My Travel Lion Privacy Policy
Down Under Promotions
Effective Date: November 1, 2025
Last Updated: November 11, 2025
1. Introduction
My Travel Lion in conjunction Down Under Promotions (the “Company,” “we,” “us,” “our,” or “Down Under Promotions“) values your privacy and is committed to being transparent about how we collect, use, disclose, and otherwise process personal information in connection with our website, mobile applications, email marketing program, SMS messaging program, and other services (collectively, the “Services“). This Privacy Policy describes our privacy practices and the choices available to you regarding your personal information.
This Privacy Policy applies to information we collect from all sources, including:
- Website visitors
- Email subscribers and recipients
- SMS/text message subscribers and recipients
- Mobile app users
- Customers and clients
- Job applicants
- All other individuals whose personal information we process
For residents of specific jurisdictions (California, Virginia, New Jersey, Indiana, EU/EEA, United Kingdom), additional disclosures and rights are outlined below in the jurisdiction-specific sections of this Privacy Policy.
2. Information We Collect
2.1 Information You Provide Directly
We collect personal information you voluntarily provide to us, including:
Email and SMS Communications
- Email Address: When you subscribe to our email marketing list or opt into communications
- Phone Number: When you opt into SMS/text messaging
- Subscription Preferences: Which communications you wish to receive, topics of interest, frequency preferences
- Account Information: Name, email address, phone number, company name, job title, address (if provided)
- Communication History: Records of your interactions with our customer service team via email, SMS, phone, or contact forms
Forms and Registrations
- Sign-Up Forms: Information provided when you subscribe to our mailing list (email or SMS)
- Contact Forms: Inquiries, questions, feedback, or support requests
- Survey and Feedback Forms: Responses to surveys, polls, or requests for feedback
- Event Registration: Information provided when registering for webinars, events, or promotions
Transactional Information
- Purchase History: Details about products or services purchased
- Payment Information: Credit card details, billing address (processed securely by third-party payment processors; we do not store full credit card information)
- Customer Service Records: Support tickets, returns, complaints, and other service interactions
Professional Information
- Career Applications: Resume, cover letter, employment history (for job applicants)
- Volunteer Information: Information provided by volunteers
2.2 Information Collected Automatically
When you interact with our website, mobile apps, or emails, we may collect information automatically:
Website and App Usage
- Browser and Device Information: Device type, operating system, browser type and version, IP address, mobile network information
- Website Activity: Pages visited, content accessed, features used, time spent on pages, clicks, scroll depth
- Referring Source: How you arrived at our website (search engine, referral link, advertisement)
- Interaction Data: Forms submitted, buttons clicked, links followed
Cookies and Tracking Technologies
- Cookies: We use both session-based and persistent cookies to recognize you, store your preferences, understand your usage patterns, and improve your experience
- Pixels and Beacons: Web beacons, clear GIFs, and similar technologies embedded in emails and web pages that track whether emails are opened and which links are clicked
- Local Storage: Browser-based storage for preferences and session information
- Tracking Tags: Google Analytics, Facebook Pixel, and similar third-party tracking tools
Email Engagement Data
- Email Opens: Whether you opened marketing emails
- Click Tracking: Which links you clicked within our emails
- Delivery Status: Whether emails were successfully delivered or bounced
- Unsubscribe Data: When and how you unsubscribed
SMS Engagement Data
- Message Delivery: Whether SMS messages were successfully delivered
- Message Responses: Your replies to SMS messages
- Link Clicks: Clicks on links contained in SMS messages
2.3 Information from Third Parties
We may receive personal information about you from:
- Data Brokers and List Providers: Third-party providers from which we may purchase or obtain mailing lists or contact information
- Publicly Available Sources: Information from public databases, directories, and social media platforms
- Third-Party Services: Information shared by other services or platforms you use that integrate with our Services
- Business Partners: Information shared by partners, affiliates, or organizations you interact with
- Social Media Platforms: When you interact with our social media accounts or authorize social media login
- Referral Programs: Information provided by individuals who refer you to our Services
- Advertising Partners: Information from advertising networks and platforms
2.4 Aggregated and De-identified Information
We may collect, use, and share aggregated or de-identified information that cannot reasonably identify you. This information is not subject to this Privacy Policy and may be used for any purpose.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
3.1 Providing and Improving Services
- Delivering email and SMS communications you have requested
- Processing transactions and sending transactional communications
- Creating and maintaining your account
- Responding to your inquiries and customer service requests
- Troubleshooting and resolving technical issues
- Improving our Services, products, and user experience
- Personalizing content and communications based on your preferences
- Conducting surveys and requesting feedback
3.2 Marketing and Promotional Communications
- Sending marketing emails, SMS messages, and promotional offers
- Creating targeted marketing campaigns based on your interests and engagement history
- Displaying personalized advertisements and content
- Conducting market research and analysis
- Testing and optimizing email and SMS campaigns
3.3 Legal Compliance and Fraud Prevention
- Complying with applicable laws, regulations, and legal processes
- Protecting the rights, property, and safety of Down Under Promotions, our users, and the public
- Detecting, investigating, and preventing fraudulent or unauthorized activity
- Enforcing our Terms of Service and other agreements
- Maintaining records for legal, compliance, and accounting purposes
- Responding to subpoenas, court orders, and other legal requests
3.4 Business Operations
- Conducting business analytics and reporting
- Auditing, accounting, and financial purposes
- Managing and organizing our business operations
- Hiring and recruitment
- Internal communications and training
- Quality assurance and performance monitoring
3.5 Other Uses
- Any other purpose with your explicit consent
- As required by law or legal process
- As necessary to establish, exercise, or defend legal claims
4. Email Marketing Program
4.1 How We Collect Email Addresses
We collect email addresses through:
- Opt-in forms on our website or landing pages
- Direct signup requests from individuals
- Purchase transactions and customer accounts
- Registration for events, webinars, or promotions
- Contact form submissions
- Third-party list purchases or data sharing agreements
4.2 Email List Management
Consent and Opt-In
- We maintain your email address on our mailing list only with your explicit consent
- We provide clear, transparent opt-in mechanisms (e.g., unchecked checkboxes)
- Your email address will not be added to our list as a condition of purchasing products or services
- We maintain detailed records of your consent, including the date, method, and context of your opt-in
Email Marketing Platform
- We use Brevo (formerly Sendinblue) as our email service provider and mailing list manager
- Brevo processes your email address and engagement data on our behalf as our data processor
- We have a Data Processing Agreement (DPA) in place with Brevo that complies with GDPR, CCPA, and other privacy regulations
- Your data is subject to Brevo’s security measures, encryption protocols, and privacy practices
Email Frequency and Content
- Marketing emails may include promotional offers, product updates, news, and other content
- You will receive approximately 2 marketing emails per month (frequency varies based on our promotions)
- Transactional emails (order confirmations, shipping notifications, account alerts) are sent regardless of marketing preferences
4.3 Email Opt-Out and Unsubscribe
Unsubscribe Options
- Every marketing email includes an “Unsubscribe” or “Manage Preferences” link
- You can unsubscribe by clicking the unsubscribe link in any marketing email
- You can update your email preferences through your account profile on our website
- You can request removal by contacting us at sales@dupromos.com
Processing Opt-Out Requests
- Upon receiving an unsubscribe request, we will remove your email address within 10 business days
- Once unsubscribed, we will no longer send you marketing emails
- You may still receive transactional emails (order confirmations, customer service updates)
- Your request is permanent unless you explicitly resubscribe
CAN-SPAM Compliance
- All marketing emails comply with the CAN-SPAM Act
- Each email clearly identifies Down Under Promotions as the sender
- Our physical mailing address is included in every email: 333 Washington Blvd #323, Marina Del Rey, CA 90292
- We honor opt-out requests in a timely manner
5. SMS/Text Messaging Program
5.1 How We Collect Phone Numbers
We collect mobile phone numbers through:
- SMS opt-in forms on our website
- Texting a keyword (e.g., “JOIN”) to a designated short code
- Providing your phone number on signup forms or during registration
- SMS opt-in requests following customer service interactions
- Purchase transactions where phone numbers are provided
5.2 SMS List Management
Consent and Opt-In
- We collect phone numbers only with your prior express written consent
- You confirm you are not on any national or state Do Not Call registry
- Participation in the SMS program is not a condition of purchasing products or services
- We maintain records of your consent, including the date and method of opt-in
SMS Service Provider
- We use Brevo as our SMS service provider and mailing list manager
- Brevo processes your phone number and SMS engagement data as our data processor
- We maintain a Data Processing Agreement with Brevo
- Brevo complies with TCPA, GDPR, CCPA, and carrier regulations
SMS Message Frequency and Content
- SMS messages may include promotional offers, order updates, shipping notifications, and customer service communications
- You may receive approximately 2 text messages per month
- Standard message and data rates from your wireless carrier may apply
- The Company is not responsible for charges imposed by your wireless carrier
5.3 SMS Opt-Out and Unsubscribe
Unsubscribe Options
- Reply “STOP” to any SMS message you receive to opt out of all future SMS messages
- You can also reply with “UNSUBSCRIBE,” “QUIT,” “CANCEL,” or similar language
- Contact us at 310-741-9747 to unsubscribe
- Update your SMS preferences through your account on our website
Processing Opt-Out Requests
- Upon receiving your opt-out request, we will confirm your unsubscribe status
- You will be removed from the SMS list within 24 hours
- We will no longer send promotional SMS messages
- You may still receive transactional SMS messages (order confirmations, shipping updates)
TCPA Compliance
- All SMS communications comply with the Telephone Consumer Protection Act (TCPA)
- We maintain consent records for at least 4 years to comply with TCPA requirements
- We honor opt-out requests and maintain an internal do-not-contact list
6. Brevo Data Processing
6.1 Brevo’s Role
Down Under Promotions uses Brevo as our email and SMS marketing platform. Brevo acts as a data processor on our behalf and processes your personal information (email addresses, phone numbers, and engagement data) according to our instructions.
6.2 Data Processing Agreement
We maintain a Data Processing Agreement (DPA) with Brevo that includes:
- Clear definitions of what data Brevo processes and for what purposes
- Specifications that Brevo processes data only on our instructions
- Brevo’s obligations regarding data security and confidentiality
- Brevo’s sub-processor disclosures and approval requirements
- Data subject rights (access, deletion, portability, restriction)
- Breach notification procedures
- Compliance with GDPR, CCPA, and other applicable regulations
6.3 Brevo’s Security Measures
Brevo implements the following security measures to protect your data:
- Encryption: Data is encrypted in transit (SSL/TLS) and at rest
- Access Controls: Role-based access controls and employee training
- Data Centers: Secure, geographically distributed data centers with backup systems
- Compliance: Brevo is SOC 2 Type II certified and complies with GDPR, CCPA, and other regulations
- Audit Trails: Data tracking and logging systems to monitor all data processing activities
- Sub-processors: Brevo has vetted and contracted with approved sub-processors
For more information about Brevo’s security practices, visit: https://www.brevo.com/security/
6.4 Data Retention by Brevo
- Your email address and phone number are retained as long as your account is active
- Engagement data (open rates, clicks, bounce information) may be retained for at least 12 months
- Upon account deletion or unsubscribe, data is deleted according to Brevo’s retention schedule
- We may request deletion of your data by contacting Brevo support
6.5 Sub-processors
Brevo may use sub-processors (third-party service providers) to process your data. These may include:
- Cloud infrastructure providers (Amazon Web Services, Microsoft Azure)
- Email delivery networks and SMS gateways
- Analytics providers
- Customer support tools
- Other third-party service providers
A current list of Brevo’s sub-processors is available at: https://www.brevo.com/sub-processors/
7. How We Disclose Your Information
7.1 Service Providers
We may disclose your personal information to third-party service providers who assist us in providing our Services:
- Email and SMS Providers: Brevo (email and SMS marketing platform)
- Payment Processors: Third parties that process payment information
- Web Hosting Providers: Companies that host our website and applications
- Analytics Providers: Google Analytics and similar services that analyze website usage
- Customer Service Platforms: Tools used to manage customer support and communications
- Advertising Networks: Companies that display advertisements on our behalf
- Cloud Storage Providers: Companies that store our data and backups
7.2 Legal and Compliance
We may disclose your information when:
- Required by law, regulation, court order, or legal process
- Necessary to enforce our Terms of Service and other agreements
- Required to protect the rights, property, or safety of Down Under Promotions, our users, or the public
- Necessary to detect, investigate, or prevent fraudulent or illegal activity
7.3 Business Transfers
If Down Under Promotions is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, similar transaction or proceeding, your information may be transferred as part of that transaction. We will provide notice if such a change occurs and any choices you may have regarding your personal information.
7.4 De-identified and Aggregated Information
We may disclose aggregated or de-identified information that cannot reasonably identify you to third parties for marketing, advertising, analytics, research, and other purposes without restriction.
7.5 Publicly Available Information
If you submit comments, reviews, or other information that you intend to be publicly visible, we may publicly display this information.
8. Your Privacy Rights and Choices
8.1 Access to Your Information
You have the right to request access to the personal information we hold about you. We will provide you with a copy of your personal information in a structured, commonly used, and machine-readable format if technically feasible.
To request access: Contact us at sales@dupromos.com with the subject line “Privacy Rights Request – Access.”
8.2 Correction and Updates
You have the right to request correction of inaccurate or incomplete personal information. You may update your information:
- Through your account profile on our website
- By contacting us at sales@dupromos.com
8.3 Deletion and Erasure
You have the right to request deletion of your personal information under certain circumstances:
- We will process deletion requests within 30 days (or as required by applicable law)
- Upon deletion, you will be unsubscribed from all marketing communications
- Certain information may be retained for legal, accounting, or compliance purposes
- Note: We may retain some information to comply with TCPA (4 years for SMS consent records) and other legal requirements
To request deletion: Contact us at sales@dupromos.com with the subject line “Privacy Rights Request – Deletion.”
8.4 Opt-Out of Marketing Communications
You can opt out of receiving marketing communications as follows:
- Email: Click the “Unsubscribe” link in any marketing email
- SMS: Reply “STOP” to any text message
- Web: Update your preferences through your account profile
- Contact Us: Email sales@dupromos.com or call 310-741-9747
8.5 Opt-Out of Data Sales and Sharing
We do not sell your personal information to third parties for their own marketing purposes. We do not share your information for targeted advertising without your consent. You are not required to provide any additional consent for our use of your information.
8.6 Cookies and Tracking
You can control how cookies and tracking technologies are used:
- Browser Settings: Most browsers allow you to refuse cookies or alert you when cookies are being sent. Instructions are typically available in the browser’s “Help” menu.
- Do Not Track: Some browsers include a “Do Not Track” feature. We currently do not respond to “Do Not Track” signals.
- Opt-Out Services: You can use third-party opt-out services like the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA)
Note that disabling cookies may limit your ability to access certain features of our website.
8.7 Promotional Communications
You can control promotional communications as described in Sections 4.3 (Email Opt-Out) and 5.3 (SMS Opt-Out) above.
8.8 Contact Preferences
You may update your communication preferences by:
- Updating your account profile
- Contacting us at sales@dupromos.com
- Responding to communications with your preferences
9. California Privacy Rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific privacy rights:
9.1 Right to Know
You have the right to request that we disclose:
- The categories of personal information we have collected about you
- The categories of sources from which we collected the personal information
- The specific pieces of personal information we have collected about you
- Our business or commercial purpose for collecting your personal information
- The categories of third parties with whom we share personal information
9.2 Right to Delete
You have the right to request deletion of personal information we have collected from you, subject to certain exceptions:
- We may retain information necessary for legal compliance, fraud prevention, or account security
- We must delete such information unless a legal exception applies
9.3 Right to Correct
You have the right to request correction of inaccurate personal information we maintain about you.
9.4 Right to Opt-Out of Sales and Sharing
Under CCPA/CPRA, we do not sell your personal information to third parties for their own marketing purposes. We also do not “share” your information for targeted advertising. Therefore, you do not need to exercise a “do not sell” or “do not share” right.
However, we use Brevo and other service providers who may use your information in ways that could be considered a “sale” or “sharing” under California law. If you would like to opt out of such uses, please contact us at sales@dupromos.com.
9.5 Right to Limit Use and Disclosure
You have the right to limit our use and disclosure of your sensitive personal information to purposes necessary to provide the services you requested or as otherwise permitted by law.
Sensitive personal information includes:
- Social Security numbers or driver’s license numbers
- Financial account information
- Precise geolocation data
- Racial or ethnic origin
- Religious beliefs
- Union membership
- Genetic data
- Biometric data
- Health information
- Sex life or sexual orientation information
9.6 Right to Non-Discrimination
We will not discriminate against you for exercising your California privacy rights. We will not deny, charge different prices, provide different quality of service, or otherwise penalize you for exercising your rights under CCPA/CPRA.
9.7 Authorized Agent
You may designate an authorized agent to make requests on your behalf. Your authorized agent must provide proof of authorization and a copy of a valid power of attorney.
9.8 How to Exercise Your Rights
To exercise your California privacy rights:
Email: sales@dupromos.com
Mail: Down Under Promotions 333 Washington Blvd #323, Marina Del Rey, CA 90292
Phone: 310-741-9747
Include:
- Your name and email address
- Clear description of your request
- Proof of residency (for CCPA/CPRA requests)
- Signature under penalty of perjury
We will verify your request and respond within 45 days (or as required by law). We may request additional information to verify your identity.
10. Additional US State Privacy Rights
Several U.S. states have enacted privacy laws providing residents with privacy rights similar to CCPA. These states include Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and others.
10.1 Consumer Rights (General)
If you are a resident of one of these states, you have the right to:
- Access: Request access to personal information we maintain about you
- Correction: Request correction of inaccurate or incomplete information
- Deletion: Request deletion of your personal information
- Data Portability: Request your information in a portable format
- Opt-Out: Opt out of targeted advertising and certain data sharing
- Non-Discrimination: Not be discriminated against for exercising your rights
10.2 How to Exercise Your Rights
For Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA) residents, or residents of other states with privacy laws:
Email: sales@dupromos.com
Mail: Down Under Promotions 333 Washington Blvd #323, Marina Del Rey, CA 90292
We will respond within 30-45 days of receiving a verified request (timeframe varies by state).
10.3 Authorized Agents and Appeals
You may designate an authorized agent to submit requests on your behalf. If we deny your request, you may have the right to appeal the denial to the applicable state attorney general or as otherwise provided by state law.
11. European Union and UK Privacy Rights (GDPR/UK GDPR)
If you are located in the European Union, European Economic Area, or United Kingdom, you have specific privacy rights under the General Data Protection Regulation (GDPR) and UK GDPR:
11.1 Legal Basis for Processing
We process your personal information based on the following legal bases:
- Consent: Where you have explicitly consented to receive marketing communications via email or SMS
- Contract: Where processing is necessary to perform our contract with you (e.g., processing orders)
- Legal Obligation: Where processing is required to comply with applicable laws
- Legitimate Interests: Where we have a legitimate interest in processing (e.g., marketing, fraud prevention) that does not override your rights
- Performance of a Task of Public Interest: Where processing is in the public interest
11.2 GDPR Rights
You have the following rights under GDPR:
Right to Access
You have the right to request access to your personal information and receive a copy in a structured, commonly used, and machine-readable format.
Right to Rectification
You have the right to request correction of inaccurate or incomplete personal information.
Right to Erasure (“Right to be Forgotten”)
You have the right to request deletion of your personal information under certain circumstances, including:
- The data is no longer necessary for the purposes it was collected
- You withdraw your consent
- You object to processing and there is no overriding legitimate interest
- The data was processed unlawfully
Exception: We may retain email consent records for up to 4 years if required by TCPA, and SMS consent records for 4 years as required by TCPA and GDPR legitimate interests.
Right to Restrict Processing
You have the right to request restriction of processing in certain circumstances, such as:
- While we verify the accuracy of your data
- The processing is unlawful but you do not want erasure
- We no longer need the data but you require it for legal claims
- You have objected to processing
Right to Data Portability
You have the right to request your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
Right to Object
You have the right to object to processing of your personal information, including:
- Object to marketing communications (see Sections 4.3 and 5.3)
- Object to processing for direct marketing purposes
- Object to processing based on legitimate interests
- Object to profiling based on legitimate interests
Rights Regarding Automated Decision-Making
You have the right not to be subject to decisions made solely by automated means that produce legal or similarly significant effects on you.
Right to Withdraw Consent
If processing is based on your consent, you have the right to withdraw that consent at any time by:
- Clicking the unsubscribe link in emails (Section 4.3)
- Replying “STOP” to SMS messages (Section 5.3)
- Contacting us at sales@dupromos.com
11.3 Data Protection Officer
Down Under Promotions’ Data Protection Officer (if applicable) can be contacted at sales@dupromos.com for privacy and data protection inquiries.
11.4 Exercise Your Rights
To exercise your GDPR rights:
Email: sales@dupromos.com
Mail: Down Under Promotions Data Protection Officer 333 Washington Blvd #323, Marina Del Rey, CA 90292
Phone: 310-741-9747
Include:
- Your name and email address
- Description of your request
- Proof of identity if requested
We will respond within 30 days (or 60 days for complex requests).
11.5 Supervisory Authority
If you believe we have violated your privacy rights under GDPR, you have the right to lodge a complaint with your local data protection authority:
- EU: Contact your national data protection authority (https://edpb.ec.europa.eu/about-edpb/board/members_en)
- UK: Information Commissioner’s Office (ICO) – https://ico.org.uk/
12. Data Security
12.1 Security Measures
We implement reasonable and appropriate security measures to protect your personal information from unauthorized access, alteration, disclosure, and destruction:
- Encryption: Data is encrypted in transit using SSL/TLS and at rest using AES-256 encryption
- Access Controls: Role-based access controls and employee authentication requirements
- Secure Infrastructure: Firewalls, intrusion detection, and other security technologies
- Employee Training: Regular training on data security and privacy practices
- Vendor Assessment: We audit and assess service providers’ security practices
- Incident Response: Procedures for detecting, investigating, and responding to security incidents
- Regular Reviews: Periodic security audits and assessments
12.2 Limitations of Security
While we implement comprehensive security measures, no system is 100% secure. We cannot guarantee absolute security of your information. You assume the risk of any breach of our security measures.
12.3 Breach Notification
In the event of a security breach affecting your personal information:
- We will notify you as soon as practicable if legally required
- Notification will be made by email, phone, or U.S. mail
- We will also notify applicable regulatory authorities and data protection authorities as required by law
- For EU/UK residents, we will notify applicable supervisory authorities within 72 hours of discovering the breach
13. Data Retention
We retain personal information only as long as necessary to accomplish the purposes for which it was collected or as required by law:
13.1 Email Lists
- Active subscribers: Retained for the duration of subscription
- CCPA compliance: Retained for at least 3 years from the date of collection
- TCPA compliance: Retained indefinitely to comply with record-keeping requirements
13.2 SMS Lists
- Active subscribers: Retained for the duration of subscription
- Consent records: Retained for at least 4 years to comply with TCPA requirements
- Engagement data: Retained for at least 12 months
13.3 Transactional Information
- Order records: Retained for 7 years for accounting and tax purposes
- Payment information: Not retained; deleted after processing
- Customer service records: Retained for 3 years
13.4 Analytics and Tracking Data
- Website analytics: Typically retained for 26 months or as configured in Google Analytics
- Cookies: Session cookies deleted when you close your browser; persistent cookies expire based on our configuration (typically 2 years)
13.5 Deletion
Upon request or at the end of the retention period, we will delete or de-identify your personal information unless:
- Retention is required by law or regulation
- The information is necessary for legal claims or disputes
- Retention is necessary for security or fraud prevention purposes
14. Children’s Privacy
Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we discover we have collected information from a child under 18, we will promptly delete such information.
If you believe we have collected information from a child under 18, please contact us at sales@dupromos.com.
15. Third-Party Links and Services
Our website and communications may contain links to third-party websites, applications, and services that are not operated by Down Under Promotions. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices.
We encourage you to review the privacy policies of any third-party services before providing your personal information or clicking on third-party links.
16. Social Media and Public Content
If you interact with Down Under Promotions on social media platforms, please be aware that:
- Information you post on social media is public and may be collected and used by third parties
- Social media platforms may collect information about your interactions with our content
- We are not responsible for third-party collection of information through social media platforms
17. International Data Transfers
Down Under Promotions is based in California. Your personal information may be transferred to, stored in, and processed in countries outside your country of residence, including the United States, which may have different privacy protections than your home country.
17.1 Transfers to the United States
If you are located in the EU/EEA or UK, we transfer your information to the United States based on:
- Your Consent: You explicitly consent to transfers for the purposes described in this Privacy Policy
- Standard Contractual Clauses (SCCs): We rely on European Commission-approved Standard Contractual Clauses for transfers of personal information
- Adequacy Decisions: Where applicable, we rely on adequacy decisions recognizing equivalent data protection levels
- Brevo’s Compliance: Our data processor Brevo implements Standard Contractual Clauses and other mechanisms to ensure adequate protection
17.2 Transfers to Other Jurisdictions
For transfers to other countries, we implement appropriate safeguards such as:
- Standard Contractual Clauses
- Binding Corporate Rules
- Your explicit consent
- Legal requirements and obligations
18. California “Shine the Light” Law
California Civil Code Section 1798.83 requires disclosure of whether we share personal information with third parties for their direct marketing purposes.
Down Under Promotions does not share personal information with third parties for their direct marketing purposes.
To request additional information about our privacy practices, contact us at sales@dupromos.com.
19. Do Not Track Signals
Some browsers include a “Do Not Track” (DNT) feature. We currently do not respond to DNT signals because there is no industry standard for recognizing and implementing DNT signals.
20. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or other factors. We will notify you of significant changes by:
- Posting the updated Privacy Policy on our website with a new “Last Updated” date
- Sending you an email notification (for material changes)
- Requesting your consent (where required by applicable law)
Your continued use of our Services following notification of changes constitutes your acceptance of the updated Privacy Policy.
Previous versions of this Privacy Policy are available upon request.
21. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Down Under Promotions
Email: sales@dupromos.com
Mailing Address: 333 Washington Blvd #323, Marina Del Rey, CA 90292
Phone: 310-741-9747
Customer Service Hours: M-F 8am – 5pm
Website: dupromos.com
21.1 Data Protection Officer
Email: sales@dupromos.com
Mailing Address: 333 Washington Blvd #323, Marina Del Rey, CA 90292
21.2 EU Representative (if applicable)
If you are located in the EU/EEA and need to contact an EU representative.
22. Dispute Resolution
Any disputes arising from this Privacy Policy or our privacy practices shall be governed by the laws of California and subject to the dispute resolution provisions in our Terms and Conditions.
23. Acknowledgment
By using our Services or providing your personal information to Down Under Promotions, you acknowledge that:
- You have read and understood this Privacy Policy
- You consent to the collection, use, and disclosure of your personal information as described
- You have received the necessary privacy notices and disclosures
- You understand your privacy rights and how to exercise them
Effective Date: November 1, 2025
Last Updated: November 11, 2025