Privacy Policy

Last Updated: June 13, 2018

We at Provaro Marketing are committed to protecting your privacy. This Privacy Policy applies to all our Websites (under the main domain and sub-domains of provaromarketing.com) and our Subscription Service (the Subscription Service).

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites or the Subscription Service.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.

 

1. Information we collect about you.

Personal and contact information including your name, age, telephone number, postal address, email address, username, social media username(s). We may collect some of that contact information when you interact with us including via our Customer Care Team.

Details (and copies) of your communications and interactions with us via our Customer Care Team or otherwise, including by email, telephone (voice recordings), post and online via webchat, the feedback button or on Provaro Marketing’s social media channels.

Copies of documents you provide to prove your identity (including driver’s license and passport) when there is a legal reason to request this from you.

Transaction details including payments from you for subscription or purchase of our courses and/or services.

Your financial information, including your payment card information (which is sent to PayPal, WePay, or Stripe) when you make a purchase or subscribe to a course.

Information about how you use our app or website, and which websites you came to us from.

Technical information about your device or browser when you use our app or website, including geolocation data to determine what country you are accessing our website or app from, your internet protocol (IP) address, device ID, browser type and version and time zone setting, which may in some circumstances be personal data.

We may also receive personal data directly from you or from various third parties and public sources, including from social media channels (if you interact with us through those channels), or other third parties.

 

2. How and why we use your personal data.

In the table below, we set out all of the ways we use your personal data, and why. We have also identified what our legitimate interests are where appropriate.

It is sometimes necessary for us to process your personal data in order to enter into a contract with you, or to satisfy a contractual requirement (referred to as ‘performance of a contract with you’ below), or to comply with a statutory requirement. In those circumstances, if you do not provide the personal data we require, we will be unable to provide our courses or other services to you.

What
How
Why

Registration
We use your personal and contact information to register you as a new student/client.

We collect financial information if you register payment card information when purchasing or subscribing to one of our courses or services.

Necessary for the performance of a contract with you.

What
How
Why

Accessing our course content
We use the personal and contact information provided by you and the transaction details about your purchases, to provide our courses and other services to you.
Necessary for the performance of a contract with you.

What
How
Why

Managing your account
We use your personal and contact information, financial information, and transaction details about your purchases, to manage your account.
Necessary for the performance of a contract with you.

What
How
Why

Communicating with you

We use the personal and contact information provided by you, copies of your communications with us and, in some circumstances, transaction details, to manage our relationship with you. For example:

  • to notify you about changes to our Account Terms or Privacy Policy;
  • to communicate with you in response to any query, request or complaint you may have including by email, telephone and in web chat whether relating to any course or subscription that you have purchased from us or otherwise.
  • to notify you about changes to our Account Terms or Privacy Policy;
  • to communicate with you in response to any query, request or complaint you may have including by email, telephone and in web chat whether relating to any course or subscription that you have purchased from us or otherwise.

Necessary for the performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to keep our records updated and to study how students use our courses).

What
How
Why

Staff training
We may use copies of your communications with us (including voice recordings) in order to train our staff.
Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).

What
How
Why

Market research

We may use the personal and contact information you have provided to ask you to take part in market research or a survey.

We also use the results of any surveys or market research that you undertake to improve our app, our website, or our service.

Necessary for our legitimate interests (to assess and improve our courses, service and business).

What
How
Why

Prize draws and competitions
We may use your personal and contact information, transaction details, and financial information as part of a prize draw or competition.
Necessary for the performance of a contract with you.

What
How
Why

Technical issues
If you contact us about an issue, we may use technical information, and personal and contact information to administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
Necessary for our legitimate interests (for running Provaro Marketing, the provision of administration and IT services, security and fraud prevention).

Necessary to comply with a legal obligation.

What
How
Why

Experience

We use information about your use of our app or website, together with technical information about your device and (in some circumstances) your personal and contact information, and other relevant information that we receive from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant website content, prize draws, competitions and other marketing to you, and to manage the delivery of that content.

  • For example, we may automatically display relevant advertisements to you based on your use of our website.
Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our app or website).

What
How
Why

Advertising effectiveness
We use information about your use of our app or website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.
Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising, its relevance and in order to fulfill contracts we have with our marketing partners).

What
How
Why

Advertising effectiveness
We use information about your use of our app or website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.
Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising, its relevance and in order to fulfill contracts we have with our marketing partners).

What
How
Why

Analytics
We use information about your use of our app or website and technical information, including about your device or where you are accessing our app or website from, to optimise our service and to improve our app, website, services, direct marketing, student relationships, behaviour profiling and experiences.
Necessary for our legitimate interests (to measure the interactions with our website, to define types of clients and students of Provaro Marketing, how students use the courses, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

What
How
Why

Winners
If you win on a Provaro Marketing competition/draw, we may use your personal and contact information to contact you to arrange support.
Necessary for our legitimate interests (to develop our courses and to manage our winner services).

What
How
Why

Publicity
We may use your personal and limited contact information in any publicity materials provided that you have given your consent.
Your consent.

What
How
Why

Regulatory compliance
We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information, to enable us to comply with our legal and regulatory obligations.
Necessary to comply with a legal obligation.

What
How
Why

Fraud prevention
We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information, in order to undertake analysis for the purposes of identifying and dealing with any fraud or fraudulent activity.
Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent).

What
How
Why

Queries
We may use your personal and contact information, financial information, information about any transaction between you and us, information about your use of the app or website, or technical information for the purpose of dealing with any request, complaint or query from you.
Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to respond to you and to deal with any request you may have).

We use your personal data to create aggregated data sets. You are not identifiable from that aggregated data and it is not considered personal data.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3. How we use your personal data for marketing.

We send you marketing communications through a number of different channels. You may receive newsletters, email notifications, and other marketing communications that either you request from us or which you consent to by opting in when completing a registration form on our service., and/or have not asked us to stop sending marketing by email to you.

How to opt out of marketing.

You may opt out from receiving such marketing communications and notifications from us at any time. There are several ways you can do this. To stop receiving marketing by email, either:

  • Click ‘unsubscribe’ or update preferences in any email communication we send;
  • Contact us in writing; or
  • Email us at helpdesk at provaromarketing.com

4. How we share your data with third parties.

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.  This does not include the following trusted third parties:

  • Banks and payment providers – to set up and/or to obtain payment of any amounts due to us.
  • Our IT system providers – in order to provide software to set up your account, to communicate with you via webchat and other communications providers and to provide our systems to us, including for the purposes of hosting, support and software licensing.
  • Social media platforms – for the purpose of fulfilling the service and targeted advertising.
  • Online survey companies and market research agencies – to undertake surveys (including for example, our website satisfaction survey) and other market research and to analyse the results.
  • Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.
  • Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.
  • Police or other such regulatory authority – as part of an investigation or otherwise for legal or regulatory purposes.
  • Auditors – to audit our systems and transactions for the purposes of ensuring efficiency, or regulatory or contractual compliance.
  • We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety or of our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

5. Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website.  These third party sites have separate and independent privacy policies.  We therefore have no responsibility or liability for the content and activities of these linked sites.  Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

6. How we protect your data.

We have put various measures in place to protect your personal data:

  • Our entire site is accessed using https rather than http, meaning that all information that is sent and received is encrypted for additional security. You can see this in the address bar of your browser.
  • As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. Where we do, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, and have limited control over how it is protected by that party.

7. How long we keep your personal data

We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

At the end of that retention period, your data will either be deleted or anonymised (so that it can no longer be associated with you) for research or statistical purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you may be entitled to ask us to delete your data: see ‘Your rights’ below for further information.

8. Your rights

You have the right:

  • to ask us not to use your personal data for marketing
  • to ask us not to process your personal data where it is processed on the basis of legitimate interests, if there are no compelling reasons for that processing;
  • to request from us access to personal information held about you (see below);
  • to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
  • to ask that we stop any consent-based processing of your personal data after you withdraw that consent;
  • to ask, in certain circumstances, to delete the personal data we hold about you;
  • to ask, in certain circumstances, for the processing of that information to be restricted; and
  • to ask, in certain circumstances, for data portability.

9. Your Consent

By using our site, you consent to our privacy policy.

10. Cookies

We use cookies and similar technologies to recognise you, your browser and your device. We also allow carefully selected third parties to use cookies, pixels and ad tags while you are browsing our website and using our app. These collect information about your browsing habits and usage and allow us to show you ads while you are browsing our website and other sites on the internet. All of our advertising cookies used are described in the cookie list below.

There are four main types of cookies and technology. Here’s how and why we use them:

Strictly necessary cookies

These are cookies that are required for the operation of our website and app. Without these cookies, you will not be able to use some functionality on our website and app, such as signing into your account.

Performance cookies

These cookies collect information about how you use our website or app and help us improve the way our website and app work by making it easier for you to navigate to and complete various tasks.

Functionality cookies

These cookies allow us to identify whether you are logged into your Provaro Training portal and to remember choices you make and your preferences, in order to improve your experience of our website and app.

Advertising cookies and pixels

Our carefully selected media partners place third party cookies, pixels and ad tags onto our website and app on our behalf. These cookies record your visit to our website and/or app, the pages you have visited and the links you have followed.

We use this information to make our website and app, and the content displayed on them, more relevant to you. They are also used to limit the number of times you see certain content, as well to measure the effectiveness of our digital campaigns.

We may share this analytics information with third parties for these purposes. You can delete these cookies and still continue to use the website and app.

More information about these types of cookies and opt out information can be found in Manage your cookies.

Managing your cookies

For more information about cookies, how to opt out and the steps you can take to protect your privacy on the internet, go to http://www.youronlinechoices.com – the guide to online behavioural advertising and privacy. This website is operated by the Internet Advertising Bureau, the industry body for online advertising. On here you’ll find information about how behavioural advertising works, how to opt out, further information about cookies and the steps you can take to protect your privacy on the internet.

If you’d prefer to restrict, block or delete cookies from our website, you can do so in your browser settings. If you choose to disable cookies, then please note that this may limit the way you use our Website. For example, you may have to re-enter information that would have ordinarily been stored as a cookie.

How to control cookies on your desktop:

Internet Explorer cookies information

Safari cookies information

Chrome cookies information

Firefox cookies information

Opera cookies information

How to control cookies on your mobile device:

Apple iOS Safari

Android Chrome

Changes to our Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.

Provaro Marketing
6640 Redwood Drive, Suite 204
Rohnert Park, CA 94928
info at provaromarketing.com

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