Privacy Policy

Last Updated: [06, March 2020]

This Privacy Policy applies to the Promota websites and apps controlled by LG Electronics Inc. ("LGE" or “we”) where this privacy policy is posted or referenced (collectively, the "Services").  This Privacy Policy applies only to information collected on the Services and does not apply to information collected by LGE through any other means, including data collected directly from LG devices. This Privacy Policy also does not pertain to other information that is collected offline or to information that is posted or processed by third parties.

BY ACCESSING OR USING THE SERVICES, YOU CONSENT TO THE TERMS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE SERVICES.

 

1. Collection of Personal Information via the Services

 

We collect or receive certain personal information from or about you in order to provide you with services and functionalities on the Services. Listed below are the categories of personal information that we collect, with examples of each:

A. Basic Identifiers. We collect basic identifying information and contact details, such as your real name or alias, email address and  business category promoted.  Basic identifiers may be collected directly from you when you interact with the Services (e.g. when you create an account, contact us, or provide feedback on something via the Services).

B. Commercial Information and Records. We collect information about purchases you have made  and your general purchase history. We collect this information by tracking your purchases, orders, or other interactions with the Services.

C. Internet and Other Network Activity. We collect information on your Internet and other network activity, including information about the way in which you interact with the Services. Such information may include your device control history record, web access log and API request log, connection status, crash logs from the application, browsing or search history, clickstream data, OS version, and interaction with ads. We may also collect  text, photos or video files in signboards create with the application. We collect this information by tracking your interactions with the Services, and may also receive this information from vendors who we engage to collect this information on our behalf.

D. Geolocation Data. We may collect information about your (retail shop) business name, business address, precise location, including street name, city or town, ZIP or post code, state, country. We collect geolocation information from you if you choose to provide it to us.

 

2. Use of Personal Information Collected Via the Services

 

We use information that we collect on the Services to provide you with our services and to facilitate and enhance your user experience. Specifically, we use your personal information for the following purposes:

 

A. To provide you with our services. We may use your Basic Identifiers, Geolocation Data, and Other Network Activity to provide you with certain services.

 

B. Providing you with a user-friendly experience as you navigate and use the Services. We may use your Basic Identifiers, Internet and Other Network Activity, and Geolocation Data to ensure our Services are tailored to you and that they function smoothly.

 

C. Completing your registration of an account or device. We may use your Basic Identifiers and Geolocation Data to complete your registration of an account or device with us.

 

D. Alerting you to special offers, updated information, and other new products or services from LGE or other third parties. We may use your Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to notify you about special offers or pricing, updated information, or other new products or services from LGE or third parties.

 

E. Fulfilling the terms of a promotion. We may use your Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to fulfill the terms of a promotion offered through the Services.

 

F. Ensuring the Services are relevant and/or tailored to your preferences and needs. We may use your Basic Identifiers, Internet and Other Network Activity, and Geolocation Data to tailor content on the Services to your preferences and needs.

 

G. Communicating with you. We may use your Basic Identifiers and Geolocation Data to communicate with you.

 

H. Providing you with promotional materials. We may use your Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to provide you with promotional materials.

 

I. Allowing you to access limited-entry areas of the Services. We may use your Basic Identifiers to allow you to access limited-entry areas of the Services, such as those requiring an account for use or access.

 

J. Assessing the performance and effectiveness of the Services and advertisements placed on the Services. We may use your Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to assess the effectiveness of the Services, any ads served through the Services, and our own marketing campaigns.

 

K. To compile statistics. We may use Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to compile statistics and other analytics about users and/or the function and usage of the Services.

 

L. Complying with our legal obligations. We may use Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to comply with any applicable legal obligations.

 

M. Protecting and ensuring the safety and security of the Services, LGE, our users, and others as applicable. We may use Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to protect and ensure the safety and security of the Services, LGE, our users, and others as applicable and necessary.

 

N. Creating and maintaining internal records. We may use Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to create and maintain internal records, such as records of user interactions, purchases, and other records as we deem necessary or as otherwise required by law.

O. Marketing to you. We may use Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data to market to you and provide you with tailored advertisements.

 

3. Sharing and Disclosure of Personal Information Collected Via the Services

 

A. Sharing For Our Business Purposes

We may share information we collect with outside entities for our own business purposes. We share this information to provide or otherwise enable your use of features and functions on the Services, and for various internal purposes, such as providing customer service, processing any orders, ensuring the security of the Services, LGE, and its users, and analyzing the data we collect. More information on the reasons we share information can be found below.

  • To Provide Services. We may share your Basic Identifiers, Commercial Information, Internet and Other Network Activity, and Geolocation Data with our service partners, who help us provide you with services you request on the Services. Such service partners include customer management and marketing vendors and mobile app measurement & attribution analytics platform. We need to share information with these partners in order to process your order, fulfill your request, provide you with customer support, or provide other services or functions. We may also share with our parent company, subsidiaries, and affiliates in order to better serve you or maintain our business.
     

  • To Provide You With More Relevant Advertisements. In order to provide you with certain advertisements, including ads tailored on your interests based upon your information (“interest-based advertisements”), we may need to share certain information with partners who work with us and with other entities to place these ads. Interest-based advertisements may be displayed across different platforms, websites, and devices.
     

  • For Legal Reasons. We may share all of the above categories of information with service partners or other outside entities as necessary to comply with our legal obligations, including compliance with any applicable law, legal process, or court order. We may also share information in order to protect and defend the rights of LGE, our users, or any other individual, to protect against fraudulent or malicious activity, to enforce our Terms & Conditions, or to cooperate with law enforcement agencies.
     

  • For Other Internal Reasons. We may share all of the above categories of information with service partners and other entities that provide LGE with certain services or assist with internal functions, such as analyzing data, maintaining the security of our systems, or ensuring our compliance with the law. For example, we may share information with auditing firms, outside attorneys in order to obtain legal advice, or with other professional advisors. Other entities that may receive information for these purposes include information security vendors, data analytics firms, quality assurance assessors, and similar types of entities. We may also share with our parent company, subsidiaries, and affiliates in order to better serve you or maintain our business.
     

  • In Connection with a Sale or Merger. If we directly or indirectly undergo a business transition (including proposed transactions), such as a merger, acquisition by another company, or sale of all or part of our assets, we may share all of the above categories of information to the successor or potential successor organization, as well as their professional advisors during the transition.
     

  • When you otherwise consent to such disclosure. We may share certain information with service partners or other entities when you direct us to share or otherwise consent to our sharing such information.

 

4. Managing Communications

From time to time, we communicate with users of the Services who subscribe to our services via email. For example, we may use your email address to confirm your request, to send you information about changes to our services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional and you have consented to receiving such e-mails by providing your email address.

Should you no longer wish to receive other types of communication from us, such as emails or updates regarding new services offered on the Services, we offer you the opportunity to stop these communications. For e-mails, you may opt-out of receiving such e-mails by clicking on the "unsubscribe" link within the text of the email. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more e-mails until the process is completed.

5. Your California Privacy Rights

 

This section applies to you if you are a California resident.

 

A. Right to Access

As a California resident, you may, subject to verification procedures, request details from us about the information we have collected from and about you over the past 12 months, including:

  • The categories of personal information we have collected about you, including Basic Identifiers, Commercial Information and Records, Internet and Other Network Activity, and Geolocation Data, as well as any other information you may choose to send us;

  • The categories of sources from which the personal information was collected;

  • The business or commercial purpose(s) for our collection of your personal information;

  • The categories of third parties with whom we have shared your personal information;

  • The specific pieces of personal information we have collected about you; and

  • The categories of personal information we disclose for a business purpose.


If you wish to request such access to your personal information, please contact us at caprivacy@lge.com or 833-660-0245

B. Right to Delete

 

As a California resident, you may, subject to verification procedures, request that we delete any personal information we have collected about you subject to a number of exceptions, including, but not limited to, if the information is necessary for us or our service provider to:

  • Complete your transaction;

  • Provide you services;

  • Perform a contract between us and you;

  • Protect your security and prosecute those responsible for breaching it;

  • Fix our system in the case of a bug;

  • Protect the free speech rights of your or other users;

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;

  • Comply with a legal obligation; or

  • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

If you wish to request deletion of your personal information, please contact us at caprivacy@lge.com or 833-660-0245. You may also delete your data by deactivating your account.

C. Timing and Format of our Response to Access or Deletion Requests

 

We endeavor to respond to a verifiable request for access or deletion within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

 

D. Do Not Sell My Personal Information (Right to “Opt-Out”)

 

As a California resident, you have the right to “opt out,” or to direct us to stop selling or otherwise sharing your personal information with third parties in exchange for monetary or other valuable consideration.

 

We hereby inform you that we do not in any way sell or share your personal information with third parties in exchange for monetary or other valuable consideration.

 

E. Verification Procedures

When you submit a request to access or delete your information, we will need to verify your identity before addressing and fulfilling your request. We will do so in accordance with applicable law.

 

F. Appointment of Authorized Agent

As a California resident, you may appoint an authorized agent to exercise your rights on your behalf. In order for us to honor a request made by your agent, you must submit proof of your written authorization of the agent.

 

G. Freedom from Discrimination

 

You have a right not to receive discriminatory treatment by LGE for exercising your California privacy rights.

 

H. Erasure for Users Under 18

 

California residents under the age of eighteen (18) who have registered to use the Services and who have posted content or information on the Services can request the removal of such information. To request removal of a submission, please send an email with a detailed description of the specific submission to caprivacy@lge.com. You also may be able to deactivate your account and delete your own submission. LGE reserves the right to request that you provide information that will enable us to confirm that the Submission that you want removed was created and posted by you.

LGE will make a good faith effort to delete or remove your submission from public view as soon as reasonably practicable. Please note, however, that your request that we delete your submission does not ensure complete or comprehensive removal of your submission. Your submission may remain on backup media, cached or otherwise retained by LGE for administrative or legal purposes or your submission may remain publicly available if you or someone else has forwarded or re-posted your submission on another website or service prior to its deletion. LGE may be required by law to not remove or allow removal of your submission.

6. Third Party Websites

This Privacy Policy applies solely to information collected on the Services. The Services may contain links to other online platforms and websites that are operated by third parties. We do not control such other online platforms or websites and are not responsible for their privacy practices, content, or use of your information. If you make purchase transactions through the commerce solution which is accessible through the Services, you may be required to provide information (including payment information) directly to a third-party retailer in connection with the sale of products through the Services.

Information you provide on public or semi-public platforms, including information you share on third-party social networking websites (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of third-party websites. Our inclusion of links to third-party platforms or websites does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators. We expressly disclaim any and all liability for the actions of third parties, including but not limited to actions relating to the use and disclosure of personal information by third parties.

Any information disclosed to third parties shall be governed by the relevant third party’s privacy policy.

7. Overseas Transfers

As a global organization, we, our affiliates, subsidiaries, and suppliers may need to transfer your information outside the country where you registered for the services (for example, we may need to transfer information to our headquarters in South Korea). We may transfer your information in this manner in order to provide you with our products and services, and for any other purposes outlined in this Privacy Policy, consistent with this Privacy Policy and any applicable laws. You should also bear in mind that the data protection laws in many of these countries may not offer the same level of protection as those in your home country. However, before transferring we will take steps to ensure that safeguards are put in place aimed at ensuring the same level of protection as required by applicable data protection laws in the country where you are located. By agreeing to this Privacy Policy you expressly consent to us and our business associates and suppliers processing your data in any jurisdiction, including, without limitation, the United States of America and South Korea, in accordance with this Privacy Policy. For further information on how we handle and protect your personal information, please contact us at admin@promota.net or 833-660-0245

 

 

8. Children’s Privacy

The Services are not designed for use by individuals under 13. LGE does not knowingly collect or solicit information from anyone under the age of 13 or knowingly allow such persons to use the Services. If you are under 13 please do not attempt to register on the Services or send us any information.

 

9. Security

 

We make reasonable efforts to ensure security on our systems; however, no transmission of information over the Internet is guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to LGE is done at your own risk.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Services or providing information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Services. We may post a notice on our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

10. Changes to this Privacy Policy

 

We reserve the right to change this Privacy Policy from time to time in our sole discretion. When we do, we will also revise the "last updated" date included in this Privacy Policy. If material changes are made to the Privacy Policy, we will notify you by placing a prominent notice on the Services, via email at the email address we have on file for you, or by other means, consistent with applicable law. We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your information.

If you do not accept and agree to this Privacy Policy, including any changes, then you must not access or use the Services.

 

 

11. Contact

 

If you have any questions about this Privacy Policy or our privacy practices, please contact us at admin@promota.net or

 

LG Electronics Inc.

128 Yeoui-daero, Yeongdeungpo-gu

Seoul 150-721 Republic of Korea

 

 All information you provide in any written communication will be handled in accordance with this Privacy Policy.

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