Privacy Policy

PromoNinja's Privacy Policy was created to reaffirm our commitment to the security, privacy and transparency in the handling of your information.

This document describes what personal data we collect, how it is handled, stored, and shared, what your rights are in relation to it, and other relevant information. Therefore, we recommend that you read this document carefully.

What is personal data processing?

Data processing is any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, control, modification, communication, transfer, dissemination or extraction of information.

Who does the Privacy Policy apply to?

This Privacy Policy applies to all individuals who access and/or register on our platform via the website www.promoninja.com; our mobile application "PromoNinja", available on Google Play and the App Store; or who use the PromoNinja product in any other way.

By accepting this Privacy Policy, you acknowledge that the controller of your personal data, that is, the company responsible for making decisions about the processing of your personal data, is PromoNinja.

The practices described in this Privacy Policy apply only to the processing of your personal data in Brazil and are subject to applicable local laws, particularly Law No. 13,709/2018 (General Personal Data Protection Law, or "LGPD") from its effective date.

What personal data do we collect?

When you access PromoNinja, create an account, register and/or use our Chat, you provide us with and we automatically collect personal data related to you. To improve your experience, we strive to understand your preferences so we can suggest relevant materials and products. By accessing PromoNinja and our Chat, you give us your express consent to process your data. The following categories of data are collected.

1. Personal data provided by you
   1. Registration data: Name, surname, username, photo, password, gender, and age.
   2. Contact data: Email, telephone number, and demographic data.
   3. Social network data: If you register using a Gmail, Facebook, or Apple account, we collect your registration email, first name, last name, and account ID.
   4. Research data: Your name, email, and responses to questionnaires and categories of interest, for the purpose of directing campaigns and surveys.
   5. Our Services are not intended to be used by children, and we do not knowingly collect or maintain personal information from children. If we learn that we have collected personal information from a child under 16 years old, we will take appropriate steps to delete this information. If you are a parent or legal guardian of a child under 16 years old and believe your child has provided personal information to PromoNinja, please contact us at [email protected] to request that we delete your child's personal information from our systems.
2. Browsing and device data
   1. Cookies
   2. Device attributes: Device ID, advertising ID, model, operating system, browser, geographic location, and language.
   3. Behavioral data: Pages viewed, time spent on the website or app, clicks, interactions with PromoNinja, and searches.
3. Personal data we collect from third parties
   1. Order transactional data: Date, product, price, and store.
   2. Service and support data: Publications, comments, among others.
4. Personal data originating from the use of PromoNinja
   1. Deal commenting data
   2. Deal voting data
   3. Liked comments data
   4. Saved Alerts data
   5. Published deal data
   6. Click data on deals to external websites
   7. Survey data: Your name, email and questionnaire responses (with your consent)
5. Public data
   1. We may collect information about you that is publicly available or that has been made public by you.
   2. Information about mentions or interactions with PromoNinja
   3. Testimonials about PromoNinja posted on social media, along with your name and image (including profile photos).

Why do we collect your personal data and how do we use it?

We use your personal data to provide, maintain, improve and personalize our products and services, intended for you, whether existing or to be developed. We detail below the specific purposes for using your data:

Personal data provided by you

• Provision of services: To enable account creation, login, and prevent fraud.
• Communication: To send you news, feature updates, personalized content recommendations, marketing campaigns, and support messages.
• Research: To conduct market and opinion research.
• Notifications: To inform you of changes to our services or Privacy Policy.
• Legal Compliance: To collaborate with or comply with court orders, legal authorities, or regulatory bodies.

Browsing and device data

• Provision of services: To optimize your experience and improve our offerings.
• Product Development: To customize and create new products and services.
• Advertising: To display relevant ads on our website and app.
• Analytics: To generate statistics, studies, and research about user behavior and marketing campaign effectiveness.
• Technical Support: To prevent and resolve technical or security issues.
• Legal Compliance: To collaborate with or comply with court orders, legal authorities, or regulatory bodies.

Personal data we collect from third parties

• Service Improvement: To enhance our products and services.
• Technical Support: To prevent and resolve technical or security issues.
• Legal Compliance: To collaborate with or comply with court orders, legal authorities, or regulatory bodies.

Personal data originating from the use of PromoNinja

• Provision of services: To enable features like commenting, voting, liking, and saving alerts.
• Customer support: To assist you with any questions or issues.
• Product Improvement: To test and improve our models, services, and products.
• Technical Support: To monitor the use and performance of our services and products, and to prevent and resolve technical or security problems.
• Communication: To send you news, information about new features, marketing campaigns, and content.
• Legal Compliance: To collaborate with or comply with court orders, legal authorities, or regulatory bodies.

Public Data

• Marketing and Promotion: To share information about PromoNinja's products and services on social networks, websites, apps, and other promotional materials.

How long will we keep your personal data?

The data we collect from you is stored on secure cloud servers provided by trusted partners. These partners may be located in Brazil or in other countries with strong data protection frameworks, such as the United States, countries in South America, and Europe. We only work with service providers that are widely used by other major technology companies and adhere to industry best practices for data security.

We retain your personal data for the period necessary to fulfill the purposes outlined in the Terms of Service and this Privacy Policy, in compliance with the data retention period determined by applicable legislation.

Even after account deletion, we may store anonymized personal data, such as deals and comments, for a period allowed by law or regulation to exercise PromoNinja's rights and for legal or regulatory compliance.

Who do we share your personal data with?

We emphasize that, under no circumstances, do we sell your personal data to third parties. However, we share this data with some partners for legitimate interests. We may share your data with:

• Pepper Media Holding GmbH - Torstr. 164, 10115 Berlin, Germany
• 6 Minutes Media GmbH - Torstr. 164, 10115 Berlin, Germany
• Pepper Deals Ltd - Unit 2, 1-6 Bateman's Row, EC2A3HH London, United Kingdom
• Pepper France SAS - 18 Rue Félix Mangini, 69009 Lyon, France
• Tipping Canoe Ltd - 200 – 171 McDermot Avenue, R3B 0S1 Winnipeg, Canada
• PMH Solutions GmbH - Torstr. 164, 10115 Berlin, Germany

We may also share data with third-party business partners, including social media platforms or technology companies like Facebook, Google or Apple, which may provide you with authentication services, such as connecting your profile information from their platforms to our platform.

Contracted, technical or analytics partners who can help us: analyze our traffic; analyze the behavior of users visiting the platform to distinguish humans from automated programs; deliver personalized push notifications to our mobile app; measure the performance of our ads and marketing campaigns; carry out new product development, maintenance and debugging; and provide customer service.

These providers have limited access to your information to perform these tasks on our behalf. They are contractually obligated to protect your data and use it only for the purposes for which it was disclosed, consistent with this Privacy Policy. We only transfer your personal data to these third parties if there is a legal basis and adequate security is provided.

When using our application or browsing PromoNinja, you may be redirected to third-party websites or applications. When this occurs, the privacy practices will be those defined by the privacy policy and terms of use of these third parties. We have no control over and are not responsible for the content and practices of third parties. We recommend that you carefully read the applicable privacy policy and terms of use to understand how they collect and process your data.

How do we protect your data?

PromoNinja adopts security, technical and administrative measures to protect personal data from unauthorized access and from accidental or unlawful situations of destruction, loss, alteration, communication or any form of inadequate or unlawful treatment.

We use the principles stipulated by law, respecting your privacy and protecting your data in our internal processes as a whole.

We only process your data with a high degree of security, implementing the best practices in use in the industry for data protection, such as: encryption techniques, monitoring and periodic security testing.

How do we use cookies and other technologies?

When using PromoNinja through the website or application, we may record the activities you perform, when possible and applicable. For this, we use certain technologies, our own or third parties, to monitor activities, namely:

Cookies: are internet files that temporarily store what you are visiting on the network. Cookies can be used for various purposes, including remembering you and your preferences, persisting information related to your activities on the visited site, or collecting information that can be used to offer content in a personalized way. Our website may also use locally stored objects to provide a personalized experience.

We have third-party cookies activated on our site. Privacy practices will be governed by the privacy policy and terms of use of these third parties, so we cannot control or be responsible for the privacy practices and content of third parties. Therefore, we emphasize that you can, at any time, block the use of cookies by activating a setting in your internet browser and your ability to limit cookies will be subject to the settings and limitations of your browser. You can also delete existing cookies through the same settings in your internet browser. If you choose to disable cookies, you can continue browsing websites and blogs, but some parts of the pages may stop working.

Web beacon: Web beacon is a technique that allows mapping who is visiting a particular web page, identifying their behavior with different websites or web servers.

Analytics tools: These tools may collect information such as how you visit a website, including which pages and when you visit those pages, as well as other websites that have been visited before, among other things.

All technologies used by us will always respect the terms of this Privacy Policy.

Do we transfer your data to other countries?

We share information globally with our partners in accordance with this policy. Your personal data may, for example, be transferred or transmitted to, or stored and processed in the United States, Europe, or other countries outside of where you live, for the purposes described in this policy.

We comply with all requirements established by current legislation and adopt the best security and privacy practices to guarantee the integrity and confidentiality of your personal data.

What are your rights and how to exercise them?

Your personal data is yours, and we respect that. As the owner of your data, you can exercise your rights with the controllers, in this case PromoNinja. To this end, we provide in detail, clearly and objectively, what your rights are and how you can exercise them in the list below:

1. Confirmation of data processing

When you access PromoNinja through our website or mobile application, or when you register for an account, you acknowledge that we are processing your personal data in accordance with the best security practices in the market and with respect for your privacy.

If you want to know more about data processing, you can contact us at any time by email: [email protected]

2. Data access

Your personal data is yours, and you can request it from us at any time by contacting us via email: [email protected]

3. Correction of incomplete, inaccurate or outdated data

We provide means of editing all personal data provided, whether related to registration information, comments, posts, etc. However, if you have noticed that your personal data is incomplete, inaccurate or outdated, and you need help to change it, you can ask for it to be corrected or completed at any time by contacting us via email: [email protected]

4. Anonymization, blocking, or deletion of personal data that is unnecessary, excessive, or processed in violation of the LGPD.

If any personal data is processed in an unnecessary way, in excess of its intended purpose or in non-compliance with the LGPD, you can request that PromoNinja anonymize, block or delete this data, as long as the excess, lack of necessity or non-compliance with the law and that there is no other legal basis for processing other than your consent.

5. Data portability

You have the right under the LGPD to request a copy of your personal data in a portable, structured, interoperable, and machine-readable format. This allows you to easily transfer your data to another service provider. You can exercise this right at any time by emailing us at: [email protected]

6. Deletion of personal processed data with consent

If you have given consent to the processing of your personal data for purposes not essential to providing our services, you can request the deletion of this personal data through your profile by clicking "delete my account".

If you have any questions about how this process works, feel free to contact us at any time by email at: [email protected] send your questions, and we will be happy to assist you.

7. Information from public and private entities with which PromoNinja shared data use

In the topic "Who do we share your personal data with" we clearly describe which companies we share information with and how we do this. However, if you still have any questions about our data sharing practices and want to know more, you can get in touch at any time by email: [email protected] send your questions, and we will be happy to assist you.

8. Information about not providing consent and the consequences of refusal

PromoNinja uses your personal data to provide a high quality service and offer you the best experience. If you wish not to provide consent for its collection, access to some features will be restricted, such as creating an account, wishlist alerts, among other features.

If you have any questions or uncertainty about providing your consent, we ask that you contact us at any time by email: [email protected] send your questions, and we will be happy to assist you.

9. Withdrawal of consent

You may withdraw your consent for PromoNinja to process your personal data at any time by emailing us at [email protected]. However, by doing so, this action may result in the inability to use some of our services and even in the deletion of the account.

How do we notify you of changes to this Policy?

Committed to transparency in the processing of your data, whenever there is any change in the privacy policy, we will send a statement via email and possibly through another official communication channel, if necessary, informing you of the changes made.

By continuing to use our platform after a change in the Privacy Policy, you will be agreeing to the new conditions – but you can always express your disagreement through our service channels, if applicable.

PromoNinja may change this Privacy Policy whenever necessary and each time this occurs, these changes will be valid, effective and binding after the new version is published on our website or sent by email to you.

In the event that the changes made to this Privacy Policy modify, in any way, how we process personal data that depends on your consent, we will obtain your consent again before continuing such processing. We will also clearly explain the new purpose(s) for which your consent is being sought.

State Privacy Rights

PromoNinja users who are residents of California, Colorado, Connecticut, Utah, or Virginia have certain rights under their respective state privacy laws regarding personal information we collect. If you are a resident of such states, this section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you. This section applies only to personal information covered by these state privacy laws.

If you interact with PromoNinja in a business capacity and are a California resident, you may also have certain rights under California law, such as the California Consumer Privacy Act (CCPA), regarding personal information we collect. This section of the Privacy Policy contains disclosures required by law and explains rights that may be available to you.

Personal Information we collect and disclose: In the past 12 months, we collected the following categories of personal information:

• Individual identifiers, such as first and last name, email address, or phone number
• Internet or other electronic network activity information, such as browsing history, search history, interactions with a website, email, app, or ad
• Geolocation information, which is limited to general location information, such as your city or state
• Inferences drawn from the above information about your predicted characteristics and preferences

Residents of California, Colorado, Connecticut, Utah, and Virginia have certain rights with respect to personal information collected. If you are a resident of one of these states, you may be able to exercise the following rights regarding personal information PromoNinja has collected about you, subject to certain exceptions and limitations:

• The right to confirm whether we are processing personal information about you.
• For California residents, the right to know the categories of personal information we collect, use, disclose, and share about you, the categories of sources from which we collected your personal information, our purposes for collecting your personal information, the categories of your personal information that we have either sold, shared, or disclosed for a business purpose, and the categories of third parties with which we have disclosed personal information.
• The right to access a copy of the specific pieces of personal information that we maintain about you.
• The right to request that we delete the personal information we have collected from you. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
• The right to request that we correct inaccuracies in the personal information we have collected about you.

To exercise your rights to confirm, know, access, delete, or opt out of the processing of your personal data, please contact us by email at [email protected].

Contact us

As the "Controller" of data according to Law No. 13,709/2018, PromoNinja is responsible for making decisions about the processing of your personal data and will do so in compliance with current legislation as described in this privacy policy document.

If you have any questions after reading the Privacy Policy and want to clarify them or need to communicate any matter related to your personal data, you can contact us through the channels below:

By email, speaking to the Data Protection Officer (DPO) [email protected]

PromoNinja may make changes to this Privacy Policy from time to time. We recommend you regularly review our Privacy Policy so that you are aware of and understand our current privacy practices.