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Privacy Policy

Introduction

Promoto Inc., including Promoto Software Pvt. Ltd., with the trade name “CustomerSuccessBox” (collectively, ‘CustomerSuccessBox’ or ‘we’ or ‘us’ or ‘our’), gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection regulation and laws. This notice provides you (referring website visitor and Subscribers/Customers to our SaaS offering collectively) with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.

Promoto Inc., with trade name “CustomerSuccessBox”, registered office is at 2035 Sunset Lake Road, Suite B-2, Newark, 19702, Delaware, USA.

Scope Of This Policy

This Policy applies to the information that we obtain through your use of “Services” or when you otherwise interact with Promoto Inc.
Sub-Contractors(s): Shall mean Data Processors and Sub Processors enlisted separately.
“Services” includes our:
Website: Promoto’s CustomerSuccessBox website, including but not limited to customersuccessbox.com and any subdomains and pages.
Software as a Service solution (SaaS Product): CustomerSuccessBox’s hosted solution including but not limited to any subdomains of customersuccessbox.com. Typically offered as .customersuccessbox.com
In this notice, “personal information” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.
Subscribers/ Sub-Contractor to our Services are solely responsible for ensuring compliance with all applicable laws and regulation, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers/ Sub-Contractors interact. If you are an individual who interacts with a Subscriber/Sub-Contractor using our Services, in addition to the rights available in “Your Rights” section below, you will be directed to contact our Subscriber / Sub-Contactor for assistance with any requests or question relating to your personal information.

Information That We Collect

CustomerSuccessBox processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

The personal data that you may provide on our website:

  • Name
  • Email Address
  • Telephone Number (Optional to provide)

The personal data that we collect as part of our SaaS solution:

  • Limited device information such as IP, Web browser version
  • Product usage data
    • Dates and times you access our Services, including but not limited to  page views
    • Which activities are performed and features that are used
    • Technical device data

The personal data that we collect/process on behalf of our Subscribers:

Here, our privacy practices will be governed by the contract we have in place with our Subscribers. This Notice will not apply to such personal information.

  • Information uploaded by Customers in the Services
  • Information from third-party platforms integrated and authorized for data transfer by Subscriber in the Services such as Support tickets, Invoices, Emails
  • Public information

We collect information in the following ways:

  • Online Demo Forms
  • Marketing Emails
  • Information provided at the time of registration
  • Telecommunication
  • Online Contact-us form
  • Cookies
  • Other Tracking Technologies/ Scripts
  • Third-party application integrations such as Intercom, Salesforce
  • Public portals

How We Use Your Personal Data

CustomerSuccessBox takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as it is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

The purposes and reasons for processing your personal data are detailed below:

  • We collect your personal data in the performance of a contract or to provide a service. We use the information to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process personal data collected in the performance of a contract solely in accordance with the directions provided by the contract.
  • We will occasionally send you marketing information like updates on promotions and events relating to products and services offered by us where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
  • We may use your email address or other information to contact you for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to personal data posted on the Service.
  • We use the information to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, feature, and functionality

Your Rights

You have the right to access any personal information that CustomerSuccessBox processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. Requests to access, change, or remove your information will be handled within thirty (30) days.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.

Unrestricted Information

Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

Service Providers

We work with third-party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

Requirement to disclose

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

International Data Transfers

Please be aware that the information we collect about you, including personal information, may be transferred to or processed in other countries or jurisdictions around the world and you consent to the transfer of information to the U.S. and the use and disclosure of information, including personal information, as described in this Policy.

We shall at all times provide an adequate level of protection for the Customer Data processed, in accordance with the requirements of Data Protection Laws.

We will not transfer Personal Information originating in the EU to third parties (including our Sub-Contractors) unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We comply with the Privacy Shield Principles for all onward transfers of personal information from participating European Countries, including the onward transfer liability provisions.

Privacy Shield Frameworks

Promoto Inc. participates in and has certified its compliance with the EU-U.S. and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. Promoto Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Our certification, please visit https://www.privacyshield.gov/.

Promoto Inc. is overseen by the US Federal Trade Commission (FTC) and US laws shall be applicable to questions of interpretation and compliance with this Policy. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance – free of charge to you. We ask that you first submit any such complaints directly to us at privacy@customersuccessbox.com. If you are not satisfied with our response, please contact JAMS at www.jamsadr.com/eu-us-privacy-shield. In the event that your concern still is not addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third-party service provider for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

Safeguarding Measures

CustomerSuccessBox takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures in place, including:

  • Encryption of data at rest
  • Encryption of data during transit (HTTPS)
  • Restricted access to only authorized personnel through authentication and password mechanisms
  • Implementation of anti-malware software
  • Each node in our AWS Cloud Infrastructure is firewall-controlled
  • Two Factor Authentications to AWS Console Access

 

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to CustomerSuccessBox, however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.

Legitimate Interests

As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We use the legitimate interests’ legal basis for processing direct marketing emailers/phone calls and have identified that our interests are to provide you with high quality, best in industry, performance support system to ease and improve user onboarding, support and training.

In addition, CustomerSuccessBox will occasionally send you marketing material/offers related to our services by email and tele-conversation that have been identified as being beneficial to our subscribers and in our interests. Such information will be relevant to you as a customer and is non-intrusive and you will always have the option to opt-out/unsubscribe at any time. Personally identifiable information collected/stored under this legitimate interests’ basis is protected by the same security measures listed in the ‘Safeguarding Measures’ section above.

Cookie Notice

A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as visited pages or logging in options.

Cookies are widely used in order to make websites work or to work more efficiently, and our site relies on cookies to optimize user experience and for features and services to function properly.

We use automatically-collected information and other information collected through our website through cookies and similar technologies to (i) personalize our service, such as remembering your information so that you will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service.

These cookies do not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Most web browsers allow some control to restrict or block cookies through the browser settings, however, if you disable cookies you may find this affects your ability to use certain parts of our website or services.

Minors and Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is not directed to children under the age of 16, and we do not knowingly collect Personal Data from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has obtained an Account on the Service, then you may alert us at privacy@customersuccessbox.com and request that we delete that child’s Personal Data from our systems.

How Long We Keep Your Data

CustomerSuccessBox only ever retains personal information for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements) and we have strict review and retention policies in place to meet these obligations. Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Changes to the Policy

We reserve the right to change our Privacy Policy at any time. If we make changes, we will post them and we will indicate at the top of this page the date this policy was last revised. If we make material changes to this policy, we will notify you by email or through a prominent notice on the Website prior to the changes being effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. You can choose to discontinue the use of the Websites or Services if you do not accept the terms of this Policy, or any modified version of this Policy.

How to Contact Us

CustomerSuccessBox only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with our Data Protection Officer at privacy@customersuccessbox.com or

Promoto Inc.
2035 Sunset Lake Road
Suite B-2, Newark, 19702, Delaware
USA

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