Legal

Privacy Policy

Promo LLC — EPK News Digital Marketing Services.

Promo LLC — EPK News Digital Marketing Services. Effective Date: August 2026. Last Updated: August 2026.

PART ONE: Scope and Who This Policy Covers

1. Information We Collect About You

This Privacy Policy explains how Promo LLC ("Company," "we," "us," or "our") collects, uses, stores, and discloses personal information in connection with our website at https://epknews.com ("Site"); our digital marketing Services for business clients ("Clients"); newsletters and email communications we create and send on behalf of Clients to client-supplied or client-authorized recipient lists ("Newsletter Recipients"); and visitors to Clients' represented digital channels and content where we are the service provider.

This Policy applies to information about identifiable individuals. It does not apply to anonymized or aggregated data that cannot reasonably be linked to a specific person. This Policy should be read alongside our Terms of Service, which govern use of the Services generally.

2. Information We Collect Directly From You

Depending on the context, Promo LLC may act in different capacities:

As an Independent Controller — when we collect and use personal information to manage our own business relationships, such as processing Client contact information, managing invoices, or communicating with Clients, we determine the purposes and means of that processing and act as a data controller (or "business" under California law).
As a Service Provider / Processor — when we access, handle, or process personal information contained in a client's email list or audience data solely for the purpose of providing a specific requested Service (such as sending a newsletter), we act as a service provider or data processor on the Client's behalf. In that capacity, we process the data only according to the Client's instructions and applicable law.

Clients who supply email lists or audience data to us are independently responsible for ensuring that such data was lawfully collected, that appropriate consents or legal bases exist, that proper notices were given to individuals, and that opt-out and data rights requests are managed in accordance with applicable law.

PART TWO: Information We Collect From Other Sources

3. Categories of Personal Information We Collect

(a) Client Business and Contact Information — business name, business address, and business license information; name, title, and contact details of Client representatives; billing information (processed and held by Stripe or Square — see Section 9); and information provided in intake forms, onboarding materials, and ongoing communications.
(b) Client-Supplied Content and Materials — logos, images, written content, social media handles, website URLs, brand guidelines, and other business materials, which may incidentally include information about individuals (e.g., a staff photo or a testimonial) that the Client has authorized us to use.
(c) Client Email List Data (Service Provider Capacity) — when a client engages us for newsletter creation and distribution, the Client provides us with an email list of their recipients. We access recipient names, email addresses, and any segmentation data the Client provides solely for the purpose of sending newsletters as instructed by the Client. We do not use this data for our own marketing, analytics, or any purpose unrelated to the Client's requested service.
(d) Communications Data — information you share with us through email, contact forms, or other direct communications with Promo LLC.
(e) Information Collected Automatically on Our Site — see Section 9 (Cookies and Similar Technologies) for details. Our current practices are limited, but third-party elements may collect data independently.

4. Information We Collect Automatically

We collect personal information directly from you when you contact us, complete forms, place orders, or communicate with us; from Clients when they supply materials, email lists, or instructions as part of the Services; and indirectly through third-party platforms (e.g., platform analytics made available to us while managing a represented channel), to the extent necessary to deliver the Services.

PART THREE: How We Use Personal Information

5. Purposes of Processing

Purpose	Details
Providing the Services	Processing Client orders, creating content, managing channels, sending newsletters, and all related service delivery activities
Account and relationship management	Communicating with Clients, sending invoices, managing subscriptions, and responding to inquiries
Legal and compliance	Complying with applicable laws, responding to lawful requests, enforcing our Terms, and protecting our rights and the rights of others
Security and fraud prevention	Detecting and preventing unauthorized access, fraud, or misuse of the Services
Improving our services	Understanding how we can better serve our Clients (using aggregated, non-identifiable insights where possible)
Newsletter and email services	Creating and distributing email communications on behalf of Clients, as a service provider, following Client instructions

We do not use personal information for unrelated advertising, behavioral tracking, or sale to third parties.

Where the General Data Protection Regulation ("GDPR") or UK GDPR applies to our processing of personal information, our legal bases are:

Processing Activity	Legal Basis
Performing a contract with a Client	Article 6(1)(b): Necessary for the performance of a contract
Compliance with legal obligations	Article 6(1)(c): Legal obligation
Legitimate business interests (e.g., security, fraud prevention, service improvement)	Article 6(1)(f): Legitimate interests, where not overridden by your interests or rights
Processing Client email lists as a processor	Acting on Client's documented instructions; the Client is responsible for establishing the applicable legal basis for their recipients
Any processing based on consent	Article 6(1)(a): Consent (you may withdraw consent at any time without affecting the lawfulness of prior processing)

PART FOUR: How We Disclose Information About You

We are committed to never selling or sharing your personal information for monetary consideration or for third-party advertising purposes unrelated to your Services. We may disclose personal information in the following limited circumstances:

(a) Payment Processors — billing and payment information is transmitted to and processed by Stripe and/or Square, which operate under their own privacy policies and security standards. We do not store complete payment card numbers.
(b) Service Delivery — where necessary to perform the Services, for example submitting approved content to a third-party platform where we manage your representation, we may share relevant information with that platform. Those platforms have their own privacy practices.
(c) Legal Requirements — we may disclose information if required by law, subpoena, court order, or legitimate governmental request, or to protect the rights, property, or safety of Promo LLC, our clients, or the public.
(d) Business Transfer — in the event of a merger, acquisition, or sale of all or substantially all of our assets, personal information may be transferred as part of that transaction, subject to the same protections described in this Policy.
(e) With Your Consent — we may share information with third parties when you explicitly authorize us to do so.

We do not use third-party email platforms to send newsletters on behalf of Clients under our current practices. If this practice changes, we will update this Policy with advance notice and, where required, seek applicable consent.

We do not sell personal information for monetary or other valuable considerations. We do not share personal information with third parties for their independent marketing or advertising purposes. This applies to Client information and to any Newsletter Recipient or audience data we access in our service provider capacity.

PART FIVE: Your Choices — Cookies, Analytics, and Similar Technologies

9. Cookies and Similar Technologies

Promo LLC's current practice is to not deploy its own cookies, analytics scripts, or advertising pixels on the Site or in the Services. However, please be aware:

(a) Third-Party Platforms — content we manage on third-party platforms (YouTube channels, social media, websites) is subject to those platforms' own cookie and tracking practices, which we do not control.
(b) Payment Processors — Stripe and Square may use cookies or similar technologies in connection with payment processing. These are governed by their own policies.
(c) Embedded Content — if our Site or any represented channel embeds content from third-party services (e.g., video players, social widgets), those third parties may collect data about visitors independently.
(d) Future Changes — if we introduce our own analytics tools, cookies, or tracking technologies in the future, we will update this Policy, add a cookie notice as required, and obtain any required consents before deployment.

PART SIX: Retention, Security, and International Transfers

10. Data Retention

We retain personal information for as long as necessary to provide the Services and maintain an active Client relationship; comply with our legal and tax obligations; resolve disputes and enforce our agreements; and fulfill any other legitimate business purpose described in this Policy.

Client information is generally retained for the duration of the service engagement plus the minimum period required or permitted by applicable law in the relevant jurisdiction following termination, unless a shorter period is required or permitted by law. Newsletter Recipient data provided in our service provider capacity is retained only for the duration of the applicable service engagement and deleted or returned upon termination, unless the Client instructs otherwise and applicable law permits.

11. Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These include access controls limiting information to personnel who need it to perform the Services; secure transmission protocols where applicable; and use of reputable, security-certified payment processors (Stripe, Square) for all payment data.

No method of transmission over the Internet or electronic storage is 100% secure. While we work hard to protect your information, we cannot guarantee absolute security. In the event of a data breach that triggers legal notification obligations, we will notify affected parties and relevant authorities as required by applicable law.

12. International Transfers of Personal Information

Promo LLC is based in the United States. If you are located in the European Economic Area ("EEA"), the United Kingdom ("UK"), or another country with data transfer restrictions, please be aware that information you provide to us will be transferred to and processed in the United States, which may not offer the same level of data protection as your home jurisdiction.

Where such transfers occur in relation to EU/UK personal data, we will rely on an appropriate lawful transfer mechanism, which may include Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner's Office, as applicable, or another recognized transfer mechanism under applicable law. By providing personal information to us or authorizing us to process it, you acknowledge this transfer.

PART SEVEN: Your Privacy Rights

If you are located in the EEA or the UK, and the GDPR or UK GDPR applies to our processing of your personal information, you may have the following rights:

Right	Description
Access	Request confirmation of whether we process your personal information and obtain a copy
Rectification	Request correction of inaccurate or incomplete personal information
Erasure	Request deletion of your personal information, subject to legal retention requirements
Restriction	Request that we limit processing of your personal information in certain circumstances
Data Portability	Receive personal information you provided to us in a structured, commonly used, machine-readable format
Objection	Object to processing based on our legitimate interests; we will cease unless we have compelling legitimate grounds
Withdraw Consent	Where processing is based on consent, withdraw at any time without affecting prior lawful processing

To exercise any of these rights, contact us at [email protected] with subject line "Privacy Rights Request – EU/UK." We will respond within 30 days (or such shorter period as required by law). We may need to verify your identity before processing your request.

Supervisory Authority — if you believe we have not handled your personal information in accordance with applicable law, you have the right to lodge a complaint with your local data protection supervisory authority. In the UK, this is the Information Commissioner's Office (ico.org.uk).

Promo LLC does not currently have a designated Data Protection Officer or an EU/UK statutory representative. If your request concerns processing we undertake in a service provider capacity on behalf of a Client, we may need to direct your request to that Client.

14. Rights of California Residents (CCPA / CPRA)

This section applies to California residents whose personal information we process as a "business" under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA/CPRA"). We collect personal information in the categories of identifiers, business or professional information, and Internet or other electronic network activity (to the limited extent described in Section 9). We do not collect sensitive personal information categories unless expressly requested by and provided by a Client. We do not sell or share personal information as defined by the CCPA/CPRA.

Right	Description
Know	Request information about the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties with whom we share it
Delete	Request deletion of your personal information, subject to applicable exceptions
Correct	Request correction of inaccurate personal information
Opt-Out of Sale/Sharing	We do not sell or share personal information; no opt-out is required, but you may contact us to confirm
Non-Discrimination	We will not discriminate against you for exercising your privacy rights

To submit a request, email [email protected] with subject line "California Privacy Rights Request." We will respond within 45 days, extendable by an additional 45 days with notice. We may need to verify your identity. You may designate an authorized agent to submit a request on your behalf.

15. Rights of Residents of Other Jurisdictions

We recognize that additional privacy rights may apply to residents of other U.S. states (including but not limited to Virginia, Colorado, Connecticut, Texas, and others with comprehensive privacy laws) or other countries. We will process reasonable requests from individuals in those jurisdictions in a manner consistent with applicable law. Contact us at [email protected] with the subject line "Privacy Rights Request" to make a request or inquiry.

Promo LLC's policy is to comply with applicable privacy and data protection laws in any jurisdiction where we operate or serve Clients. Where applicable law prohibits or materially restricts a service we would otherwise offer, we will decline or cease to offer that service in that jurisdiction rather than operate in a non-compliant manner.

PART EIGHT: Additional Provisions

16. Children's Privacy

Our Services are directed exclusively to licensed and currently operating business entities. We do not knowingly collect personal information from individuals under the age of 16, and our Services are not intended for minors. If we become aware that we have inadvertently collected personal information from a minor, we will promptly delete it. If you believe a minor has submitted personal information to us, please contact us immediately at [email protected].

17. Third-Party Links and Platforms

Our Site and the channels we manage on your behalf may contain links to or be hosted on third-party websites, platforms, and services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party platform before providing personal information to it. We are not responsible for the privacy practices, content, or security of any third-party site or service.

18. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or applicable law. When we make material changes, we will post the updated Policy on our Site with a new "Last Updated" date; provide reasonable advance notice by email to Clients where required or appropriate; and where required by law, seek fresh consent. Your continued use of the Services after the effective date of any update constitutes your acknowledgment of an agreement to the revised Policy.

19. How to Contact Us

For privacy inquiries, rights requests, concerns, or questions about this Policy, please contact:

Promo LLC 1309 Coffeen Avenue STE 1200 Sheridan, Wyoming 82801, USA Email: [email protected] Website: https://epknews.com

We aim to acknowledge all privacy inquiries within 5 business days and to resolve them within the time-frame required by applicable law.