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Privacy and Data Protection Policy

In this privacy notice we explain how we collect and use your personal data. This privacy notice applies to all personal data we process about you when you order, purchase or use our products and services, visit our websites, use our customer support or otherwise interact with Promo2u Ltd. 

We respect privacy and acknowledge that processing personal data in a lawful and proper manner is an important social responsibility. We declare that we will strive to protect personal data. This privacy notice applies to all personal data that we process concerning our prospective, current and former customers and suppliers, and your usage of our products and services, our website at promo2u.com, or otherwise when you conduct business with Promo2u Limited (hereafter "you"). In this privacy notice, we explain which personal data we collect and how we use these data. We encourage you to read this notice carefully. 

1. Who we are
2. Personal data we collect and what we do with your data
3. How we collect your data
4. Information sharing
5. Security measures and data retention
6. International transfers of personal data
7. Your rights
8. How we look after this policy
9. Contact details for your privacy inquiries

1. Who we are

We are Promo2u Limited, 1^st Floor, 4 Kings Road, London E4 7EY, United Kingdom. We are responsible for the collection and use of your personal data, as described in this privacy notice. References to "Promo2u", "we" and "our" throughout this notice, depending on the context. You can contact Promo2u Ltd using the contact details in Section 9 if you have any privacy questions or would like to exercise your rights as a data subject.

2. Personal data we collect and what we do with your data

We have outlined our data processing operations and the purposes for which we process your personal data in the Appendix: Overview Promo2u Ltd Customer & supplier processing activities. In summary, we use various systems to deliver products and services to you. For example, we provide promotional products and corresponding print services. Legal basis Promo2u processes your personal data to provide our products and services to you, to comply with legal obligations we are subject to, if it is necessary for our legitimate interests or the interests of a third party or on the basis of your consent. 

When we process your personal data for our legitimate interests or the interests of a third party, we will take reasonable measures to prevent unwarranted harm to you. Our legitimate interests may for example include our interest in improving our product and services delivery by storing contact details, reducing our costs, improving our newsletters and websites by analysing which parts of our communications are most relevant for you. Also we do so to provide our services and facilities, such as the purposes mentioned in the Appendix. In specific cases we may process your personal data with your consent. More information on the balancing tests we perform is available upon request. Where we process your personal data for our legitimate interests or the interests of a third party, you have the right to object to our processing at any time on grounds relating to your particular situation (please see Section 7. Your rights below).

You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your setting (if available) or by reaching us through the contact details in Section 9. Contact details for your privacy inquiries below. Where we process your personal data for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data were initially collected. More information on this assessment is available upon request (please see Section 7. Your rights below).

3. How we collect your data

Most of the personal data we process is information that you knowingly provide to us directly or through third parties. However, in some instances, we process personal data that we are able to infer about you based on other information you provide to us or on our interactions with you, or personal data about you that we receive from a group company or a third party with your knowledge (please see the Annex below). If you refuse to provide personal data that we require for the performance of a contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us.

4. Information sharing

Promo2u Ltd will process some of your personal data locally. However, as a global organization, many of our business activities can also be carried out (and business efficiencies achieved) by processing or consolidating information about you in specific or centralized databases and systems located at specific secured facilities worldwide. As a result, your information may be shared with other entities within our supply chain. However, each supply partner and those other systems / databases will only collect, receive, use, share or otherwise process such personal data in accordance with applicable laws and this privacy notice. Moreover, internally we maintain a strict access policy with regard to the processing of personal data. Only a limited group of authorized Promo2u staff, on a need to know basis, may have access to your personal data.

As a rule, we do not share your personal data with anyone outside Promo2u. However, we may share your personal data with trusted third parties that perform business functions or provide services to us such as couriers. All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws. Your personal data may also be shared on legal grounds or investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).

5. Security measures and data retention

Promo2u Ltd will secure your personal data in accordance with our IT and security policies so that personal data is protected against unauthorized use, unauthorized access and wrongful modifications, loss or destruction. Your personal data will be stored no longer than is necessary for the purpose they were obtained, including compliance with legal and fiscal obligations and for solving any disputes. We have outlined the specific data retention periods in the Apendix: Overview Promo2u Ltd Customer & supplier processing activities. 

6. International transfers of personal data

Given the global nature of our sourcing, your personal data may be transferred to trusted third parties in countries outside the European Economic Area (‘EEA’) whose laws may not afford the same level of protection of your personal data. Where necessary, Promo2u Ltd will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, Promo2u Ltd may use Commission approved mechanisms, such as the Privacy Shield certification, and Standard Contractual Clauses as safeguards, such as the "(EU-)controller to (Non-EU/EEA-)controller" Decision 2004/915//EC (see Article 46 GDPR). If you wish to receive a copy of these safeguards, please contact us through the contact details in Section 9. Contact details for your privacy inquiries below. The European Commission has determined that certain countries outside the European Union offer an adequate level of data protection (see Article 45 GDPR). You can find an overview of these countries here.

7. Your rights

You can contact us (please see Section 9. Contact details for your privacy inquiries below)to exercise any of the rights you are granted under applicable data protection laws, which includes (1) the right to access your data, (2) to rectify them, (3) to erase them, (4) to restrict the processing of your data, (5) the right to receiving a file of your personal data and (6) or the right to object to the processing, and where we have asked for your consent, to withdraw this consent. These rights will be limited in some situations. We will, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal data in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.
When you would like to exercise your rights, please send your request to the contact details in Section 9. Contact details for your privacy inquiries below. Please note that we may need you to provide additional information to confirm your identity. You also have the right to lodge a complaint with the Information Commissioner’s Office, www.ico.org.uk). You can also contact us info@promo2u.com if you have any questions, remarks or complaints in relation to this privacy notice.

7.1. Right to access

You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned as well as any other information necessary for you to exercise the essence of this right. 

7.2. Right to rectification

You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement. 

7.3. Right to erasure

You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, any other controller to whom your data has previously been disclosed by us. Erasure of your personal data will only take place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data are no longer necessary in relation to the initial purposes for which they were processed, as well as situations where they were processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased. 

7.4. Right to restriction of processing

You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where you have challenged the accuracy of your personal data but some time is needed for us to verify their (in) accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted. 

7.5. Right to receive your file (data portability)

Your right to data portability allows you to request from us your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible we will transmit your personal data directly to the other controller. 

7.6. Right to object

You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in cases where the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing (see par. ‘Legal basis’ above). At any time and free of charge you can object to direct marketing purposes when your personal data are processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. If you exercise this right, we will no longer process your personal data for such purposes.

8. How we look after this policy

We have most recently updated this notice on 20 Dec 2020 and it replaces earlier versions. We will update this privacy notice from time to time and notify you of any changes by posting the revised policy on this website and informing you by email if the changes are substantial.

9. Contact details for your privacy inquiries

Promo2u Limited, 1^st Floor, 4 Kings Road, London E4 7EY

Email info@promo2u.com

Appendix: Overview Promo2u Ltd Customer & supplier processing activities

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