1. Introduction

The Promo CMO, a sole proprietorship owned and operated by Robert Jay Hagel, Jr. ("we," "us," or "our") operates https://thepromocmo.com and provides marketing consulting services in the promotional products industry. We are committed to protecting your privacy and handling your personal information transparently and securely.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our services, visit our website, or interact with us. This policy applies to all users of our services, regardless of location.

Contact Information:
Business: The Promo CMO
Owner: Robert Jay Hagel, Jr.
Address: 9 Opera Lane, Aliso Viejo, CA 92656
Email: [email protected]
Phone: +1 949-806-5514

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us, including:

• Contact Information: Name, email address, phone number, business address
• Business Information: Company name, job title, industry details
• Account Information: Login credentials for our services
• Communication Data: Information in messages you send us
• Marketing Preferences: Communication preferences, interests
• Personal Details: Birthday (for relationship building purposes)
• Payment Information: Billing address, payment method details (processed securely through third-party processors)

2.2 Information We Collect Automatically

When you visit our website or use our services, we automatically collect:

• Usage Data: Pages visited, time spent, clicks, navigation patterns
• Device Information: IP address, browser type, device identifiers
• Location Data: General geographic location based on IP address
• Cookies and Tracking Data: As described in our Cookie Policy below

2.3 Information from Third Parties

We may receive information about you from:

• Business partners and referral sources
• Social media platforms (when you interact with our content)
• Data enhancement services (to improve our services)
• Public databases and directories

3. How We Use Your Information

We use your personal information for the following business purposes:

3.1 Service Delivery

• Providing marketing consulting services
• Managing client relationships and projects
• Communicating about our services
• Processing payments and billing

3.2 Marketing and Communications

• Sending promotional emails and newsletters
• SMS marketing (with your consent)
• Personalizing marketing content
• Conducting market research and analysis

3.3 Business Operations

• Improving our website and services
• Analyzing usage patterns and trends
• Preventing fraud and ensuring security
• Complying with legal obligations

3.4 AI and Automated Decision-Making

We use artificial intelligence tools (including OpenAI, Anthropic, and MerchAI) to:

• Analyze market trends and data
• Generate marketing insights and recommendations
• Improve service personalization
• Automate certain business processes

You have the right to request human review of automated decisions that significantly affect you.

4. Legal Basis for Processing (EU/UK Users)

Under GDPR and UK GDPR, we process your personal data based on:

• Consent: For marketing communications and non-essential cookies
• Contract: To perform our consulting services
• Legitimate Interests: For business operations, analytics, and service improvement
• Legal Obligation: To comply with applicable laws and regulations

5. How We Share Your Information

We may share your personal information in the following circumstances:

5.1 Service Providers

We share data with trusted third-party service providers, including:

• Analytics: Google Analytics for website performance
• AI Services: OpenAI, Anthropic, and MerchAI for business insights
• Payment Processors: Secure payment processing services
• Marketing Tools: Email and SMS marketing platforms
• Cloud Services: Data storage and processing providers

5.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

5.3 Legal Requirements

We may disclose your information when required by law, legal process, or to protect our rights and safety.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

6. International Data Transfers

As we serve clients globally, your personal information may be transferred to and processed in countries outside your residence, including the United States. When we transfer data internationally, we implement appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) for EU/UK transfers
• Adequacy decisions where available
• Other legally approved transfer mechanisms

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy:

• Active Client Data: During the term of our service agreement
• Post-Contract Data: Up to 2 years after contract termination
• Marketing Data: Until you withdraw consent or request deletion
• Legal Requirements: As required by applicable laws

8. Your Privacy Rights

8.1 All Users

• Right to access your personal information
• Right to correct inaccurate information
• Right to request deletion of your information
• Right to restrict processing
• Right to data portability

8.2 California Residents (CCPA/CPRA)

You have additional rights including:

• Right to know what personal information we collect
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising your rights
• Right to correct inaccurate personal information
• Right to limit use of sensitive personal information

Notice: We do not sell personal information in the traditional sense, but we may share information with partners for business purposes.

8.3 EU/UK Residents (GDPR)

Additional rights include:

• Right to object to processing
• Right to withdraw consent at any time
• Right to lodge a complaint with supervisory authorities

8.4 Canadian Residents (PIPEDA)

• Right to access personal information we hold about you
• Right to request correction of inaccurate information
• Right to withdraw consent for marketing communications

9. Exercising Your Rights

To exercise your privacy rights, contact us at:

• Email: [email protected]
• Phone: +1 949-806-5514
• Mail: 9 Opera Lane, Aliso Viejo, CA 92656

We will respond to your request within the timeframes required by applicable law (typically 30-45 days).

10. Cookies and Tracking Technologies

We use cookies, pixels, and similar technologies to:

• Essential functions (necessary for website operation)
• Analytics and performance monitoring
• Marketing and advertising personalization
• User experience enhancement

Cookie Management: You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

Third-Party Cookies: We use Google Analytics and other third-party services that may place cookies on your device.

11. Marketing Communications

11.1 Email Marketing

We send marketing emails based on your relationship with us and, where required, your consent. You can unsubscribe at any time using the link in our emails.

11.2 SMS Marketing

SMS marketing requires your explicit consent. Reply STOP to opt-out at any time.

11.3 Personalization

We may use your information to personalize marketing content and recommendations.

12. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Employee training on data protection
• Secure data processing agreements with vendors

13. Children's Privacy

Our services are designed for businesses and we do not knowingly collect personal information from individuals under 16 years of age. If we learn we have collected such information, we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the updated policy on our website
• Sending email notification to registered users
• Other appropriate communication methods

15. Supervisory Authority Contacts

EU Users: You may lodge complaints with your local data protection authority.
UK Users: Information Commissioner's Office (ICO) - ico.org.uk
Canadian Users: Office of the Privacy Commissioner of Canada - priv.gc.ca
California Users: California Attorney General - oag.ca.gov

16. Contact Information

For privacy-related questions or concerns, contact our privacy team:

The Promo CMO
Privacy Officer: Robert Jay Hagel, Jr.
Email: [email protected]
Phone: +1 949-806-5514
Address: 9 Opera Lane, Aliso Viejo, CA 92656