Last Updated: November 4, 2024

Promotino Ltd. (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use DrivePassword (“App”) and visit our websites at app.drivepassword.com and drivepassword.com (“Websites”). It also describes your rights and choices regarding your data.

If you have any questions, please contact us at [email protected].

1. Information We Collect

1.1 Information You Provide

We collect information that you voluntarily provide when you:

  • Register an account
  • Request support
  • Purchase a plan
  • Request information or materials
  • Participate in promotions, contests, or giveaways
  • Submit questions or comments

The information we collect includes:

  • Name
  • Email address
  • Billing information (e.g., billing address, payment details)
  • Usernames and passwords
  • Google User Data: Google Account email address, profile picture, and access to Google Drive for encrypted storage

1.2 Information Automatically Collected

When you visit our Websites or use our App, we automatically collect certain information, including:

  • Log and Usage Data: IP address, browser type, pages visited, and other diagnostic data
  • Device Data: Information about your device, including model, operating system, and settings
  • Cookies and Similar Technologies: See Section 8 for more details

2. How We Use Your Information

We use your information to:

  • Provide and maintain our App and Websites
  • Process transactions and manage your account
  • Authenticate your identity and manage access to your Google Drive
  • Respond to inquiries and provide customer support
  • Send administrative updates
  • Improve our products and services
  • Send marketing communications, if opted in
  • Enforce our terms and comply with legal obligations

3. Sharing Your Information

We are committed to keeping your information private. We do not sell, rent, or lease your information. We may share your data in the following cases:

  • Service Providers: We work with third-party providers (e.g., payment processors, hosting services, and analytics providers like Google Analytics) to support our App and Websites.
  • Legal Requirements: We may disclose your data to comply with legal obligations or in response to lawful requests.
  • Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred.

3.1 Google User Data Sharing

We do not share your Google User Data with third parties except as necessary to provide our services:

  • Firebase Crashlytics: For crash reporting to improve App stability.
  • Google Analytics: To analyze website traffic and user interactions.

Our service providers are obligated to keep your Google User Data confidential and use it only for their designated purpose.

4. Data Protection and Security

We take reasonable measures to protect your data from unauthorized access or misuse. Our security practices include:

  • Encryption: Sensitive data, including Google User Data, is encrypted using AES-256 before storage in Google Drive.
  • Secure Authentication: OAuth 2.0 is used for secure authentication with Google services.
  • HTTPS: We use secure protocols for data transmission.
  • Access Controls: Only authorized personnel have access to your information.
  • Regular Audits: We conduct security assessments to address vulnerabilities.
  • Employee Training: Our team members receive regular training on data protection practices.

Please avoid sending sensitive information, like payment details, via unsecured channels.

5. Data Retention and Deletion

5.1 Retention of Personal Information

We retain your information only as long as necessary to fulfill the purposes in this Privacy Policy or as required by law.

5.2 Deletion of Personal Information

You may request the deletion of your personal information by contacting us at [email protected]. We will delete or anonymize your information unless retention is required by law.

5.3 Retention of Google User Data

We retain Google User Data only while your account is active or as needed to provide services. If your account is inactive for 24 months, we will delete this data.

5.4 Deletion of Google User Data

To request deletion of your Google User Data:

  • Contact: Email us at [email protected].
  • Revoke Access: You may also revoke access via your Google Account settings.
  • Process: Upon request, we will revoke access and delete any stored Google User Data within 30 days.
  • Confirmation: We will confirm deletion by email.

6. Compliance and Enforcement

We periodically review our compliance with this Privacy Policy. If you have concerns about our data practices, please contact us. We will investigate and address any issues.

7. Links to Other Sites

Our Websites may include links to third-party websites. We are not responsible for the privacy practices of these sites and encourage you to review their privacy policies.

8. Cookie Policy

We use cookies and similar technologies on our Websites to improve your experience:

  • Session Cookies: These expire when you close your browser.
  • Persistent Cookies: These remain on your device until deleted or expired.

We also use third-party cookies (e.g., Google Analytics) for analytics purposes. You can manage cookie settings in your browser. We do not currently respond to “Do Not Track” signals due to the lack of a standard.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The revised version will be posted on this page with an updated “Last Updated” date. We encourage you to review this Privacy Policy for updates.

10. Compliance with Google API Services User Data Policy

Our use of Google API information complies with the Google API Services User Data Policy, including the Limited Use requirements.

11. Your Rights and Choices

Depending on your location, you may have rights regarding your information, including:

  • Accessing and Updating: You can access and update your account information by logging in to your account settings.
  • Opting Out of Marketing: You can unsubscribe from marketing communications via the link in our emails.
  • Requesting Deletion: You may request deletion of your personal data by contacting us.

12. International Data Transfers

Your information may be transferred to servers located outside of your country. By providing your information, you consent to its transfer and processing in countries where we or our service providers operate, with safeguards in place.

13. Children’s Privacy

Our App and Websites are not intended for children under 13, and we do not knowingly collect data from children under 13. If we learn that we have collected such data, we will delete it promptly.

14. Contact Us

For questions about this Privacy Policy, contact us at:

  • Email: [email protected]
  • Postal Mail: Promotino Ltd., Mladost 1A 537, Sofia, 1729, Bulgaria

By using our App or Websites, you acknowledge that you have read and understood this Privacy Policy.