Privacy Policy
In short. We collect only what we need to run our website and our services for business clients. Our public website sets no cookies and does not store your IP address; our checkout records it only as proof that you accepted our Terms. We never sell personal information and we do not use it for third-party advertising.
Contents
1. Who is responsible
The controller of your personal data is Luca Pugliese, a sole proprietorship registered in Italy and trading as Promote Center, VAT number IT04877990400, Via Giacomo Leopardi 1, 20021 Bollate (MI), Italy (“we”, “us”). For any privacy question, write to [email protected].
2. What this policy covers
This policy explains how we handle personal data when you:
- visit our website, promotecenter.com;
- contact us, place an order or use our client area and checkout;
- work with us as a client or as a client's representative;
- receive a business email from us about our services;
- click a Promote Center tracked link in a creator's content.
If you are a content creator, a separate Creator Privacy Notice explains how we handle your data; we provide it when we first contact you.
3. What we collect and why
3.1 Website visitors
Our website sets no cookies and stores nothing on your device. To count visits, our server computes a pseudonymous code from your IP address, browser and a random value that changes every day. The IP address itself is never stored, and the code cannot be linked to you on a different day. We record the pages viewed and the referring website with that code. Detailed records are deleted after 90 days; after that we keep only daily totals. Our hosting and network providers may keep short-lived technical logs to protect the service.
3.2 Contact form and emails
When you write to us, we collect your name, email address, company and message, and we use them to reply. The form uses anti-abuse checks that do not rely on third-party services.
3.3 Clients and their representatives
When you order or work with us, we collect:
- contact and business details: name, business name, email, phone, billing address, country and tax identifiers;
- account data: your login email and a password, which we store only in hashed form, plus access logs;
- campaign data: your brief, approvals, feedback, messages and the reports we prepare for you;
- order and payment data: what you bought, amounts, payment status and invoices. Card payments are handled by our payment processor; we never receive your full card number;
- acceptance records: the version of our Terms you accepted, with date, time, IP address and browser, as proof of the contract;
- store data, if you connect your online store: the product and order information needed to send products to creators.
We use this data to provide the services, manage payments, invoices and taxes, keep accounting records, communicate with you and protect our legal rights.
3.4 Business prospects
We may email businesses in the United States about our services, using business contact details from public sources such as company websites and professional profiles. Every such email identifies us, links to this policy and tells you how to stop receiving them, and we honor your request promptly. If you ask, we tell you where we found your details. We do not send marketing emails to people in the European Union or the United Kingdom without their consent.
3.5 People who click a tracked link
When you click a Promote Center tracked link, our server records the time of the click, the domain of the website you came from and a pseudonymous code derived from network and browser data that changes every day. We do not store your IP address and we do not set cookies. We use these records to count valid clicks and exclude bots. After a set period (currently 90 days) we keep only daily totals.
3.6 AI and research tools
To prepare strategy documents and campaign analyses, we may use software tools, including AI services, to process your brief and public information about your brand and market. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you.
3.7 Do you have to give us your data?
No. However, we need your contact, business, billing and account details to accept an Order, issue invoices and provide the services; without them we cannot do so. On the contact form, we need your name, email and message to reply.
4. Legal bases
If the EU General Data Protection Regulation (GDPR) applies, we rely on these legal bases:
| Purpose | Legal basis |
|---|---|
| Providing the services, managing orders, payments and the client area | Performance of a contract, or steps taken at your request before a contract (Art. 6(1)(b)) |
| Invoices, accounting and tax records | Legal obligation (Art. 6(1)(c)) |
| Replying to messages, website statistics, security, fraud prevention, tracked-link counts, proof of acceptance and defense of legal claims | Legitimate interests (Art. 6(1)(f)): running a secure business and measuring campaigns |
| Business emails to prospects | Legitimate interests (Art. 6(1)(f)); you can object at any time |
5. Who receives your data
We share personal data only as needed, with:
- service providers acting on our behalf: website and platform hosting (Hostinger); network, DNS and bot protection (Cloudflare); business email (mailbox.org and Google Workspace); AI, data and audience-research tools (such as OpenAI, Apify and SparkToro); shipment tracking (17TRACK);
- your online store platform (such as Shopify), which we access on your behalf when you connect your store;
- payment and banking providers: our payment processor (Stripe), any other payment provider you choose at checkout, and our bank (Wise). Some of them also act as independent controllers, for example to prevent fraud and meet legal duties, under their own privacy policies;
- creators working on your campaign, who receive the brand and campaign information they need; they do not receive your personal contact details unless needed for the campaign;
- our accountant and professional advisers, and the Italian tax authorities through the national electronic invoicing system;
- authorities or courts, when the law requires it, and a buyer or successor if our business is transferred.
We do not sell personal information and we do not share it for third-party advertising.
6. International transfers
Some providers process data outside the European Economic Area, for example in the United States. When they do, we rely on an adequacy decision of the European Commission, such as the EU-US Data Privacy Framework for certified companies, or on the European Commission's Standard Contractual Clauses. You can ask us for a copy of these safeguards.
7. How long we keep data
| Data | How long |
|---|---|
| Contracts, orders, invoices, acceptance records and accounting records | 10 years after the end of the year they refer to, as Italian law requires |
| Client account and campaign data | For the duration of the relationship, then up to 10 years for legal claims |
| Messages from people who did not become clients | 24 months after the last contact |
| Business contact details of prospects | 24 months after our last email, if you do not become a client |
| Website visit details and tracked-link click details | 90 days, then daily totals only |
| Requests to stop receiving emails | For as long as needed to honor them |
8. Your rights
You can ask us to access, correct or delete your personal data, to restrict its use, or to receive it in a portable format. You can object at any time to processing based on our legitimate interests, including business emails. We reply within one month. To exercise your rights, write to [email protected]. You also have the right to lodge a complaint with a data protection authority; in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it).
9. US state privacy rights
Depending on the state where you live, you may have the right to know what personal information we hold about you, to correct or delete it and to opt out of its sale or sharing. We do not sell personal information and we do not share it for cross-context behavioral advertising. We use sensitive personal information, such as your account login and password, only to provide the services and keep your account secure, and not to infer characteristics about you. You can make any request by writing to [email protected]; if we decline it, you can appeal by replying to our answer. We will not treat you differently for exercising your rights.
10. Security
We protect personal data with technical and organizational measures, including encrypted connections, hashed passwords, encrypted storage of access keys, access limited to what each person needs and activity logs. No system is perfectly secure; if a breach affects your data, we will inform you as the law requires.
11. Children
Our services are for businesses and are not directed to people under 18. We do not knowingly collect personal data from children.
12. Changes and contact
We may update this policy. The date at the top shows the latest version, and we will tell clients about important changes by email. For any question, write to [email protected] or to Luca Pugliese, Via Giacomo Leopardi 1, 20021 Bollate (MI), Italy. See also our Cookie Policy.