Privacy Policy

Last Updated:  March  12, 2023

Promowise LLC, an Illinois limited liability company, doing business as TopicPro, and its subsidiaries, divisions, and affiliates ("Promowise," "our," "we," or "us") take your privacy very seriously. Accordingly, this Privacy Policy (the "Policy") describes how Promowise collects the personal information you provide by engaging our services on our websites promowise.com and topicpro.com (the "Sites"), social media, email exchanges, mobile apps, and other online services on which this Policy is posted (collectively, the "Service").

Your use of the Service is conditioned upon your agreement with this Policy and our Terms of Service. Before using our Service, please read this Policy carefully as it contains important information on who we are and how and why we collect, store, use, and share your personal information. This Policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

By using the Service, you acknowledge and accept that you have read and understand our Policy and Terms of Service and that you agree to be bound by them. If you do not agree with any part of this Policy or our Terms of Service, then you may not use the Service.

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

1. CHILDREN'S PRIVACY

The Service is not meant for individuals under the age of eighteen, and the Service may use mechanisms to prevent the registration and use of the Service by such underage individuals. Promowise will never knowingly request or collect personal information from any child. If you are under eighteen years old, please do not provide your information on our Service. Upon notification that a child has provided us with personally identifiable information, we will delete the child's personally identifiable information from our records. If you believe we might have any information from a child, please contact us.

2. COLLECTION OF PERSONAL INFORMATION

Information you provide to us

Promowise will collect personal information from you directly when you interact with our Service, create or modify your account, request customer support, or otherwise communicate with us.

Information we obtain indirectly

We may receive personal information about you from our third-party affiliates or partners and from marketing companies that provide us with such information as a part of their relationship with us, and we may combine this information with information that we have already collected about you.

For example, if you engage with a third-party site application whose API we use (e.g., Salesforce) or who uses our API, we may receive information about you or your connections from such site or application. Likewise, if you are referred to us by one of our referral partners, we receive information about you from such referral partner.

Information collected automatically

When you use our Service, we collect certain information about you automatically through our use of cookies and similar technologies. This information may include your IP address, device and browser type, operating system, referring URLs, access times, pages visited, links clicked, and other browsing activities. This data helps us understand how users interact with our Service and enables us to improve the user experience.

To learn more about how we use cookies and other tracking technologies, please refer to our Cookie Policy, which is available on our website.

3. CATEGORIES OF PERSONAL INFORMATION AND PURPOSE FOR COLLECTION

Promowise collects the following categories of personal information: (1) contact information, including your name, postal address, email address, telephone number, company name, and title; (2) authentication information, including your username, password, and other registration information; (3) financial information for payment processing services; (4) transaction-related information, such as when you use web applications from us, register for the Service, or contact us for help; (5) personal preferences including product preferences, online preferences, and interests; (6) user content, such as comments, reviews, and suggestions; (7) usage information, such as the type of mobile device or computer you use, the system and application software you use, the pages and screens you view and how long you viewed them, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, your traffic data, your logs and other communication data, and metadata and other information associated with other files stored on your device.

Beyond this, unless stated otherwise in a separate agreement, Promowise does not collect sensitive personal information such as your social security, driver’s license, state identification card, or passport number; your account login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your racial or ethnic origin, religious or philosophical beliefs, political opinions, or trade union membership; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; your genetic data; your biometric information for the purpose of uniquely identifying you; and personal information collected and analyzed concerning your health or your sex life or sexual orientation. We ask that you not send nor disclose this sensitive personal information to us.

Promowise only collects and processes the minimum amount of personal information from you that is necessary to the purposes of our information processing activities and retains such information only if required to fulfill such purposes.

Promowise does not trade, rent, or sell your personal information to third parties or share your personal information with third parties for cross-context behavioral advertising.

Most often, the reason we process your information is to perform the contract that you have with us or to take steps at your request before entering into a contract. For example, we use your information to maintain your account. We also use your information for our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. For example, we analyze users’ behavior to continuously improve the Service and for administrative, fraud detection, and legal purposes. Finally, from time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us using the information provided below.

The table below explains what we use or process your personal information for, our processing operations, our reasons for processing, and the relevant categories of personal information that we process:

What we use your personal information for	Processing operations	Our reasons for processing	Relevant categories of personal information
To conduct our business, such as by providing B2B Content Syndication Services, setting up and maintaining your registration with the Service	Creating and managing user accounts, providing access to features and functionality, maintaining and improving our services, promoting client marketing collateral	For the performance of our contract with you or to take steps at your request before entering into a contract	Contact information, authentication information, user content, usage information, client marketing collateral
To generate qualified leads for our clients	Promoting content on our website and across 3rd party websites, converting contacts on landing pages, obtaining consent to share contact information with Promowise and sponsors	For our legitimate interests or those of a third party, i.e., to provide valuable leads for our clients	Contact information, personal preferences, consent records
To send marketing and advertising materials and deliver relevant content to existing and former customers	Creating targeted marketing campaigns, sending promotional materials, and analyzing engagement	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers	Contact information, personal preferences
To communicate with you and provide customer support	Responding to inquiries, resolving issues, and providing updates about our services	For our legitimate interests or those of a third party, i.e., to address your questions and concerns about the Service; For the performance of our contract with you or to take steps at your request before entering into a contract	Contact information, authentication information, user content
User verification	Verifying the identity of users to prevent unauthorized access and maintain security	To comply with our legal and regulatory obligations	Authentication information, usage information
To process payment	Facilitating transactions, processing payments, and managing refunds	For the performance of our contract with you or to take steps at your request before entering into a contract	Financial information, contact information
To customize the Service for you	Personalizing content, tailoring recommendations, and optimizing user experience	For the performance of our contract with you or to take steps at your request before entering into a contract	Personal preferences, usage information
Quality management services to operate, manage, develop, administer, and improve the Service and your experience on the Service	Monitoring and analyzing usage, evaluating performance, and implementing improvements	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you; For the performance of our contract with you or to take steps at your request before entering into a contract	Usage information, user content
To prevent and investigate fraud and other misuses of the Service	Identifying and investigating suspicious activity, enforcing our terms and policies	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you	Contact information, authentication information, usage information
To protect our rights and property	Enforcing legal claims, preserving evidence, and managing disputes	For our legitimate interests or those of a third party, i.e., to be able to enforce, retain, or preserve such rights and property in the event of a dispute	Contact information, authentication information, user content, usage information
To ensure the technical functionality and security of the Service	Maintaining system security, detecting and preventing breaches, and ensuring data integrity	For our legitimate interests or those of a third party, i.e., to preserve the integrity of our confidential or proprietary information; For the performance of our contract with you or to take steps at your request before entering into a contract; To comply with our legal and regulatory obligations (e.g., under Article 32, U.K. GDPR and E.U. GDPR)	Usage information, user content
To analyze trends and gather broad aggregate demographic information, statistically monitor how many people are using the Service or opening our emails, and research our audience	Analyzing usage data, generating reports, and identifying areas for improvement	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price	Usage information, user content, contact information To audit and analyze the Service
Usage information, user content, contact information To audit and analyze the Service	Reviewing and assessing the performance and effectiveness of the Service, ensuring compliance with legal and regulatory obligations	For our legitimate interests or those of a third party, i.e., to demonstrate we operate at certain standards; To comply with our legal and regulatory obligations (e.g., Article 28, U.K. GDPR and E.U. GDPR)	Usage information, user content, contact information

4. DISCLOSURE OF PERSONAL INFORMATION

We share personal information collected via the Service with:

• Our affiliates; 
• Service providers we use to help perform services (e.g., data storage) on our behalf and to deliver such services to you;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts; and
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

The table below lists the specific third party with whom we disclose your information, the processing operations related to such disclosure, and the relevant categories of personal information that we disclose, and have within the preceding twelve months disclosed, for a business purpose:

Recipient	Processing operation (use) by recipient	Relevant categories of personal information transferred to recipient
Data Storage Provider	Providing data storage and backup services	Full name, business email address, job title, country, city, business phone number, custom profiling questions
Marketing Agency	Assisting with marketing and promotional campaigns	Full name, business email address, job title, country, city, business phone number, custom profiling questions
Website Host	Hosting the website and managing user accounts	Full name, business email address, job title, country, city, business phone number, custom profiling questions
Social Media Sites (approved by you)	Linking accounts or sharing content	Full name, business email address, job title, country, city, business phone number, custom profiling questions
Third-party Payment Providers (approved by you)	Processing payments	Full name, business email address, job title, country, city, business phone number, custom profiling questions

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

In addition, Promowise may aggregate information collected through the Service and remove identifiers so that the information is no longer considered personal information and cannot be used to re-identify an individual ("Anonymized Information"). Promowise shares Anonymized Information with third parties, and such parties are not limited in their use of Anonymized Information.

Promowise does not sell any categories of personal information for business purposes.

Promowise may further share personal information if Promowise is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (in whole or in part). Should such an event occur, all shared personal information shall remain subject to the then-current Privacy Policy, unless and until you agree to new privacy terms, and the recipient of such information will be bound by confidentiality obligations.

Finally, applicable law may require Promowise to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena, or search warrant) or other legal requirements; (ii) disclosure would mitigate Promowise's liability in an actual or threatened lawsuit; (iii) necessary to protect legal rights of Promowise, users, customers, business partners, or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).

5. DO NOT TRACK SIGNALS, COOKIES, AND OTHER TECHNOLOGIES

We may use cookies, pixel tabs, web beacons, flash cookies, clear GIFs, and similar technology (“Data Collection Technology”) to collect certain information about your online activity and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information that enables Promowise to improve our services and provide you with more relevant content and advertising offered by Promowise, or through or linked from our services.

Data Collection Technology helps us improve your experience of the Service by, for example, storing your password, measuring the success of marketing campaigns, compiling statistics related to the use of the Service, and helping us analyze technical and navigational information about the Service in order to detect and prevent fraud. We may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings, including the language your system uses and the country and time zone in which your computer or device is located. We also use Google Analytics, which is a Google service that collects aggregate information about the use of the Service and reports website trends. Google Analytics does not directly identify individual users. You can learn about Google’s practices and opt out by visiting www.google.com/settings/ads or by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

You may disallow receiving cookies at any time through your web browser. It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service. However, while you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

At this time, Promowise does not respond to browser “do not track” or “DNT” signals.

6. LOCATION OF INFORMATION AND NOTICE TO INTERNATIONAL VISITORS

Promowise is headquartered in the United States, and the Service is controlled and operated from the United States. We process and store personal information in the United States, where privacy laws may not be as protective as in your place of residence. Information may be held at our offices and those of our affiliates, third party agencies, service providers, representatives, and agents as described above, and some of these third parties may also be based outside your place of residence.

Accordingly, if you are using the Service from outside of the United States, by providing your personal information to us, you consent to the transfer of your personal information to the United States for processing consistent with this Policy. If you reside in the European Union or United Kingdom, please see the section in this Policy titled "Special Notice to E.U. and U.K. Residents."

7. SECURITY

If you choose to provide us with your personal information, you understand that we are transferring it to Promowise's locations and systems in the United States. Promowise uses reasonable security measures to protect the loss, misuse, and alteration of the information under its control and takes precautions intended to help protect information that we process. Such measures and precautions may change from time to time, depending on industry standards and perceived security risks. However, despite such security measures and precautions, no system or electronic data transmission is completely secure. Promowise cannot guarantee the security of your information and disclaims liability for loss, misuse, and alteration of your information under its control to the maximum extent permitted under applicable law. By using the Service, you agree to assume any security risk related to personal information.

You are responsible for maintaining the security of your account credentials for the Service. Promowise will treat access to the Service through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Service without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If Promowise becomes aware of a breach that affects the security of your personal information, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Promowise will provide any such notice that we must provide to you at your account’s email address. By using the Service, you agree to accept notice electronically.

8. RETENTION OF PERSONAL INFORMATION

We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to Promowise or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, and for similar essential purposes.

By way of illustration but not limitation, this means we keep your personal information while you have an account with us or while we are providing the Service to you. Thereafter, we will keep your personal information for as long as it is necessary to, for example, respond to any questions, complaints, or claims made by you or on your behalf; show that we treated you fairly; or keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will securely delete or anonymize it in accordance with applicable laws and regulations.

9. LINKS AND THIRD-PARTY WEBSITES

Our Service may contain links to other websites owned and operated by third parties, including without limitation social media websites. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of the information presented on or in such third-party website or service. When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect personal data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information by third parties through the linked sites. Promowise is not responsible for the privacy practices or the content of such other websites. Promowise expressly disclaims any liability that may arise from your use or provision of any of your information whatsoever to third-party websites. You understand and agree that by clicking on a link to another site or service that you have left our Service.

10. USER CONTENT

Some features of the Service may now or in the future allow you to provide content, such as written comments or reviews, to be published or displayed on public areas of the Service ("User Content"). Be careful about giving out information in public areas of the Service. The information you share in public areas may be viewed by any user of the Service. We cannot control the actions of other users of the Service with whom you may choose to share your User Content. Promowise is not responsible for any unauthorized use of your User Content by other users or third parties.

11. PROMOTIONAL COMMUNICATIONS AND OPTING OUT OF CERTAIN EMAILS

We may use your personal information to send you promotional communications when you provide your contact details to us to purchase our products or services. You may object to and "opt out" of receiving future communications from us for these direct marketing purposes at any time by indicating that you decline such communications. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these emails or contacting us at support@promowise.com.

12. NOTIFICATION OF PRIVACY POLICY CHANGES

We may update this Policy to reflect changes to our information practices. 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 a notice on the Service prior to the change becoming effective. Use of information we collect now is subject to the Policy in effect at the time such information is used. You are bound by any changes to our Policy when you use the Service after such changes have been first posted. We encourage you to periodically review this policy for the latest information on our privacy practices.

13. SPECIAL NOTICE TO CALIFORNIA RESIDENTS

If you would like to submit a Consumer Request, you can contact Promowise at privacy@promowise.com or  708-402-8378. If you choose to submit a Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. Promowise will only use the information it receives to respond to your request. Promowise will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person's behalf.

"Personal information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. "Personal information" does not include publicly available information.

1. Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.

2. Request to Access. You may submit a Consumer Request to obtain a copy of or access to the personal information that Promowise has collected on you.

3. Request to Know. You may submit a Consumer Request to receive information about Promowise's data collection practices.

• • Right to Know what Personal Information is being Collected. You may request information on the categories of personal information Promowise has collected about you; the categories of sources from which the personal information is collected; Promowise's business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom Promowise discloses personal information, if any; and the specific pieces of personal information it has collected about you.
  • Right to Know what Personal Information is Sold or Shared and to Whom. You may also request the categories of personal information that Promowise has collected about you; the categories of personal information that Promowise sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and the categories of personal information that Promowise disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy. Additionally, Promowise is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Promowise is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

4. Request to Delete. You may request that Promowise delete personal information it has collected from you. Subject to certain exceptions set out below, we will, on receipt of a verifiable Consumer Request, delete your personal information from our records, direct any service providers to do the same, and notify all third parties to whom Promowise has shared your personal information to delete it unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business' ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business' deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business and compatible with the context in which the consumer provided the information.
• Comply with a legal obligation.