPro may disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose.

3. Disclosures to a Buyer of the Company

  • If our company or substantially all our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to TopicPro may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

C. Verifiable Consumer Request

Any consumer that is interested in exercising his/her CCPA rights, shall submit a verifiable consumer request to privacy@promowise.com, and TopicPro shall respond within 45 days of the receipt of the request.

 

D. Changes to this Privacy Policy

We may occasionally modify, alter, or update this Privacy Policy. Any changes will be posted here and take effect as they are posted. We encourage you to review this policy occasionally as we will not provide individual notice when changes to this Privacy Policy are made. By continuing to use our Site or Services you are agreeing to the latest Privacy Policy.

 

E. Contact us

Contact us at privacy@promowise.com should you have any questions or requests.