Privacy Policy

Any information is subject to copyright law and data protection. Promona Ltd on behalf of Hanway London [the Hanway] will never sell or knowingly hand over any personal information collected including e-mail addresses or other information. See our new GDPR updated Data policy below - 

PROMONA LIMITED.

Privacy Policy

Modified 20 Jan 2021

Our privacy obligations

PROMONA ("Promona") is governed by the United Kingdom. The Freedom of Information Act 2000 regulate how personal information is handled by Promona Ltd. 

'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Promona’s Privacy Policy applies to personal information collected and/or held by Promona Ltd. 

This Privacy Policy also explains how we process 'personal data' about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR). 

We will review this policy regularly, and we may update it from time to time. 

The types of personal information we collect and hold

We collect personal information about our users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect. 

Not all information requested, collected, and processed by us is "Personal Information" as it does not identify you as a specific natural person. This will include majority of "User Generated Content" that you provide us with the intention of sharing with other users. Such "Non-Personal Information" is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency. 

In some situation users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and control and thus the information provided will not be governed by this privacy policy. 

In some situations users may provide us personal information over platforms that are outside our control; for example through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy. 

How we collect personal information

Information that you specifically give us

While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal. 

We may request, collect, or process the following information: 

• Account       Details - username, password, profile picture.
• Contact        Details - email address, phone number.
• Location      Details - physical address, billing address, timezone.
• Identity        Details - full name, proof of identity (e.g. drivers      licence, passport), proof of address (e.g. utility bill), photograph of the user.
• Financial      Information - credit card details, wire transfer details, payment processor details (e.g. paypal, iZettle), tax numbers.
• User Generated Content - project descriptions and attachments, description, user profiles, user reviews, contest descriptions and attachment, user messages etc.

Information that we collect from others

Users can give permission for us to connect to their account on other platforms to collect personal information. This includes but is not limited to Facebook, LinkedIn, Instagram, Twitter and Google. Information collected will be governed by this Privacy Policy. Users can stop us from collecting data from other platforms by removing our access on the other platform or by contacting our support team. 

Users have the ability to invite non-users to our platform by providing contact details such as e-mail address. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of the invite systems. 

Your payment provider may transmit information about the payment that we may collect or process. 

In some situations, personal information of users may be collected from public sources. 

We may collect or process the following information: 

• Basic           Details - username, profile picture.
• Contact      Details - email address, phone number.
• Location    Details - Physical Address, billing address, timezone.
• Financial   Information - payment account details (e.g. paypal, email address and physical address), and wire transfer details.
• List of contacts - e-mail provider address book.
• User Generated Content - user profile.

Information we collect as you use our service

We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button. 

In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data. 

When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used. 

We may collect or process the following information: 

• Metadata - IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
• Device Information - device identifier, device type, device plugins, hardware capabilities, etc.
• Location - GPS position.
• Actions - pages viewed, buttons clicked, time spent viewing, search keywords, etc.

Links to other sites

On our website, you will encounter links to third party websites. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy. 

How we use personal information

The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes: 

• to provide the service or product you have requested;
• to facilitate the creation of a User Contract (see Terms of Service for more information);
• to provide technical or other support to you;
• to answer enquiries about our services, or to respond to a complaint;
• to promote our other programs, products or services which may be of interest to you (You must actively opt-in unless you have opted out from such communications);
• to allow for debugging, testing and otherwise operate our platforms;
• to conduct data analysis, research and otherwise build and improve our platforms;
• to comply with legal and regulatory obligations;
• if  otherwise permitted or required by law; or
• for other purposes with your consent, unless you withdraw your consent for these purposes.

The 'lawful processing' grounds on which we will use personal information about our users are (but are not limited to): 

• when a user has given consent;
• when necessary for the performance of a contract to which the user is party;
• processing is necessary for compliance with our legal obligations;
• processing is necessary in order to protect the vital interests of our users or of another natural person.
• processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

When we disclose personal information

Our third party service providers

The personal information of users may be held or processed on our behalf outside United Kingdom, including 'in the cloud', by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions. 

Our third party service providers include: 

• Cloud hosting, storage, networking and related providers
• SMS providers
• Payment and banking providers
• Marketing and analytics providers
• Security providers

Third party applications

Through the Promona website or and any other platforms it is possible for users to grant third party applications access to their Promona account. Depending on the permissions that are granted, these applications may be able to access some personal information or do actions on the users' behalf. These third party applications are not controlled by us and will be governed by their own privacy policy. Users are able to remove third party applications from access their data through their settings. 

Other disclosures and transfers

We may also disclose your personal information to third parties for the following purposes: 

• if necessary to provide the service or product you have requested;
• we receive court orders, subpoenas or other requests for information by law enforcement;
• if otherwise permitted or required by law; or
• for other purposes with your consent.

As we are a local company, with offices in the UK, your personal information may be processed by staff in any of our offices. Promona currently has offices in the United Kingdom.

Accessing, correcting, or downloading your personal information

You have the right to request access to the personal information Promona holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be requested in writing. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer. 

You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support. 

Exercising your other rights

You have a number of other rights in relation to the personal data Promona holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace - these data uses are protected against the below rights. 

You have the right to: 

• seek human review of automated decision-making or profiling
• opt-out of direct marketing, and profiling for marketing
• erasure
• temporary restriction of processing.

Human review of automated decision making / profiling - In the case of our ranking algorithms, it is not possible to exercise this right as this ranking is a fundamental part of the marketplace that users participate in, opting out would mean not being able to participate in the marketplace. Decisions affecting marketplace security are already reviewed by humans. 

Direct marketing and profiling - users can control what emails they receive through their e-mail responses to opt-out. 

Erasure - Most personal information and user generated content cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protecting other legitimate users of the marketplace. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.

Temporary restriction to processing - under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer. 

Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer. 

To contact our Privacy Officer

If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows: 

By Email: privacy@promona.co.uk

By Mail:
Attn: Privacy Officer
20-22, Wenlock Road
London, N.1 7GU 

For the purposes of the GDPR, our Privacy Officer is also our Data Protection Officer (DPO). 

While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days of receipt. 

If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the Office of the Information Commissioner (IOC) by calling them, making a complaint online at or writing to them.  https://ico.org.uk/global/contact-us/email/ 

If you are in the European Union, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. 

This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the responsible body for the data processing that occurs via this website has their basis outside of the European Economic area and Switzerland, then the associated Google Analytics data processing is carried out by Google LLC. Google Ireland Limited and Google LLC. will hereinafter be referred to as “Google”.

Google Analytics uses “cookies”, which are text files saved on the site visitor’s computer, to help the website analyze their use of the site. The information generated by the cookie (including the truncated IP address) about the use of the website will normally be transmitted to and stored by Google.

Google Analytics is used exclusively with the extension "_anonymizeIp ()" on this website. This extension ensures an anonymization of the IP address by truncation and excludes a direct personal reference. Via this extension Google truncates the site visitor’s IP address within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional situations will the site visitor’s full IP address be transmitted to Google servers in the United States and truncated there. The IP address, that is provided by the site visitor’s browser in using Google Analytics will not be merged by Google with other data from Google.

On behalf of the site operator, Google will use the information collected to evaluate the use of the website, to compile reports on website activity and to provide other website and internet related services to the site operator (Art. 6 (1)( f) GDPR). The legitimate interest in data processing lies in the optimization of this website, the analysis of the use of the website and the adaptation of the content. The interests of the users are adequately protected by the pseudonymization of their data.

Google LLC. offers a guarantee to maintain an adequate level of data protection on the basis of European standard contractual clauses. The data sent and linked to the Google Analytics cookies, e.g. user IDs or advertising IDs will be automatically deleted after 50 months. The deletion of data whose retention period has been reached is carried out automatically once a month.

The website visitor may refuse the use of cookies by selecting the appropriate settings in their browser. The website visitor can also prevent Google from collecting information (including their IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout

The website visitor can prevent data collection via Google Analytics on this website by clicking here. An "Opt-out Cookie" shall then be applied which shall prevent any future collection of the site visitors data when visiting this website.

Further information concerning data processing and use by Google, the settings and deactivation possibilities can be found in the Google Privacy Policy (https://policies.google.com/privacy) as well as in the Google Ads Settings (https://adssettings.google.com/authenticated).

We use the reCAPTCHA service provided by Google LLC (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.
This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google's privacy policy, please visit: https://policies.google.com/privacy?hl=en
By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

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