This Privacy Policy explains how SimplyRecommend collects, uses and protects personal data when you visit our public website, use our affiliate portal, access campaign or Pre-Sell Pages, contact us, or otherwise interact with our services.
1. Data controller
The data controller for SimplyRecommend is:
PROMOS MARKETING, promotional gifts d.o.o.
Viška cesta 49 c, 1000 Ljubljana, Slovenia
VAT ID: SI28733304
Phone: +386 41 367272
Email: info@promowheelsoffortune.com
Website: simplyrecommend.com
2. Personal data we may collect
- Account and identity data, such as name, company/business name, postal address, country, email address, phone number and optional website.
- Affiliate-program connection data, such as an external affiliate URL, nickname, identifier, sponsor-related information, market/language connection or other data needed to connect a supported Promotion.
- Account and security data, including authentication/session information, role, permissions and account status.
- Usage and technical data, such as IP address, device/browser information, timestamps, page views, referring pages, campaign parameters and similar technical logs.
- Campaign and performance data generated through SimplyRecommend tracked links, QR codes, Pre-Sell Pages and outbound clicks.
- Communications you send to us, including support requests, feedback and correspondence.
- Cookie and consent data, including your cookie preferences and, where applicable, analytics or advertising identifiers.
3. Why we use personal data and our legal bases
- To create and administer user accounts, provide portal functionality, route affiliate traffic correctly and deliver requested services — performance of a contract or steps taken at your request.
- To secure, operate, troubleshoot and improve SimplyRecommend, prevent abuse, maintain records and understand service performance — our legitimate interests, where those interests are not overridden by your rights.
- To respond to enquiries, provide support and communicate about service-related matters — performance of a contract, steps taken at your request, or legitimate interests.
- To send marketing/news communications where permitted — consent where required, or another lawful basis where applicable. You can unsubscribe from marketing communications at any time.
- To use non-essential analytics or advertising technologies where consent is required — your consent.
- To comply with legal, tax, accounting, regulatory and compliance obligations — compliance with legal obligations.
4. Affiliate and campaign tracking
SimplyRecommend may use internal identifiers to attribute visits and actions to an Affiliate, Promotion, Marketing Material, Pre-Sell Page or anonymous visitor journey. This allows us to operate tracked links, measure campaign performance, improve materials and route visitors to the correct external affiliate destination. We do not claim to know a purchase, commission or other downstream outcome unless that information is actually available to us from the relevant external program or another verified source.
5. Cookies, analytics and advertising
We may use strictly necessary technologies to operate the site and portal. With the appropriate consent where required, we may also use analytics and advertising technologies, including Google Analytics, Google Ads and Google Tag Manager, to measure usage and advertising performance. Our cookie banner or privacy controls should allow you to make or change relevant choices.
6. Recipients and service providers
We may share personal data with service providers that help us operate SimplyRecommend, such as hosting, application infrastructure, email delivery, analytics, advertising, security and support providers. We may also disclose data where required by law or to protect legal rights.
When you choose to continue to a third-party product, affiliate or merchant destination, that third party operates its own environment and processes data under its own privacy terms.
7. International transfers
Some service providers may process data outside Slovenia or the European Economic Area. Where required, transfers are handled using an applicable legal transfer mechanism or safeguard provided under data-protection law.
8. Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Policy, including account operation, security, support, analytics, legal obligations and dispute resolution. Retention periods may differ by data category and service provider.
9. Your rights
Subject to applicable law, you may have rights to access, correct or erase your personal data; restrict or object to certain processing; receive certain data in a portable format; and withdraw consent where processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing before withdrawal.
To exercise a privacy right, contact info@promowheelsoffortune.com. We may need to verify your identity before acting on a request.
10. Complaints
You also have the right to lodge a complaint with the competent data-protection supervisory authority. In Slovenia, this is the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec).
11. Automated recommendations
SimplyRecommend may use profile information such as business type, audience interests, market/language and available Promotions to recommend products, Themes or Marketing Materials. These recommendations are intended to simplify the user experience and are not used to make decisions that produce legal or similarly significant effects.
12. Children
SimplyRecommend is intended for adults and business users. We do not knowingly offer the service to children.
13. Changes to this Policy
We may update this Privacy Policy as the service, technologies or legal requirements change. The current version will be published on the SimplyRecommend website with an updated revision date.