Terms of Service
Privacy Policy
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Privacy Policy

Last Modified: May 25, 2018

We at Promoter Ninja (HoshinPlan Strategy S.L.) are committed to protecting your privacy. This Privacy Policy applies to both our Website (www.promoter.ninja) 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, or if you subscribe to the Subscription Service.

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

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@promoter.ninja or by mail to Promoter Ninja (HoshinPlan Strategy S.L.) Sant Francesc, 4 Cerdanyola del Vallès 08290 Barcelona, Spain.



1. Use of the Subscription Service by Promoter Ninja and our Customers

The Promoter Ninja Subscription Service

Our online Subscription Service allows any company that uses it (our customers and Promoter Ninja itself) to create and share NPS surveys. The information added to the Subscription Service, either by site visitors providing their NPS answer to the question or when a Subscription Service user adds the information, is stored and managed on our service providers' servers.



Use by Promoter Ninja

We use our own Subscription Service to create NPS surveys for our customers. Information that we collect and manage using the Subscription Service for our own customer care activities belongs to us and is used, disclosed and protected according to this Privacy Policy.



Use by Our Customers

Our customers use the Subscription Service to send NPS surveys to their customers and learn more about them. Promoter Ninja does not control the content of these NPS surveys if our customers edit them. That information belongs to them and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy. Promoter Ninja processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers, but we do not have control over its collection or management. Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Privacy Policy, and as required by law. We have no direct relationship with individuals who provide Personal Information to our customers. Promoter Ninja acknowledges that you have the right to access your Personal Information. Our customers control and are responsible for correcting, deleting or updating information they have collected from you using the Subscription Service. If requested to remove data we will respond within a reasonable timeframe. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage. Our agreements with our customers prohibit them from using the Subscription Service to collect, manage, or process Sensitive Information. We are not responsible for our customers' use of information they collect on the Subscription Service.

Promoter Ninja collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customer that use our Subscription Service, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.



"Sensitive Information"

This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver's license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.



2. Information We Collect

When You Answer An NPS Survey

You are free to answer an NPS survey sent by any of our Customers. When you visit the register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.



"Personal Information"

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Navigation Information" section below. Payment information includes We collect and process payment information from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.



Log Files

When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Promoter Ninja for the operation of the Subscription Service, to maintain quality of the Subscription Service, and to provide general statistics regarding use of the Promoter Ninja Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.



Information we collect from third parties

From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.



Information About Children

The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16 If you believe that we have collected information about a child under 16, please contact us at privacy@promoter.ninja, so that we may delete the information.



3. How We Use Information We Collect

Compliance with Our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.



We Never Sell Personal Information

We will never sell your Personal Information to any third party.



Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:



  • improve your browsing experience by personalizing the Websites and to improve the Subscription Service;
  • send information or Promoter Ninja content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements
  • meet legal requirements.

We use the information collected through our Subscription Service by our customers for the following purposes:



  • to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
  • to respond to customer support requests; and
  • otherwise to fulfill the obligations under the Promoter Ninja Customer Terms of Service.

Legal basis for processing Personal Information (EEA visitors only)

Promoter Ninja (HoshinPlan Strategy S.L.) is the data controller of your personal information. Promoter Ninja's Data Protection Officer can be contacted at privacy@promoter.ninja

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.



Use of Navigational Information

We use Navigational Information to operate and improve the Websites and the Subscription Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Promoter Ninja.



Customer Testimonials and Comments

We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.



Use of Credit Card Information

If you give us credit card information, we use it solely to collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.



Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.



External Websites

Our Website and emails provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.



Retention of Personal Information

How long we keep information we collect about you depends on the type of information as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communcations" below.

If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Promoter Ninja account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.



4. How we Share Information we Collect

Service Providers

We employ other companies and people to provide services to visitors to our Website, our customers, and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information, analyzing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.



Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Promoter Ninja on the Websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.



Compelled Disclosure

We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.



5. International Transfer of Information

This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected.



International transfers to third parties

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.



6. Cookies and Similar Technologies

Cookies

Promoter Ninja and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.



Information Collected by Our Customers

Our customers can use the tools we provide, as well as tools provided by third parties, to collect Information when you answer an NPS question. Promoter Ninja does not control our customers' use of these tools, nor do we control the information they collect or how they use it.



Single Sign-On

You can log in to our site using a Single Sign-on (SSO) service like your Google account. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Such services may give you the option to post information about your activities on this Web site to your profile page to share with others within your network.



Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.



7. How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information



You have the following data protection rights:

You can request access, correction, updates or deletion of your personal information.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

To exercise any of these rights, please contact us at privacy@promoter.ninja. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.



Anti-Spam Policy

It’s prohibited to use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use at all times, and any violations of the Acceptable Use by a customer can result in immediate suspension or termination of the Subscription Service.



To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.



To Unsubscribe from Our Customers' Communications

Our customers are solely responsible for their own NPS survey emails; we cannot unsubscribe you from their communications. You can unsubscribe from our customers' communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.



Contact

HoshinPlan Strategy S.L.

Carrer Sant Francesc, 4

Cerdanyola del Vallès 08290 Barcelona

Spain

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© 2018 · Promoter Ninja

Net Promoter, NPS are registered service marks, and Net Promoter Score and Net Promoter System are service marks, of Bain & Company, Inc., Satmetrix Systems, Inc. and Fred Reichheld.