Version Web 1.1, December 2023


This Privacy Policy is intended to explain how information about you is collected and used when you enter Promotons (Italy), and our social media page (“Social Media”) on Facebook.


    Our Website allows you to browse the current offers and advertisements of selected retailers in a personalized manner, contact us directly, or otherwise interact with us.

    If you visit our Website or our Social Media, we may collect certain information about you that may be considered personal data. Below you will find detailed information about it and the purpose of such usage, as well as how to control your preferences.


    We may collect two main groups of data combined with your use of the Website or Social Media:

    • If you are posting comments on our Social Media or otherwise interacting with the content we publish (likes, follows, shares, survey answers, etc.). The scope of such information will depend on the type of interaction and may include: your name, content of messages you send us, etc. In Social Media, each message you send or post you publish will include the name of your Social Media profile, which is likely to be your full name, as well as your profile picture, the date of interaction, and a link to your Social Media profile.
    • Information is collected automatically by our Website, e.g. through cookies or other tracking technologies.

    Such information is recorded under a unique identification number (e.g. cookie ID) we assign to your browser or device and include (1) data related to your activity on a Website along with timestamps recording moment of particular events, (2) technical information about the browser or device you are using; (3) IP address indicating your non-specific geographic location e.g. country or region.

    This data does not directly disclose your identity – it only identifies the browser or device you use to enter our Website and allows us to measure the use of our Website and personalize its content and our ads to that browser or device, as described below.

    Please note that Social Media platforms may collect other data in connection with your use of those platforms. Please consult their privacy policies to learn more.


    We use the collected data to:

    • Answer your queries

    For this purpose we use the data you provide us voluntarily. For example, if you send us a message via a contact form available on our Website or in a direct message on Social Media, we will process your contact data and the content of such message to handle your query, provide you with relevant information and remember what the query was about.

    • Create profiles to personalize content, use profiles to select personalized content and use limited data to select content

    We realize the above data processing purposes to present you with properly personalized offers, based on factors like your localization, the shops you consider to be your favorite or what products you viewed. Also, we want the Website to remember if you are over 18 years old and can view the restricted product offers, such as alcohol. To achieve these purposes, we store and access information on your device.

    • Measure advertising and content performance

    We use third-party tools, such as Google Analytics to measure the offers, leaflets and advertisements that you see on our Website.

    Google Analytics uses the data stored in a cookie related to the device or browser, IP address and on-site activities to measure and report statistics about your interactions with our Website. Please note, that Google may link this information with data related to your activity from other sites that use Google Analytics. Learn more about Google Analytics.

    You may disable sharing your data with Google Analytics by adding to your browser an extension tool that blocks Google Analytics: Google Analytics Opt-out Add-on (by Google). To learn more about privacy at Google, see Google Privacy Policy.

    We may also use other third party analytics tools providers that track your actions on our Website, such as Hotjar software which creates a map of users’ clicks.

    On Social Media, we may contribute to processing of your personal data by the respective platforms, by requesting aggregated insight to your interactions with our Social Media pages. To learn more, please see the description of such processing at Facebook.

    We may also from time to time ask for your feedback by conducting surveys or inviting you to comment and share the content we publish on our Social Media.

    • Develop and improve our services

    The data collected about your usage of the Website can be used to improve it and to develop new products based on that data.

    • Create profiles for personalized advertising, use profiles to select personalized advertising, use limited data to select advertising

    We will record information concerning your use of our Website (e.g. which retailers’ offers you browsed) and based on the data collected this way we will create a profile of you to conduct personalized advertising campaigns of our Website or our mobile applications on third party digital properties. We will do this either by using our own technology or by tools provided by third parties.

    We will also personalize your experience on the Website as we assume you expect from us exactly to view the offers and ads that suit you best and are properly personalized. In order to record your activity on our Website, we will use tracking technologies such as our own (RTB House) or third parties’ advertising cookies.

    Third parties’ technology we use to conduct advertising activities include:

    Based on data collected this way we may conduct advertising campaigns either using our own technology or by tools provided by those third parties (e.g. Facebook Ads).

    You may allow the delivery of push notifications to your browser. Such campaigns are conducted based on your IP address and by using ‘cookie’ technology. Once you subscribe to receive notifications, we will send you them on a regular basis with current offers of selected retailers or other marketing materials. We use the services of Pushpushgo sp. z o.o. To send you these notifications. Click here to know more about Pushpushgo’s privacy practices.

    • Allow third-party partners to advertise on our Website

    We with Google (AdManager), to display third-party vendors’ ads on our Website in the scope of purposes they declare. These vendors will collect certain non-personally identifiable information about your browser and the page you are entering in order to place an ad there, as the page is loading. For more information on how digital advertising works, please check: (1) Google Privacy Policy where you can disable (opt-out from) personalized advertising; (2) review ad partners’ identities and privacy policies which you can access via the ‘consent banner’ that was presented to you upon opening the Website.

    We may also process your personal data to:

    • Understand audiences through statistics or combinations of data from different sources, for example when we will want to present the ad campaigns’ results to our advertising clients.
    • Defend our rights or pursue claims

      This may happen e.g. if you file a complaint regarding the operation of the Website, or in case we discover an external attack in our Website.

    • Ensure security, prevent fraud, and debug the Website

      Your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely.

    • Deliver and present advertising and content

      Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to your device.


    In order to lawfully process your personal data we need to have legal basis for such processing.

    The legal basis will depend on the particular operation of processing. It may be: (i) performing a contract with you, (ii) our legitimate interests (such as developing functionalities of the Website), or (iii) your consent for data processing.

    If you need further information concerning the legal basis for collection and use your personal information, please contact our Data Protection Officer at:


    In order to pursue the purposes indicated above your data may be shared with the following categories of third-party recipients:

    • affiliated companies

    We share data collected on the Website or the Social Media with our affiliated companies who are responsible for securely running the Website and the Social Media for us.

    • third party contractors

    For analytical and advertising purposes, we use tools provided by third parties. Please see section 3 to learn about the purposes of processing and find useful links.

    The data we process is stored in third party data centers.

    • competent authorities

    Your personal data may also be disclosed also to authorities which are competent by the applicable laws to receive such data, including law enforcement authorities.

    We carefully select third parties to whom your data may be disclosed, in particular we make sure they grant an appropriate level of privacy security to your data and process your data only for the intended purposes as well as in compliance with this Privacy Policy and the applicable laws.

    We will not transfer or permit any of your personal data to be transferred to a territory outside of the European Economic Area unless we have taken measures necessary to ensure the transfer is in compliance with applicable laws. Such measures are either transferring the personal data to a recipient in a country that the European Commission has decided provides adequate protection for Personal Data as referred to in Article 45 GDPR or the conclusion of standard contractual clauses, as referred to in Article 46.2 (c).

    We also let you know that with respect to our cooperation with TikTok in the scope of our joint controllership of your data: (1) we concluded the agreement on joint controllership available here; (2) we agreed that we will inform you about cooperation with TikTok; (3) we agreed with TikTok that between the Parties, TikTok is responsible for enabling you rights under Articles 15-20 of the GDPR with regard to the personal data stored or otherwise processed by TikTok after the joint processing.


    We implement the following retention periods with regard your data:

    • 3 years for queries submitted via the contact form on our Website,
    • up to 25 months for data collected automatically via cookies or other tracking technologies on our Website,
    • the period of validity of the legal basis for processing, e.g. until you object to processing, for data collected via our Social Media.

    After the expiry of the following retention periods, and in any case upon your request, we will either delete or anonymize your personal data.


    To the extent provided by the applicable data protection laws, in particular the GDPR, you have the right to:

    • access your personal data,
    • rectify your personal data,
    • request erasure of your personal data,
    • object to data processing,
    • restrict processing of your personal data,
    • receive a copy of your data in a structured, commonly used and machine-readable format or to request transmission of the data to another controller,
    • lodge a complaint with a competent supervisory authority,
    • withdraw consent for data processing you gave at any time (without affecting the lawfulness of processing based on consent before its withdrawal).

    We have appointed a Data Protection Officer to assist you in any privacy related matters, in particular to help you exercise the above rights. You may contact our DPO at


    We do not knowingly collect or solicit any information from anyone under the age of 16. Neither our Website nor App or our Social Media pages are directed to children under the age of 16. In case we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible.


    In order to access the website you need at least:

    • Internet access (dedicated line of 128 kbit/s per user at least);
    • web browser: Internet Explorer ver. 5.5 and higher, Opera ver. 7.x and higher, Firefox ver. 1.x and higher, Google Chrome ver. 5.0 and higher, Safari 5 or higher.

    In order to access the App you need at least:

    • Internet access (dedicated line of 128 kbit/s per user at least);
    • Access to Google Play, App Store or App Gallery
    • Smartphone with Android System 5.0 or higher or iPhone/iPad/iPod Touch with iOS 13.0 or later.

    We keep this privacy policy under regular review to make sure it is up to date and accurate. We will notify you about its changes in advance.


    The operator of the Website and the controller of personal data collected on the Website as well as on the Social Media is:
    RTB Marketing & Tech Services Ltd.,
    Kyriakou Matsi 18, 2nd Floor,
    Egkomi, Nicosia 2408, Cyprus

    With regard to certain data collected and processed on Social Media, we and the operator of the respective social media platform may be joint controllers of your personal data (e.g. in terms of joint controllership with Meta), as the purposes and means of processing of such data are agreed jointly by us and such platform. If you have any questions regarding the processing of your personal data on our Social Media, please contact our Data Protection Officer first.

    You may file a complaint regarding the operation of this website to the above address or to Please contact our Data Protection Officer at: in any matters regarding this Privacy Policy.