Last Updated: 31 January 2023
2. KEY DEFINITIONS
“European Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable national legislation implementing the GDPR and, if applicable, the UK Data Protection Act 2018 and the UK GDPR.
“Prowly”, “we”, “us” and/or “our” refers to Prowly.com Sp. z o. o., unless specified otherwise.
“Services” refers to our PR and media relations tools offered as software-as-a-service made available via our websites.
3. WHO WE ARE
Prowly is a corporation established in Poland. The Services enable public relations and media relations professionals to create and manage media lists, distribute press releases and measure their effects as well as maintain an online newsroom supporting their brand. The Services are available as a subscription service at prowly.com. As a part of the Services, Prowly also provides its customers with access to a database that contains information about Media Contacts from all over the world (the “Media Database”).
4. DATA CONTROLLER
Prowly is responsible for how your personal data is handled. This means we are the controller of your personal data under the GDPR, including personal data of Media Contacts included within the Media Database portion of the Services.
However, we act as a processor on behalf of our customers in relation to personal data that our customers may upload to our Services or make accessible to us through the use of APIs. We process this data pursuant to our customers’ instructions and subject to our agreements with our customers. If you have questions about how your personal data is processed by our customer, please contact that customer directly.
5. INFORMATION WE COLLECT
We collect data, including personal data, about you as you use our websites and Services or request our Services, and otherwise interact with us. Some of our websites’ functionality can be used without providing any personal data, though for using some features of the Services, personal data is required. We process three broad categories of personal data:
- Information you provide us;
- Information we receive from third parties; and
- Information we collect automatically.
Information You Provide Us
Communication with Prowly. We collect personal data that you voluntarily give us when you contact us with inquiries (including by filling out relevant forms on our websites), engage with our chat bot on the website, respond to one of our surveys, contact our customer support regarding a problem you are experiencing with the Services or otherwise contact us regarding the website or the Services.
Transactions. We collect details of transactions you carry out using the Services including information you provide to enable us to fulfill your orders, which may include financial information such as your credit card number. As a paying user of the Services, we may receive your payment transaction details (for example, your name, the amount paid and the date of payment).
Payment Information. We collect payment and billing information when you register for certain paid Services. For example, upon registration we ask you to designate a billing representative, including name and contact information. You may also provide payment information, such as payment card details, which we collect via secure payment processing services. If you sign-up for a free trial account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to the Services.
Additional Payment Information. You may choose to provide additional information such as your VAT, additional billing address or name of the entity that you represent.
Identity Verification. In some cases (for example if you request a refund) we may ask you to provide us information such as your billing information (name, transaction ID, billing date, etc.), email address, login name, and if needed, information that verifies your identity, in accordance with applicable law.
Use of our blog or requesting content. If you use our blog, request content or register to participate in or receive information about any of our webinars or events, we may ask you to provide us with information such as your name, job title, photo or other information. By posting any information on publicly accessible blogs or other areas of our websites you acknowledge and agree that the data you provide on our websites would be visible to any member of the public who accesses the websites.
Testimonials. We collect and display personal testimonials of satisfied customers and users on the Services in addition to other endorsements. With your consent, we may post your testimonial, along with your name, on the Services. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Information We Receive From Third Parties
Media Database. If you are a Media Contact, we obtain personal data about you from third parties for use within our Media Database. We limit the data that we collect for use in the Media Database to that which we think is likely to enable our customers to engage with you in a meaningful and targeted way. Such personal data includes name, publicly available contact details (such as email, telephone), position, industry, photo (if publicly available), workplace (if publicly available), social media network links, topic areas covered and/or links to one or more of your publications.
Resellers, Affiliates. We may obtain personal data about you from our resellers or Affiliates, for example, if you purchase access to the Services through them. The personal data we may receive includes business contact information, including mailing addresses, job titles, email addresses, phone numbers.
Publicly Available Sources. We collect information from publicly accessible sites such as business directories and social media sites.
Information We Collect Automatically
Device and Usage Data. When users come to our website, we may track, collect, and aggregate information indicating, among other things, which pages of our websites were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our websites. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the website. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
Collection of Information from Google API Services. In order to enhance your experience with the Services’ content creator tool, you may grant us access to your Google Drive account through Google APIs. If you choose to connect your Prowly.com account with your Google Drive account, we will access the individual Google Drive files that you elect to share for the sole purpose of providing and improving your use of the Services, and allowing you to further edit and publish files through the Services.
6. HOW WE USE YOUR INFORMATION
We use the personal data we receive and/or collect as follows:
To provide the Services and related customer and/or technical support, process transactions, manage your user account, invoice you for the Services, and respond to your requests. This is necessary to perform the contract we are about to enter into or have entered into with you.
To pursue legitimate interests of Prowly or those of third parties, including customers and Media Contacts as follows:
- to provide you with the information that you request about our Services, scheduling a demo or enrolling you in a webinar, or to respond to other requests you may have about our Services (including sharing your personal data with our resellers as necessary to respond to your request for the Services in an efficient manner and facilitate the sale of our Services, as described in the ‘How We Share Your Information’ section below);
- to plan or host company events, online forums and social networking activities, such as our user conference or webinars about our Services or the products and services of our Affiliates;
- to operate and administer our websites;
- to manage our relationship with you, including sending administrative information to you, such as information regarding the website and changes to our terms, conditions, and policies;
- in relation to the personal data of Media Contacts, to grow the Media Database to help our customers improve the relevancy of their media outreach, further develop our customers’ business and to enable Media Contacts to be found by potential customers, as well as to help Media Contacts manage their online profiles to boost their online visibility. If at any time you want us to remove you from the Media Database, please contact us at email@example.com;
- to analyze trends and track your usage of and interactions with our websites and Services in order to improve or enhance your experience by providing you with more relevant content and service offerings, present our website content in a more effective manner for you and for your computer or device, and to help us develop new products and services (including to increase our Service’s functionality, product features, and user-friendliness);
- to prevent fraud or criminal activities, misuse of our Services and ensure the security of our IT systems, architecture and networks;
- to (a) comply with legal obligations and legal processes, (b) respond to requests from public and government authorities, including public and government authorities outside your country of residence, (c) enforce our Terms of Service, (d) protect our operations, (e) protect our rights, privacy, safety of property, and/or that of you or others, and (f) enable us to pursue available remedies or limit the damages that we may sustain.
To send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law we will only send you marketing information if you consent to us doing so at the time you provide us your personal data. You may opt-out of receiving such emails by following the instructions in each promotional email we send you or by updating your user settings. In addition, if at any time you wish not to receive future communications or you wish to have your name deleted from our mailing lists or Media Database, please contact us at firstname.lastname@example.org. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
7. HOW WE SHARE YOUR INFORMATION
Media Database Profiles. We make personal data in our Media Database available to our customers as part of the Services, to enable our customers to send out media releases to Media Contacts based on their profiles in the Media Database and to save a list of such Media Contacts. We make a limited amount of such personal data available to our website visitors in order to show our prospective customers the type of information in the Media Database.
Service Providers. We may engage other persons or entities to perform tasks on our behalf -- meaning they are helping us provide our Services. In particular, we use third party providers of payment processing, fraud prevention, and risk assessment, hosting and other information technology services, email communication and customer support services, analytics, marketing, and advertising. Following our instructions, these parties may process your personal data in the course of providing the relevant services to us.
- Semrush Inc. (Delaware registration number 5225683), 800 Boylston Street, Suite 2475, Boston, MA, 02199, U.S.A.
- Semrush CY LTD (registration No. HE 324428), Griva Digeni and Kolonakiou corner, Grosvenor tower, 2nd and 3rd floor, 3107 Neapolis, Limassol, Cyprus
- Semrush CZ s.r.o. (registration No. 04464800), Na Hřebenech II 1718/10, Nusle, 140 00 Praha, Czech Republic
- Semrush RS doo Beograd (registration No. 21791148), Bulevar Mihajla Pupina 115, floor - 1, Belgrade-Novi Beograd, 11000 Belgrade, Serbia
- Semrush AM Limited (registration No. 273.110.1232023), Mashtots Ave., 8/7, Kentron, Yerevan 0015, Armenia
- Semrush Development, S.L. (registration No. B67784736), Calle Tanger, 98, plantas 6a y 7a, 08018, Barcelona, Spain
- Semrush GmbH (registration No. HRB 276311), Elsenheimerstr. 7, ℅ RPI Roehm, 80687, Munich, Germany
- Semrush B.V. (registration number 8635.80.051), Prins Bernhardplein 200, 1097 JB Amsterdam, Netherlands
Marketing Partners. We may share your personal data with our marketing partners and resellers and with whom we may jointly offer products, services and programs (such as PR or other services, newsletters or web content); such marketing partners use the information we provide in accordance with their own privacy policies.
Social Networking Websites. Where permissible according to applicable law we may use certain limited personal data about you, such as your email address, to hash it and to share it with social network websites, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products or Services. The social network websites with which we may share your personal data are not controlled or supervised by us. Therefore, any questions regarding how your social network websites service provider processes your personal data should be directed to such a provider.
Business Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your personal data and other information may be transferred to a successor or Affiliate as part of that transaction.
Legal Requirements. We may share your personal data so that we can comply with a legal obligation to which we are subject, protect and defend the rights or property of Prowly, act in urgent circumstances to protect your personal safety or that of the public, or protect Prowly against legal liability, such as where we are obliged to share your personal data with regulatory bodies which govern our work and services; government departments such as law enforcement, courts orders; financial institutions; external auditors; etc.
8. DATA RETENTION
We retain your personal data for as long as reasonably necessary to provide the Services and fulfill the transactions you have requested, complying with our legal obligations or for other legitimate business purposes, such as maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. After the applicable retention period has elapsed, your personal data will be anonymized and deleted.
9. HOW WE PROTECT YOUR PERSONAL DATA
We have implemented physical, technical, and administrative security measures designed to protect personal data. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal data you provide to us. It is your responsibility to protect the security of your login information. If you know or suspect that your personal data have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your Prowly account, please immediately contact us by email at email@example.com.
10. YOUR CHOICES AND RIGHTS REGARDING YOUR PERSONAL DATA
If you are a user of the Services, you may access, review, modify and delete your account profile within the Services by going to your account and editing your information. For all other requests to access, review, modify, update, delete, or limit the use or disclosure of the personal data we hold about you, and to see or amend your Media Database profile, you must email your request to us at firstname.lastname@example.org.
Moreover, the GDPR grants data subjects the following rights:
- Access. You can request a copy of the personal data that we maintain about you. If you require additional copies, we may need to charge a reasonable fee.
- Deletion and Correction. You can ask us to delete or correct the personal data that we hold about you.
- Objection. You may have the right to object to how we use your personal data.
- Restrict Processing. You may ask us to suspend our processing of your personal data, for example, if you want us to establish its accuracy or the reason for processing it.
- Data Portability. If required to do so, we will give you your personal data in a structured, commonly used, and machine-readable format.
- Withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
To exercise these rights, please email email@example.com. You also have the right to complain to a data protection authority in your country about our processing of your personal data.
Our Services are not directed to children who are under the age of 16. We do not knowingly collect personal data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal data to us through the Services, please contact us at firstname.lastname@example.org and we will endeavor to delete that information from our databases.
12. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Prowly.com Sp. z o.o. is based in the European Union. Our Affiliates and service providers are based in countries outside the European Union and the United Kingdom (please read the Affiliates section above for more information). Please note that in connection with our business and for administrative, management and legal purposes, we may transfer your personal data from the European Union and the United Kingdom to our Affiliates and to our service providers in the United States, Armenia and Serbia. These countries may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. We have taken measures to protect your personal data where it is processed and your rights as a data subject , including through the use of Standard Contractual Clauses approved by the European Commission. If you would like to receive more information, please contact us as indicated below.
13. CONTACT INFORMATION
Prowly.com Sp. z o.o. ul. Antoniego Józefa Madalińskiego 71/1
02-549 Warszawa, Mazowieckie, Poland
Attention: General Counsel