Submit Privacy Statement

This Privacy Statement explains how Submit may collect, use, and disclose “Personal Data” and other information we obtain through Submit’s website.

Personal Data means any information processed by Submit relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Submit will only collect, process or use Personal Data for the purposes of providing the Services. Submit does not sell, trade or otherwise transfer your personal information to third parties in any manner that could be harmful, dangerous or violating your privacy.

For citizens based in the EU, certain regulations apply to Personal Data stored on their behalf as set out by the EU General Data Protection Regulation (GDPR) – regulation (EU) 2016/679. For all Personal Data collected, regardless of location, Submit will comply with the provisions of the GDPR in the context of its obligations as controller of the data to the extent applicable.

Submit agrees to use commercially reasonable technical and organisational measures designed to prevent unauthorised access, use, alteration or disclosure of Personal Data. Submit will have no responsibility for errors in transmission, unauthorised third-party access or other causes beyond Submit’s control. In certain situations, it may be a legal requirement for us to disclose Personal Data to the relevant authorities.

What information does Submit collect?

Using Submit.com, you may voluntarily provide Personal Data (name, email, phone number) using the Service. In addition, one other form of Personal Data, namely IP address, is collected automatically.

Other, non-personal information is also collected, namely User Agent (browser details) and pages browsed when using Submit.

Service providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”

Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Intercom

We provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

Behavioural remarketing

Submit uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

LinkedIn

LinkedIn retargeting service is provided by LinkedIn Ireland U.C.

You can learn more about the privacy practices and policies of LinkedIn by visiting their Privacy Policy page: https://www.linkedin.com/legal/privacy-policy

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Where is your data stored?

Submit stores all of its data in the EU. You should note that, depending on the information you provide, Personal Data may be temporarily transferred outside of the EU solely for the purposes of providing the service. As an example, if you voluntarily choose to submit your email address in order to be notified of a reply by email, your email address is temporarily transferred to a 3rd party service outside of the EU, in order to notify you. Note also that Submit will only use 3rd party service providers that have adequate security measures in place aligned with the GDPR.

Your rights in relation to your Personal Data

As outlined in the GDPR, you have the following rights in relation to your Personal Data. Note, that the GDPR only stipulates that these rights are required for EU citizens. We, however, apply these rights to your Personal Data regardless of your location.

Right to access – you have to access and view any Personal Data we store relating to you.
Right to rectification – you have the right to request we update any information we hold about you that is inaccurate.
Right to be forgotten – you have the right to request we erase any information we hold you on, except where we are subject to hold that data under legislation or for legal requirements.
Right to restriction – you have the right to request we temporarily restrict the processing of your Personal Data under the conditions set out in the GDPR
Right to data portability – you have the right to obtain a machine-readable copy of the Personal Data we store for you
Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legal purposes.

Subscription to our newsletters

On the website of Submit, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

Submit informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorised to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in a different way.

Newsletter-Tracking

The newsletter of Submit contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Submit may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. Submit automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Contact possibility via the website

The website of Submit contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

What about cookies?

Cookies are small text files which are stored on a user’s computer and are designed to hold a modest amount of data specific to a particular user and website e.g. time on site. They can be accessed either by the web server or the client computer. It is important to note that accepting cookies used on our site does not give us access to any personal information. Most browsers automatically accept cookies by default, but you can usually refuse cookies or selectively accept certain cookies by adjusting the preferences in your browser.

Age Requirement

In line with the GDPR you must be 16 years or older to use the Submit service. Submit is committed to protecting the privacy of young children, and therefore does not knowingly collect or maintain personal information on the service from persons under 16 years of age.

Acceptance of Privacy Statement

By using Submit’s messaging applications, you agree to terms of this Privacy Statement. We recommend that you review this Statement periodically, as we may update it from time to time. If you continue to use the services after those changes are in effect, you agree to the revised Statement.

Contacting Submit

Please use the contact options on the Submit website Submit.com

Updated 06/02/2024