This Privacy Policy informs You about Your rights to privacy and your legal protections, as well asOur policies and processes regarding the collection, use, and sharing of Your information when youuse the Website.
Your personal information is used by us to operate and enhance the website. You consent to thecollection and use of information on this website in line with this privacy policy by using the website.
Definitions and Interpretation

DefinitionsIn the context of this privacy statement:Account refers to a special account that has been made for You so that You can access certain areasof our website.Affiliate means an entity that controls, is controlled by or is under common control with a party, where"control" means ownership of 50% or more of the shares, equity interest or other securities entitledto vote for election of directors or other managing authority.Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collectsConsumers' personal information and determines the purposes and means of the processing ofConsumers' personal information, or on behalf of which such information is collected and that alone,or jointly with others, determines the purposes and means of the processing of consumers' personalinformation, that does business in the State of California.CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by theCalifornia Privacy Rights Act of 2020 (the "CPRA").Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers toPromindelta.For the purpose of the GDPR, the Company is the Data Controller.Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.A resident, as defined in the law, includes (1) every individual who is in the USA for other than atemporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outsidethe USA for a temporary or transitory purpose.Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to theCompany as the legal person which alone or jointly with others determines the purposes and meansof the processing of Personal Data.Device means any device that can access the Website such as a computer, a cellphone or a digitaltablet.GDPR refers to EU General Data Protection Regulation.Personal Data is any information that relates to an identified or identifiable individual.For the purposes of GDPR, Personal Data means any information relating to You such as a name,an identification number, location data, online identifier or to one or more factors specific to thephysical, physiological, genetic, mental, economic, cultural or social identity.For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relatesto, describes or is capable of being associated with, or could reasonably be linked, directly orindirectly, with You.

Website Provider means any natural or legal person who processes the data on behalf of theCompany. It refers to third-party companies or individuals employed by the Company to facilitate theWebsite, to provide the Website on behalf of the Company, to perform services related to the Websiteor to assist the Company in analyzing how the Website is used. For the purpose of the GDPR,Website Providers are considered Data Processors.Usage Data refers to data collected automatically, either generated by the use of the Website or fromthe Website infrastructure itself (for example, the duration of a page visit).Website refers to Promindelta, accessible from http://www.Promindelta.comYou means the individual accessing or using the Website, or the company, or other legal entity onbehalf of which such individual is accessing or using the Website, as applicable.Under GDPR, You can be referred to as the Data Subject or as the User as you are the individualusing the Website.

Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Website, We may ask You to provide Us with certain personally identifiableinformation that can be used to contact or identify You. Personally identifiable information mayinclude, but is not limited to:
Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Usage Data is collected automatically when using the Website.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IPaddress), browser type, browser version, the pages of our Website that You visit, the time and dateof Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Website by or through a mobile device, We may collect certain informationautomatically, including, but not limited to, the type of mobile device You use, Your mobile deviceunique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobileInternet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Website or whenYou access the Website by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Website and storecertain information. Tracking technologies used are beacons, tags, and scripts to collect and trackinformation and to improve and analyze Our Website.

The Company may use Personal Data for the following purposes: to supply and manage our website, including keeping an eye on how it is being used.To manage Your Account: To manage Your online user registration. You may be able to accesscertain website functionality that are only accessible to registered users with the help of the PersonalData you submit.

To communicate with You: To communicate with You by email, phone calls, SMS, or othercomparable electronic communication channels, like push alerts for updates or educational materialsfrom a mobile application.To send you news, promotions, and general details about other products, services, and events thatwe offer and that are comparable to those that you have already bought or inquired about.To handle Your inquiries: to respond to and oversee Your demands made of Us.For more uses: We might employ Your information for additional uses, like data analysis, spottingusage patterns, gauging the success of our marketing initiatives, and assessing and enhancing ourwebsite, goods, services, marketing, and user experience.

We may share Your personal information in the following situations:With Website Providers: In order to contact You and to track and evaluate how our website is used,we may disclose Your personal information to Website Providers.For business transfers: In the course of negotiating or in conjunction with a merger, the sale ofcompany assets, financing, or the acquisition of all or a portion of Our business by another entity,We may share or transfer Your personal information.With Affiliates: In the event that we disclose Your information to one of our affiliates, we will demandthat they abide by this privacy policy. Our parent company, any further subsidiaries, joint venturepartners, and any other businesses that We control or that share control with Us are consideredaffiliates.With business partners: In order to provide You with certain goods, services, or promotions, We maydisclose Your information to Our business partners.With other users: Any personal information you exchange or otherwise deal with other users in publicplaces could be seen by all users and could even be shared publically outside.With Your consent: If you give us permission, we may use your personal information for any otherreason.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Website, or We are legally obligated to retain this data for longer time periods.Transfer of Your Personal DataYour information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.Delete Your Personal DataYou have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.Our Website may give You the ability to delete certain information about You from within the Website.You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.Disclosure of Your Personal DataBusiness TransactionsIf the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.Law enforcementUnder certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).Other legal requirementsThe Company may disclose Your Personal Data in the good faith belief that such action is necessary to:Comply with a legal obligationProtect and defend the rights or property of the CompanyPrevent or investigate possible wrongdoing in connection with the ServiceProtect the personal safety of Users of the Website or the publicProtect against legal liabilitySecurity of Your Personal DataThe security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.GDPR PrivacyLegal Basis for Processing Personal Data under GDPRWe may process Personal Data under the following conditions:Consent: You have given Your consent for processing Personal Data for one or more specific purposes.Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.Your Rights under the GDPRThe Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.You have the right under this Privacy Policy, and by law if You are within the EU, to:Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Website.Exercising of Your GDPR Data Protection RightsYou may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.CCPA/CPRA Privacy NoticeThis privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.Categories of Personal Information CollectedWe collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.Category A: Identifiers.Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.Collected: Yes.Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.Collected: Yes.Category C: Protected classification characteristics under California or federal law.Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).Collected: No.Category D: Commercial information.Examples: Records and history of products or services purchased or considered.Collected: No.Category E: Biometric information.Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.Collected: No.Category F: Internet or other similar network activity.Examples: Interaction with our Website or advertisement.Collected: Yes.Category G: Geolocation data.Examples: Approximate physical location.Collected: No.Category H: Sensory data.Examples: Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.Category I: Professional or employment-related information.Examples: Current or past job history or performance evaluations.Collected: No.Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.Collected: No.Category K: Inferences drawn from other personal information.Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Collected: No.Category L: Sensitive personal information.Examples: Account login and password information, geolocation data.Collected: Yes.Under CCPA/CPRA, personal information does not include:Publicly available information from government recordsDeidentified or aggregated consumer informationInformation excluded from the CCPA/CPRA's scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial dataPersonal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994Sources of Personal InformationWe obtain the categories of personal information listed above from the following categories of sources:Directly from You. For example, from the forms You complete on our Website, preferences You express or provide through our Website.Indirectly from You. For example, from observing Your activity on our Website.Automatically from You. For example, through cookies We or our Website Providers set on Your Device as You navigate through our Website.From Website Providers. For example, or other third-party vendors that We use to provide the Website to You.Use of Personal InformationWe may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:To operate our Website and provide You with Our Website.To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Website.To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Website, We will use that personal information to respond to Your inquiry.To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.For internal administrative and auditing purposes.To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.Other one-time uses.Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.Disclosure of Personal InformationWe may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:Category A: IdentifiersCategory B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Category F: Internet or other similar network activityPlease note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.Share of Personal InformationWe may share, and have shared in the last twelve (12) months, Your personal information identified in the above categories with the following categories of third parties:Website ProvidersOur affiliatesOur business partnersThird party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to YouSale of Personal InformationAs defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.We do not sell personal information as the term sell is commonly understood. We do allow Website Providers to use Your personal information for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.We may sell and may have sold in the last twelve (12) months the following categories of personal information:Category A: IdentifiersCategory B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Category F: Internet or other similar network activityPlease note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of Our knowledge that some of that information from the applicable category may be and may have been shared for value in return.Sale of Personal Information of Minors Under 16 Years of AgeWe do not knowingly collect personal information from minors under the age of 16 through our Website, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You: The categories of personal information We collected about YouThe categories of sources for the personal information We collected about YouOur business or commercial purposes for collecting or selling that personal informationThe categories of third parties with whom We share that personal informationThe specific pieces of personal information We collected about YouIf we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You: The categories of personal information categories soldThe categories of personal information categories disclosedThe right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact Us.The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct our Website Providers to correct) Your personal information, unless an exception applies.The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.The right to delete Personal Data. You have the right to request the deletion of Your Personal Data under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Website Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Website Providers to: Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.Debug products to identify and repair errors that impair existing intended functionality.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.Comply with a legal obligation.Make other internal and lawful uses of that information that are compatible with the context in which You provided it.The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by: Denying goods or services to YouCharging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penaltiesProviding a different level or quality of goods or services to YouSuggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or servicesExercising Your CCPA/CPRA Data Protection RightsPlease see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us:By email: [email protected] You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.Your request to Us must:Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representativeDescribe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to itWe cannot respond to Your request or provide You with the required information if We cannot:Verify Your identity or authority to make the requestAnd confirm that the personal information relates to YouWe will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal InformationAs defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.We do not sell personal information as the term sell is commonly understood. We do allow Website Providers to use Your personal information for the business purposes described in Our Privacy Policy, and these may be deemed a sale under CCPA/CPRA.You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

Limit the Use or Disclosure of My Sensitive Personal InformationIf You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average Consumer who requests such services or goods.We collect, use and disclose sensitive personal information in ways that are necessary to provide the Website. For more information on how We use Your personal information, please see the "Use of Your Personal Data" section or contact us.

Children's PrivacyOur Website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other WebsitesOur Website may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy PolicyWe may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.We will let You know via email and/or a prominent notice on Our Website, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

However if you are still looking for more information then you can contact us by Email: [email protected].