SweepstakesPros Services Privacy Policy
Last Updated: April 16, 2020
CONTENTS
INTRODUCTION
SweepstakesPros is a division of Pacific Digital Industries, Inc. which also does business under the following names: Hail Agency, SweepstakesPros, Sweepstakes Monkey, Promotion Trust and Site Systems (collectivly "PDI" or "SweepstakesPros"). This
services privacy policy discloses the privacy practices for SweepstakesPros, related to
services provided to our clients. For information related to SweepstakesPros data collection practices on our corporate website, please refer to our
website's Corporate Privacy Policy.
Internet user privacy is of paramount importance to SweepstakesPros and our clients. Since
personal privacy integrity is at the very core of our business, SweepstakesPros
success depends implicitly upon our ability to maintain the trust of the people
using and viewing our services.
SweepstakesPros works with our
clients to create online, offline and mobile promotions, marketing campaigns and permission-based email
marketing programs that achieve superior results. SweepstakesPros is a third party
vendor that provides solutions that enable companies to create and deliver
highly successful marketing programs that drive revenue and deepen customer
relationships.
SweepstakesPros Services Privacy Policy is designed to ensure
that users understand how and why SweepstakesPros may collect and use information.
The following document
thoroughly explains our privacy policy related to services we provide to our
clients. Please read it carefully.
CROSS BOARDER TRANSFERS
SweepstakesPros collects information globally from many countries and we have developed data security practices designed to ensure that your personal information is appropriately protected. Please note that personal information may be transferred, accessed and stored globally as necessary in accordance with this policy.
SweepstakesPros complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transfered from the European Union and Switzerland to the United States. SweepstakesPros 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 privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In any matters relating to the EU-U.S. Privacy Shield Framework, SweepstakesPros is subject to the investigatory and enforcement powers of the Federal Trade Commission. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov and search for our parent company name, Pacific Digital Industries, Inc. in the Privacy Shield List.
ONWARD TRANSFERS
SweepstakesPros takes steps to protect the confidentiality, privacy and security of personal information communicated to third parties. We will only transfer your personal information to third parties as set forth herein or, in the case of personal information collected by us on behalf of clients, as directed by the client who owns the personal information. For personal information owned by SweepstakesPros, we shall ensure that any third party for which personal information may be disclosed subscribes to the Privacy Shield Principles or are subject to law providing the same level of privacy protection as is required by the Privacy Shield Principles and agree in writing to provide an adequate level of privacy protection.
SweepstakesPros may provide your personal information to SweepstakesPros contractors who provide support services to SweepstakesPros in its execution of its services, but only to perform such functions on our behalf and for our purposes under confidentiality agreements or other appropriate confidentiality assurances. In such cases, SweepstakesPros will share only the minimum personal information necessary and maintain liability for those data processors.
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on SweepstakesPros.
In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the personal information. If SweepstakesPros or substantially all of its assets are acquired, personal information will be one of the assets transferred to the acquirer.
All individuals, including EU, UK, and Swiss individuals, have the right to know if SweepstakesPros maintains personal information relating to you. Upon request, SweepstakesPros will provide you with access to the personal information that we hold about you. You may also correct, amend, delete or limit the use and disclosure of the personal information we hold about you. If you have provided SweepstakesPros with personally identifiable information, you may access, modify, delete or limit the use and disclosure of the personal information SweepstakesPros holds about you by sending an email to with "My Personal Information" written in the subject line. We will respond to your request within thirty (30) days. SweepstakesPros, may require proof of identity in order to release/modify personal information.
SweepstakesPros acts as a data processor on behalf of its clients. Each of our clients is the data controller for the data they collect in the applicable promotion and is the sole owner of that data. If you contact us regarding personal data collected in connection with a client promotion for which we are a data processor, we will attempt to refer your request to the relevant client, which is the sponsor of the promotion and the data controller. We are not responsible for responding to your request on behalf of the data controller and your request will be directed to the client only. We will process such requests only upon instructions from the data controller that is sponsoring the promotion.
QUESTIONS & DISPUTE RESOLUTION
If you have questions or concerns regarding our compliance with
this privacy policy, or if you feel that SweepstakesPros is not in compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield principles, you should first contact SweepstakesPros by email at . SweepstakesPros will respond to any such inquiries or complaints within forty-five (45) days. We will investigate and attempt to resolve questions and any concerns regarding use and disclosure of personal information in accordance with this policy.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact JAMS, our U.S.-based third party dispute resolution provider, (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
WHO WE ARE
SweepstakesPros is the premier provider of technologies for online marketing. SweepstakesPros
is a third party vendor that provides solutions that enable companies to create
and deliver highly successful marketing campaigns that may include registration
forms, sweepstakes, email programs, ads and other marketing programs that drive
revenue and deepen customer relationships. SweepstakesPros solutions provide deep
customer insight and powerful campaign execution through a combination of
web-based applications, hosted technology infrastructure and professional
services.
These services include the collection and management of customer information.
Customers provide this information in two ways: by what they say and by what
they do. SweepstakesPros helps clients collect and manage customer information from
a variety of online, mobile and offline sources in a securely hosted database, including
customer-provided profile data from sweepstakes, contests and registration forms, plus
behavioral data such as click history. This technology enables SweepstakesPros and our clients to better understand the effectiveness of marketing
campaigns and to deliver individualized messages to customers.
SweepstakesPros is a third party that collects and processes data only on behalf of our clients for
the completion of stated purposes. The client, not SweepstakesPros, owns data
collected by SweepstakesPros on behalf of the client. SweepstakesPros is contractually
bound to keep clients' customer data private and this data is never shared among
clients.
CLIENT WEBSITE PRIVACY POLICIES
Clients retain the sole and exclusive right
to use any data, which they have obtained through explicit permission from a
user. SweepstakesPros relies on our clients' consumer privacy policies, and we urge
consumers to check the privacy policy of a site before they voluntarily provide
information to or do business with a site regarding:
- What personal information is collected about the consumer
- How that information is used
- With whom the information may be shared
- What options are available to Web users regarding the accumulation, use and distribution of the information
- What security procedures are in place to protect the data
- How a consumer can correct inaccuracies in the data
INFORMATION COLLECTION AND USE
SweepstakesPros collects information for a client from
online registration forms, mobbile applications, sweepstakes, banner ads, telephone, fax, mail, hosted web pages, website
tracking, emails sent on behalf of the client to its customers, and other
methods. At a client's request, SweepstakesPros may also collect information for
a client from a variety of methods, such as its website, its ecommerce site, mobbile applications or offline data provided by the
client or by 3rd parties. Some clients use all of our services while other
clients use only one service.
Providing these services, SweepstakesPros acts as a service provider for our clients. This
means that SweepstakesPros is a third party that processes data only on behalf of
our clients for the completion of stated purposes. The client, not SweepstakesPros,
owns data collected by SweepstakesPros on behalf of the client. SweepstakesPros is
contractually bound to keep clients' customer data private and this data is
never shared among clients.
Below are descriptions of what information is collected and how this information is
used. For information on the collection technology, please see the section below
on how this information is collected.
What kind of information does SweepstakesPros collect?
For some clients, SweepstakesPros hosts data collection pages. These data collection
pages may include surveys, sweepstakes entries or profile pages, where a user
knowingly provides data such as name, email address, physical address, and
product preferences. These data collection pages will usually appear to the user
as a page that resides on the client website. If the client uses a SweepstakesPros-hosted data collection page, the client website links to a page that
resides on a different server. However, the information is still owned by the
client.
Information such as information about the computer system and click stream data are
automatically collected and logged when the user browsers the site, but the data
is not personally identifiable. Personally identifiable information ("PII")
provided by the user, such as Name, Email Address, Postal Address or Phone
Number information, is optional and is done in order to participate in
activities like sweepstakes, contests, games, surveys, forums, subscription
registrations, content or suggestions you submit, chats, bulletin boards, or
because users want to be furnished with products, services or information. On those occasions when we obtain PII from a third
party, we use only reputable sources of such information.
SweepstakesPros is a service provider and provides clients with a website tracking and
analysis service. This service uses cookies to measure the effectiveness of a
client's marketing campaigns.
Why is this information collected?
The profile data as well as tracking and analysis information are gathered to
facilitate a client's ability to provide relevant offers to customers and
determine the effectiveness of marketing campaigns.
Under most circumstances, the user has knowingly provided the personally identifiable
information to the client website. For more information on the information
collection practices of a client, users may refer to the privacy policy for the
client website where the information was submitted.
What kind of information does SweepstakesPros collect
on behalf of clients using our email delivery service?
SweepstakesPros sends permission-based email on behalf of clients to their customers.
SweepstakesPros includes a coded sensor in all of its HTML-based email messages to
determine the user's ability to receive HTML-based email messages. The sensor
activates when the email message is opened and flags the email address of the
user as one that is capable of receiving HTML-based email messages. The web
sensor does not function in a text-only email.
The technology is a web sensor, which is described in detail below, under the
section "HOW DO WE COLLECT THIS INFORMATION?"
If a user does receive HTML-based email messages, SweepstakesPros collects data on the
email client utilized by the user and whether the user opens an email. SweepstakesPros collects this information on behalf of the client who sent the email.
SweepstakesPros may gather information to determine the success of an email campaign by
recording which offer links a user clicks on and which web pages the user
visits. SweepstakesPros may use information collected to analyze
click-through rates to various offers delivered in an email campaign, or use the
information collected to deliver individualized (“one to one”) email
campaigns.
In
addition, many emails sent by SweepstakesPros on behalf of clients include a link
that enables users to forward a copy of the email to a friend. Also known as
referral marketing, this application is completely optional for email
subscribers (the user). Unless the user opts to forward an email, no additional
information is collected.
If
a user opts to forward the email, the only information the user is required to
enter is the user's friend's email address. Once the email is sent on behalf
of the user to the user's friend, the email address of the friend is not used
to contact the friend again, unless the friend visits the client website and
subscribes to receive email from the client.
SweepstakesPros stores the friend's email address and maps this email address to the
email address of the original user (the "forwarder"), in order to provide
any promised incentive or to track complaints.
Why is this information collected in email?
SweepstakesPros includes technology within the emails to
determine a user's ability to receive HTML-based email messages and to track
which links they click on inside the email.
Use of cookies
SweepstakesPros collects the information described in the
previous sections through the use of various technologies, including one called
"cookies." A cookie is a piece of data stored on the user's hard drive
containing information about the user.
For the tracking and analysis services provided on a client
website, SweepstakesPros sets the cookie when a user clicks on a specifically coded
link in an email to the user from the client website. The cookie is set every
time a user clicks on the coded link. The cookie is read by the client website
wherever the website wishes to identify traffic on its website generated by a
marketing campaign.
The cookie set is a persistent cookie. "Persistent"
means that the cookie remains on the user's hard drive after the browser is
closed.
Simple
data collection pages may use per-session only cookies to allow users to log on
and access secure areas of the site. These cookies are destroyed when the user
closes their browser.
Users
can set their browsers to notify them before a cookie is read, giving them the
chance to decide whether to accept it. Users can also set their browsers to turn
off cookies. However, if they do so, some areas of some sites may not function
properly.
How We Respond to Do Not Track Signals
SweepstakesPros does not process or comply with any web browser's "do not track" signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services.
Use of web sensors for tracking and analysis
SweepstakesPros and some clients also use web sensor technology. A number of pages
across client websites and ads may have these sensors. When a user accesses
these pages, notice of that visit is generated. As described above, this
"notice" may or may not be tied to personally identifiable information,
depending upon the purpose of the data collection.
If
users turn off cookies, web sensor technology will still detect visits to the
client website pages where web sensors are located. However, the notices the
sensors generate cannot be associated with other cookie information and will be
counted in the aggregate.
Web sensors in email
messages
In
order to determine a user's ability to receive HTML-based email messages, SweepstakesPros includes a coded sensor in all of its HTML-based email messages. The
sensor activates when the email message is opened and flags the email address of
the user as one that is capable of receiving HTML-based email messages.
This
capability helps SweepstakesPros to send the e-mail in a format users can read. If
the user cannot receive HTML, the user will not receive a functioning sensor.
In
addition, the sensor provides SweepstakesPros with information on how many users
open an email. This information is used to compile aggregated statistics about
an email campaign for our client.
For
information collected by us on behalf of clients, the client for whom we are
providing the service has access to the data collected. The client owns the
information and once the data is transferred to the client, the client controls
who has access to this information.
Prior
to this transfer, SweepstakesPros limits access to the data to employees
responsible for receiving, storing and transferring the data to the client. SweepstakesPros is bound by contract to maintain client data in a secure environment.
SweepstakesPros retains data collected for as long as each client requires it and as required by law. This time period varies for each client. Web log data may be retained for an indefinite
period of time.
SweepstakesPros requires that all clients include an unsubscribe link in every marketing
email sent to users through SweepstakesPros systems. SweepstakesPros also requires
that all clients honor unsubscribe requests in a timely manner. For specific
information on how to access information users have provided to a client
website, users should consult the privacy policy of the client website where
they submitted the information.
SweepstakesPros only provides the information collected to the client for whom it is
collected. Users may have access to certain information collected by the client
and should consult the client's website privacy policy for more specific
information.
SweepstakesPros does not currently provide a mechanism that
allows individuals to opt out of the use of information for a particular
purpose. However, the user should be able to access profile pages and
unsubscribe from email messages at any time. The client may provide users access
to this information.
In addition, a user can opt out of an email list managed by
SweepstakesPros by sending an email to .
Users should include:
- A copy of the email that was received
- The company name and email list from which they would like to be unsubscribed, and
- The email address where they receive the messages.
SPECIAL NOTE ABOUT CHILDREN
SweepstakesPros promotions are not available to anyone under the age of thirteen (13), unless otherwise specifically indicated. We do, however, manage promotions on behalf of our clients which may collect personally identifiable information from children under the age of thirteen (13). In each such instance, for U.S based promotions, SweepstakesPros and our clients fully comply with all aspects of the Children's Online Privacy Protection Act ("COPPA") in the operation of the promotion, in the collection of the information itself and in the subsequent use of the data collected. Personally identifiable information will not be collected in the U.S. from children under the age of thirteen (13) without parental consent in compliance with the COPPA guidelines.
Sites may include links to other websites and SweepstakesPros may develop websites on behalf of our clients whose privacy practices may differ from those of SweepstakesPros. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
Websites may also include social media features such as the social sign-on services, Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on a web site. Your interactions with these features are governed by the privacy policy of the company providing it.
YOUR CALIFORNIA PRIVACY RIGHTS (As provided by California Civil Code Section 1798.83)
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes ("California customer") is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customers' personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and providing a cost free means to exercise that right.
ANTI-SPAM STATEMENT
SweepstakesPros practices permission-based email marketing. SweepstakesPros does not send
unsolicited email or work with companies who do so, and the transmission of unsolicited commercial email is expressly forbidden
through any of our systems.
If
you have received unwanted, unsolicited email sent via this system or purporting
to be sent via this system, please forward a copy of that email, the email
address to which the email was sent and any comments to
for review.
NOTIFICATION OF CHANGES TO THIS POLICY
From time to time SweepstakesPros may revise this Servivces Privacy Policy. Therefore, you should review it periodically so that you are up to date on our most current policies and practices. When a change to our this policy occurs, we will post a notification at the top of this Services Privacy Policy notifying users when it is updated.
If you have any privacy related questions or issues, please contat us at:
Privacy Department
SweepstakesPros
2033 Gateway Place, Suite 500
San Jose, CA 95110
USA
Phone: (888) 900-4245
International: +1-408-475-4245
Email:
Website: www.sweepstakespros.com