PRIVACY POLICY
Last Modified: May 25th
CONTENTS
CLAUSE
Welcome to Marketro LLC’s Privacy Policy. Your privacy is very important to us.
We have created this Privacy Policy to demonstrate our firm commitment to privacy and security.
This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. [Alternatively, you can download a pdf version of the Policy here http://marketro.com/privacy_policy.pdf ]. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE INFORMATION WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED
4. HOW WE USE YOUR PERSONAL INFORMATION
5. DISCLOSURES OF YOUR PERSONAL INFORMATION
6. INTERNATIONAL TRANSFERS
7. INFORMATION SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY Important information and who we are
Purpose of this Privacy Policy
This Privacy Policy aims to give you information on how Marketro LLC collects and processes your
personal information through your use of the Marketro LLC corporate website at http://Marketro LLC.com, its Support website at http://support.marketro.com/, and their respective subdomains (collectively the “Website”), including any information you may provide through the Website when you access some of our services without creating an account with us, when you register to open a vendor or affiliate account to sell/promote products and/or pay a monthly fee to subscribe to our services, when you search our Website, when you register to open a Support account with us, when you submit a Support ticket.
Please note that this website is not intended for persons under 18 years of age. No one under age
18 may provide any information to or on this Website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18 without verification
of parental consent, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us here http://support.marketro.com//.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.
[Marketro LLC Group is made up of different legal entities, details of which can be found here http://marketro.com/group.txt . This Privacy Policy is issued on behalf of the Marketro LLC Group so when we mention "Marketro LLC", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Marketro LLC Group responsible for processing your information.] Marketro LLC, LLC is the controller and responsible for your personal information.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us here http://support.marketro.com//
If you are based in the European Union, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us at http://support.marketro.com// in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website and the last revision date of revision will be updated so that you will always be able to understand what information we collect, how we use your information, and under what circumstances we may share your information with others. We will notify you of any material changes by way of a pop-up notice on the Website announcing that the Privacy Policy has changed pointing the changes to your attention AND/OR by the way of email AND/OR web app notification.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
Please note that we also do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. If you are based in the United States you can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website at http://optout.networkadvertising.org. If you are based in the European Union you may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.
Our Website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request the removal of your personal information, if you are EU from our blog or community forum, contact us by posting a request on our helpdesk here http://support.marketro.com/.
2. Our Website includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, and which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Website. Your interactions with these Features are governed by the privacy policies of the companies providing them.The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal information about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. How is your personal information collected?
We use different methods to collect data from and about you including through:
(a) analytics providers such as Google based outside the EU;
(W) advertising networks such as perfectaudience.com based outside] the EU; and
(c) search information providers such as Google and Bing based outside the EU.
We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at http://support.marketro.com//.
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us http://support.marketro.com// if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.
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Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
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To register you as a new vendor or affiliate |
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Performance of a contract with you |
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To process and deliver your order including:
|
|
|
|
To manage our relationship with you which will include:
|
|
|
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To enable you to partake in a prize draw, competition or complete a survey |
|
|
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To administer and protect our business and this Website (including troubleshooting, data a n a l y s i s , t e s t i n g , s y s t e m |
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(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the |
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maintenance, support, reporting and hosting of data) |
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context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
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To deliver relevant website content and advertisements to you and measure or understand t h e e f f e c t i v e n e s s o f t h e advertising we serve to you |
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Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
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To use data analytics to improve our website, services, marketing, customer relationships and experiences |
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Necessary for our legitimate interests (to define types of customers for our services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To ma k e s u g g e s t i o n s a n d recommendations to you about services that may be of interest to you |
|
Necessary for our legitimate interests (to develop our services and grow our business) |
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. [We have established [a privacy center where you can view and m a k e c e r t a i n d e c i s i o n s a b o u t y o u r p e r s o n a l d a t a u s e http://support.marketro.com/support/solutions/13000002971 OR the following personal information control mechanisms]:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you o] by contacting us http://support.marketro.com//.
Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.
California residents: Under California Law SB27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please contact us at http://support.marketro.com// send and please include the phrase “California Privacy Request” in the subject line of request, and the domain name of the Website you are inquiring about, along with your name, postal address, and email address. We will respond to you within 30 days of receiving such a request.
While we take all reasonable steps to protect the privacy of our Website visitors, we cannot promise that the current limitations of our online applications programming will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications programming is refined, we will take all reasonable steps to honor such requests in the future. Please return to this Privacy Policy for further updates on this topic.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see http://Marketro LLC.com/cookie_policy.pdf
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at http://support.marketro.com//.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above.
We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).
Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.
If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguard is implemented :
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. However, you should note that no transfer of data over the Internet is completely secure. While we use reasonable efforts to protect your personal information on our systems, when the information is transferred over the Internet, it may be accessed and used by unauthorized third parties. Marketro LLC has no control over the performance, reliability, availability or security of the Internet and does not warrant that any information transfer via the Internet or any communication through the Internet is secure. Marketro LLC shall not be liable for any disclosure, unauthorized use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception, corruption, intervention, misuse or alteration of any personal information due to any reason beyond Marketro LLC’s reasonable control.
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your information: see [Request erasure] below for further information.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal information. Please click on the links below to find out more about these rights:
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting http://support.marketro.com//].
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
Other companies in the Marketro LLC Group acting as joint controllers or processors and who are based US and provide IT and system administration services and undertake leadership reporting.
You have the right to:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.