This privacy policy (the “Privacy Policy”) sets forth the collection and use practices of Promevo LLC, a Kentucky Limited Liability Corporation (“Promevo,” “we,” “us,” or “our”) for Personal Information that Promevo collects from you in the course of carrying out the services rendered to you, through our various services (including gPanel and gScholar), and through the Promevo website and application URLs under our control, including promevo.com and various sub-URL web pages, gpanel.promevo.com, shop.promevo.com and other websites through which you access or use the services which you purchase from Promevo (collectively, the “Promevo Services” or “services”).

By using our services and/or registering for an account with us, you are accepting the terms of this Privacy Policy, and you are consenting to our collection, use, disclosure and retention of your Personal Information as described in this Privacy Policy. If you do not provide the information we require, we may not be able to provide some of the Promevo Services to you.

This Privacy Policy may refer to the user of Promevo Services as “customer,” “you,” or through any second person pronouns, such as “yours” etc. We want to develop relationships with our users based on respect and integrity. We are aware of the trust and confidence you demonstrate when you use our services, visit our websites and provide us with information. This Privacy Policy is posted to demonstrate our commitment to protecting your privacy online. This Privacy Policy is further drafted to comply with the Children’s Online Privacy Protection Act (“COPPA”) (as it relates to gScholar),  California Consumer Privacy Act (“CCPA”) and E.U. General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Information We Collect and How We Use It

For the purposes of this Privacy Policy, Promevo is considered at times a Data Controller or a Data Processor of Personal Information collected through the Promevo Services depending on the service being provided. We collect several types of information from and about you, including:

Personal Information: We may collect Personal Information (i.e., “personal data” under the GDPR) from you when you complete forms, navigate web pages, and in connection with other activities, services, features, or resources we make available through the Promevo Services. Personal information means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). Personal Information does not include publicly available information from government records, deidentified or aggregate information, or information excluded from the scope of the CCPA and GDPR.

The type of Personal Information we have collected, used, stored, and disclosed in the last twelve (12) months include the following categories of information:

Category Type of Information

Identifiers

First Name, Last Name, Email, Address, Username, Password, IP Address, Credit/Debit Card Information

Categories of Personal Information listed in the CA Consumer Customer Records law

First Name, Last Name, Address, Credit/Debit Card Information

Internet or Other Similar Network Activities

Browsing History, Search History, Interactions with the Promevo Services, Time Information

Geolocation Data

Geolocation, beacon based location, GPS location

You may disable our use of certain internet identifiers and activities through your device or browser settings.

Google Workspace Data

Google Workspace Admin settings, reports, roles, licenses, Users, Profiles, Groups, Organizational Units, Mobile Devices, Chrome devices, Google Drive, Gmail, Contacts, Calendar, Google Sites

gScholar Data

Class names, Class Times, Chromebook Usage, Navigation Data

We offer a number of services that do not require you to register for an account or provide any Personal Information to us, such as our advertisements, press releases, website, and company blogs.

Deidentified Information: We may collect deidentified information from you that may not by itself reasonably identify you as the source when you navigate the Promevo Services (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.

Children’s Information: Through the gScholar service (“gScholar”), we offer a management application to enable educational institutions to setup classes and monitor student activity on Chromebooks during class using a School Google Workspace account. Educational institutions may process Personal Information of children who are younger than 18 years of age using gScholar. The type of Personal Information that may be collected from students and used, stored, and disclosed by educational institutions includes Identifiers, Internet or Other Similar Network Activities, and gScholar Data. Students are not able to make Personal Information publicly available themselves.

Otherwise, we do not offer our services or promote the Promevo Services to, nor do we intentionally collect or retain Personal Information from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.

How We Collect Information

The information we collect depends on what you do when you visit or utilize the Promevo Services. We collect Personal Information and Deidentified Information in various ways:

  1. Information you provide - When you enable your organization for Promevo gPanel for Google Apps, gScholar, or other Promevo service or promotion that requires registration, we may ask you for Personal Information (such as your name, email address, address and an account password). For certain services where credit card information is requested, Promevo does not store credit card information in our systems; such information is processed by a PCI compliant third party payment processor. We may combine the information you submit under your account with information from other Promevo Services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
  2. Through Use of the Promevo Services - We may collect PII and Deidentified Information that the Promevo Services and your browser transmits when you navigate the Promevo Services. We may also collect Deidentified Information about how you access and interact with the Promevo Services through the use of automated tracking technologies, such as session cookies, persistent cookies, and web beacons.
  3. Log information - When you access Promevo Services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
  4. User communications - When you send email or other communications to Promevo, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
  5. Affiliated Promevo Services on other sites - We offer some of our services on or through other websites. Personal information that you provide to those sites may be sent to Promevo in order to deliver the service. We process such information under this Privacy Policy. The affiliated sites (such as appspot.com) through which our services are offered may have different privacy practices and we encourage you to read their privacy policies.
  6. Third Party Applications - Promevo may make available third party applications (for example, helpdesk functions and internet-based text chat) through its services. The information collected by Promevo when you use a third party application from within the Promevo Services is processed under this Privacy Policy. Information collected by the third party application provider is governed by their privacy policies.
  7. Links - Promevo may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology, customized content and advertising.

How We Use Information

We may use your Personal Information for lawful business purposes: (i) as necessary for the performance of our contract with you (such as our Terms of Use), (ii) for our legitimate interests, so long as they are not overridden by your own rights and interests, or (iii) as required by law as described in this Privacy Policy and/or supplementary privacy notices for specific services. These purposes include:

  1. Enhancing user experiences by combining the information you submit under your account with information from other Promevo Services or third parties in order to provide you with a better experience and to improve the quality of our services;
  2. Facilitating communications with users to process your inquiries, respond to your requests and improve our services;
  3. Providing our services, including the display of customized content and advertising;
  4. Auditing, research and analysis in order to maintain, protect and improve our services;
  5. Ensuring the technical functioning of our network;
  6. Protecting the rights or property of Promevo or our users; and
  7. Developing new services.

You can find more information about how we process Personal Information by referring to the supplementary privacy notices for particular services, where applicable.

In addition, Personal Data collected through gScholar may be used by educational institutions (including teachers and administrators) for classroom management purposes and to evaluate student interactions on their respective Chromebook.

Choices for Personal Information

We will not collect or use Personal Information for purposes other than those described in this Privacy Policy and/or in the supplementary service privacy notices, without providing you notice. If we propose to use Personal Information for any purposes other than those described in this Privacy Policy and/or in the specific service privacy notices, we will offer you an effective way to opt out of the use of Personal Information for those other purposes. You can decline to submit Personal Information to any of our services, in which case Promevo may not be able to provide those services to you.

Use of Cookies

When you interact with our websites and Promevo Services, we try to make that experience simple and meaningful. When you visit our website(s), our web server sends a cookie to your computer. Cookies are files that web browsers place on a computer’s hard drive and are used to indicate whether you have visited the website(s) previously. The data collected may include how you navigate around a web page and the most commonly clicked links on a specific web page. Certain technical information, such as your browser version and operating system, are also collected. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set (each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences). We use cookies for a number of purposes, including to: access a customer’s account information when a customer logs into a website, so that we can provide the customer with customized content, keep track of preferences you specify while you are using the Promevo Services, and to estimate and report total audience size (unique users) and traffic for our websites, and to conduct research to improve the content and services of our websites.

Web Beacons

We may use web beacons (also known as clear GIFs) to access cookies and count users who visit our websites or open our HTML-formatted email messages. Web beacons are single-pixel graphic files with a unique identifier, similar to cookies. Web beacons are embedded invisibly on web pages and emails and are stored on a user’s hard drive. You can modify your browser settings to control web beacons.

Behavioral Targeting/Re-Targeting

We partner with third party ad networks to either display advertising on our websites or to manage our advertising on other websites. Our ad network partners may use cookies and web beacons to collect non-personally identifiable information about your activities on our websites and other websites to provide you targeted advertising based upon your interests.

How We Disclose Information

Promevo only shares Personal Information with other companies or individuals outside of Promevo as described below. Otherwise, we do not sell Personal Information and will not disclose your Personal Information to third parties without your permission.

  1. When we have your consent. We require opt-in consent for the sharing of any Sensitive Personal Information.
  2. We provide such information collected through the Promevo Services to our subsidiaries, affiliated companies or other trusted businesses, service providers, or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
  3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Promevo, its users or the public as required or permitted by law.

If Promevo becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any Personal Information involved in such transactions and provide notice before Personal Information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular advertisement, or how many total users have subscribed to a Promevo service. Such information does not identify you individually unless otherwise arranged with you via a separate agreement.

We do not share Personal Data collected through gScholar except with service providers (i.e., Google) in order to deliver the services.

Please contact us at the address below for any additional questions about the management or use of your Personal Information.

Type of Information Disclosed

In the last twelve (12) months, we have disclosed the following categories of Personal Information to third parties for a business purpose: Identifiers; Categories of Personal Information listed in the CA Consumer Customer Records law; Internet or Other Similar Network Activities; and Geolocation Data.

Information Security

We take appropriate security measures to ensure your Personal Information is treated securely and in accordance with this Privacy Policy and in accordance with applicable law, and to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Personal Information. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store Personal Information.

We restrict access to Personal Information to Promevo employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Despite our efforts regarding security, it is important to bear in mind that the Internet is not a secure means of communication. Personal Information communicated through the Internet may be intercepted by other people. We cannot guarantee the security of Personal Information sent to us through the Promevo Services. You accept that you use the Promevo Services at your own risk.

Data Integrity

Promevo processes Personal Information only for the purposes for which it was collected and in accordance with this Privacy Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the Personal Information needed to provide or improve our services or as otherwise permitted under this Policy. We take reasonable steps to ensure that the Personal Information we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Information whenever necessary.

Your Responsibilities

With respect to your Promevo User Accounts, you are required to protect your passwords and take full responsibility for Your own, and third party, use of Your accounts. You are solely responsible for any and all activities that occur under your account. You agree to notify Promevo immediately upon learning of any unauthorized use of your account or any other breach of security.

When using the Promevo Services, you are responsible for protecting the privacy rights of your users under all applicable laws and regulations, including the GDPR, as they apply to your organization. Your administrators and delegates may have the ability to access, monitor, use, or disclose data available to users within the User Accounts. In order to use the Promevo Services, you agree to obtain and maintain the requisite consent from your users to your access, monitoring, use or disclosure of this data, and to Promevo providing you with the ability to do so. You are responsible for obtaining any necessary authorizations from your users to enable Promevo to provide our services.

Legal Rights

GDPR Data Subject Rights

If you are a data subject located in the European Economic Area (“EEA”), the GDPR grants you certain data privacy rights. Your rights include the:

  • Right to Access: You have the right to request a copy of your Personal Information.
  • Right to Rectification: You have the right to request that we correct any mistakes in your Personal Information.
  • Right to Erasure: You have the right to request that we delete your Personal Information.
  • Right to Restrict Processing: You have the right to restrict processing of your Personal Information.
  • Right to Object to Processing: You have the right to object to our processing or your Personal Information.
  • Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used and machine-readable format.

To exercise your rights, please use the Verifiable Consumer Request methods described below. Please be aware that your rights are limited to the extent permitted by the GDPR.

Please note that if a Verifiable Consumer Request effects the services that Promevo provides, Promevo will contact the data subject with information regarding what services will be effected prior to taking action on the data request.

Additional GDPR Privacy Rights

If you are a data subject located in the EEA, the GDPR grants you the right to lodge a complaint with a competent supervisory authority as well. To find a competent supervisory authority, please use the following resource: https://edpb.europa.eu/about-edpb/board/members_en.

CCPA California Resident Rights

If you are a California resident, the CCPA grants you certain data privacy rights. Your rights include the:

  • Right to Access: You have the right to request a copy of the specific pieces of Personal Information that we have collected about you in the previous twelve (12) months. The information will be delivered by mail or electronically. Upon receipt of a Verifiable Consumer Request, we will disclose:
    • The categories of Personal Information we have collected about you;
    • The categories of sources from which Personal Information is collected;
    • Our business purpose for collecting Personal Information;
    • The categories of third parties with whom we share Personal Information, if any; and
    • The specific pieces of Personal Information we have collected about you.
  • Right to Data Portability: You have the right to receive your Personal Information in a portable, readily usable format that allows you to transmit your information to another entity without hindrance.
  • Right to Deletion: You have the right request that we delete your Personal Information.
  • Right to Be Free from Discrimination: You have the right to not be discriminated against by us for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
    • Deny goods or services to you;
    • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    • Provide a different level or quality of goods or services to you; or
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise your rights, please use the Verifiable Consumer Request methods described below. Please be aware that your rights are limited to the extent permitted by the CCPA.

Please note that if a Verifiable Consumer Request effects the services that Promevo provides, Promevo will contact the California resident with information regarding what services will be effected prior to taking action on the data request.

Additional California Privacy Rights

California’s “Shine the Light” law permits Users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at the contact information provided below.

Verifiable Consumer Requests

If you are a California resident or a data subject located in the EEA, you can exercise your legal rights by submitting a Verifiable Consumer Request to us by:

  • Calling us at (888)380-1061; or
  • Contact our Data Protection Officer at dataprotectionofficer@promevo.com or at the address provided below.

Only you, or someone legally authorized to act on your behalf, may make a Verifiable Consumer Request related to your Personal Information. Making a Verifiable Consumer Request does not require you to create an account with us. California residents may only make a Verifiable Consumer Request for access to Personal Information twice in a 12-month period.

The Verifiable Consumer Request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a Verifiable Consumer Request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will acknowledge receipt of a Verifiable Consumer Request within ten (10) days. We endeavor to respond to Verifiable Consumer Requests within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the Verifiable Consumer Request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to Verifiable Consumer Requests, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Withdraw Consent

Generally, we do not process Personal Information based on consent. However, in the event we do, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on said consent before its withdrawal. If you would like to withdraw your consent, please contact our Data Protection Officer.

Accessing and Updating Personal Information

When you use Promevo Services, we make good faith efforts to provide you with access to your Personal Information to either correct this data if it is inaccurate, restrict our use or maintenance of such data if it is not otherwise required to be retained by law or for legitimate business purposes, or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You (including educational institutions) may make such a request by contacting our Data Protection Officer at the contact information provided below.

We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

If you do not wish to receive update messages and/or direct marketing communications from us, you may opt-out by making such changes through your User Account, following any instructions included in the communication or by contacting us at the contact information provided below. To help us process your request, please include sufficient information for us to identify you in our records. Please be aware that although you may opt-out of update messages and/or direct marketing communications, we reserve the right to email you administrative notices regarding the Site, as permitted under the CAN-SPAM Act.

We will make commercially reasonable efforts to respond to opt-out requests, respond to account cancellation requests, and handle requests to access, update, change, or delete PII as quickly as possible.

Cross Border Data Transfer

Promevo processes Personal Information on our servers in the United States of America and in other countries. In some cases, we process Personal Information on a server outside your own country. We may process Personal Information to provide our own services. In some cases, we may process Personal Information on behalf of and according to the instructions of a third party, such as our advertising partners.

If you are a data subject located in the European Economic Area (“EEA”), it may be necessary for us to share data subjects’ Personal Information outside the EEA to deliver the Promevo Services. We may share data subject Personal Information with Promevo affiliates and service providers located in the United States.       In the event we transfer Personal Information outside the EEA, we will take commercially reasonable measures to ensure the transfer complies with data protection laws and Personal Information is securely transferred. Our standard practice is to use standard contractual clauses approved by the European Commission to facilitate such data transfers. If you have any questions about our data transfer practices, please contact us at the contact information provided below.

Data Retention

We will retain your Personal Information while you maintain an account with us or to the extent necessary to provide Promevo Services. Thereafter, we will keep Personal Information for as long as necessary: (i) to respond to any queries from you; (ii) to demonstrate we treated you fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws. We delete Personal Information within a reasonable period after we no longer need the information for the purposes set out in this Privacy Policy.

Third Party Links

The Site may contain links to other websites or applications (“Linked Sites”) that are not owned by the Company.  We do not control the collection or use of any information, including Personal Information, which occurs while you visit Linked Sites. This Privacy Policy applies to Promevo Services only. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Site are framed within a page of the Site.

Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and the Company is not responsible for the privacy practices of those Linked Sites. The Linked Sites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. We encourage you to be aware of when you leave the Site and read the privacy policies of Linked Sites.

Enforcement

Promevo regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or Promevo’s treatment of Personal Information by contacting us through this website or by writing to us at

Privacy Information
c/o Promevo, LLC
1720 Wildcat Blvd, Suite 200
Burlington, Kentucky, 41005
USA

When we receive formal written complaints at this address, it is Promevo’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between Promevo and an individual.

Promevo Data Protection Officer

Promevo has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

Promevo LLC
Attn: Data protection officer
1720 Wildcat Blvd, Suite 200
Burlington, Kentucky, 4100
USA
dataprotectionofficer@promevo.com

Promevo reserves the right to modify the Promevo website and this Privacy Policy at any time, in particular to reflect changes in market conditions affecting Promevo activities, changes in technology, changes in relevant laws and regulatory requirements and changes in Promevo system’s capabilities. In the event that Promevo modifies this Privacy Policy, Promevo’s revised Privacy Policy shall be effective immediately upon the posting of such revised Privacy Policy on the website. Accordingly, we would recommend that you periodically re-review 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 (including, for certain services, email notification of Privacy Policy changes).

Contact Us

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this website or at:

Privacy Information
c/o Promevo, LLC
1720 Wildcat Blvd, Suite 200
Burlington, Kentucky, 41005
USA
(888) 380-1061
dataprotectionofficer@promevo.com 

Unless otherwise specified in this Privacy Policy, no other operators or entities may collect or maintain Personal Information from children through the Promevo Services.