1. Introduction

By applying to our Affiliate Program, you agree to be bound by this Privacy Policy. This Privacy Policy explains how we collect, use, process and disclose your information. The “Data Controller” is the company that determines the purposes and means of processing your personal data under this Privacy Policy. *Company Name* is the Data Controller under EU Regulation 2016/67 and determines the purposes and means of processing your personal data. For the purposes of this Policy, “we” or “our” means the company responsible for your information under this Privacy Policy. For contact details of the Data Controller, please refer to Section 7.

2. Information We Collect

When you sign up to become an Affiliate, we ask for and collect your username, website URL, email address, country and currency. After you are approved as an Affiliate, we collect your name, address, date of birth, telephone number and, in some cases, your Skype ID.

3. How we use the information we collect

The information you provide to us is necessary to properly perform the contract between you and us, in particular to enforce our Terms of Use, including notifying you of changes to the terms. In some cases, we may also use your data for the following purposes: • Contacting you from time to time about promotions, products or services that may be of interest to you. Only if you have consented to receiving such marketing communications. • Carrying out certain profiling of you in order to personalise, measure and improve our marketing and to send you more relevant marketing communications. In such cases, we process your personal information for the purposes listed in this section, taking into account our legitimate interest in conducting marketing activities to provide you with products or services that may be of interest to you. You may opt out of receiving marketing communications at any time by following the unsubscribe instructions contained in the marketing communication or by changing your notification settings within the interface.

4. Sharing and Disclosure

4.1. Compliance with the law, responding to legal requests, preventing harm and protecting your rights.

We may disclose your information, including personal information, to courts, law enforcement agencies, government authorities or authorized third parties where required or permitted by law or where such disclosure is reasonably necessary. To comply with our legal obligations, (ii) comply with legal process, respond to claims brought against us, (iii) respond to requests in connection with a criminal investigation, suspected or alleged illegal activity or other activities that may expose us, you or any other user to legal liability. The legal basis for this processing is our legitimate interests, namely protecting and asserting our legal rights and ensuring that our business is properly protected against risks.

4.2. Third Party Service Providers

We may use a variety of third party service providers to help us provide services in connection with the Affiliate Program. The service providers may be located within or outside the European Economic Area (“EEA”). These providers have limited access to your information and are obliged to protect and use it on our behalf only for the purposes for which it was disclosed and for purposes consistent with this Privacy Policy. We may share some of your information with these third party service providers to ensure the proper performance of our contract with you, for our legitimate interests and to comply with our legal obligations. We will obtain your consent where required. You may contact us at any time to obtain a full list of our service providers who process your data.

4.3. Corporate Affiliates

We may share your information, including personal information, with any member of our group (meaning our subsidiaries, our ultimate holding company and all of its subsidiaries) to the extent reasonably necessary for the purposes and on the legal basis set out in this Policy.

4.4. Business Transfers

If we undertake or are involved in a merger, acquisition, reorganization, sale of assets, insolvency or bankruptcy proceeding, we may sell, transfer or otherwise share some or all of our assets, including your information in connection with or contemplating such transaction. Investigation of the transaction (e.g. due diligence). In this case, we will notify you before your personal data is transferred and a separate privacy policy applies.

5. Data Subject Rights

In accordance with the General Data Protection Regulation, you have the right to access, correct, port and delete some of your data. You also have the right to object to and restrict certain processing of your data. This will be determined on a case-by-case basis, depending on the nature of the data, the reasons for collecting and processing it, and any applicable legal or operational retention requirements. You may exercise your rights described in this section by sending an email to [email protected] to the Data Controller. We may also ask you to verify your identity before taking further action on your request. Please note that while we will try to accommodate your request in relation to your rights, this is not an absolute right. This means that we may have to refuse your request or may only partially comply with it.

5.1. Managing your information

You may access and update certain information through the interface settings. You are responsible for keeping your personal data up to date.

5.2. Correcting inaccurate or incomplete information

You have the right to ask us to correct inaccurate or incomplete personal data about you (information that cannot be updated within the interface).

5.3. Data Access and Portability

You have the right to access the personal data we hold about you and to receive certain personal data in a structured, commonly used and machine-readable format and/or to request that this information be transmitted to another service provider (where technically feasible).

5.4. Data Retention and Deletion

We will retain your personal data for the period necessary to fulfil our contract with you and to comply with our legal obligations. We will delete your personal data when we no longer need to process it. However, please note that we may be subject to legal and regulatory requirements that require us to retain your personal data for longer periods. You have the right to have certain personal data erased where we no longer need to process your personal data, where you have withdrawn your consent in accordance with section 5.5, where you have raised an objection in accordance with section 5.6, where your personal data has been unlawfully processed, or where we are required to erase your personal data in accordance with a legal obligation. If you request the erasure of your personal data, please note the following: . We may retain and use your personal information to the extent necessary to comply with our legal obligations. b. We may retain some of your personal information where necessary for our legitimate business interests, such as fraud detection and prevention, and security. c. Information we receive about you may be accessed and retained for longer periods of time if it is subject to legal requests or obligations, government investigations, or investigations into possible violations of our terms or policies, or to prevent harm.

5.5. Withdrawal of consent and restriction of processing

Where we have specifically asked for your consent to process your personal data, but there are no other legal requirements that we can rely on, you have the right to withdraw this consent at any time by changing your interface settings or by contacting us at [email protected]. You may also have the right to restrict how we use your personal information, subject to applicable law, in particular where (i) you contest the accuracy of your personal information; or (ii) the processing is unlawful and you object to the erasure of your personal information. (iii) we no longer need your personal data for the purposes of the processing, but we require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to processing pursuant to the following section and are waiting for the verification that the legitimate grounds of the data controller override your grounds.

5.6. Objection to processing

You have the right to object to processing where our legitimate grounds are in our interests. However, we may still process your personal data where there are other relevant legitimate grounds or compelling grounds for continuing to process your personal data that are not overridden by your rights, interests or freedoms; You also have the right to object to direct marketing by opting out of direct marketing via the interface settings or via the communication itself. You also have the right to object to profiling that is related solely to direct marketing.

5.7. Accommodation complaints

You have the right to lodge a complaint with the competent data protection authority regarding the data processing activities carried out by the data controller. For more information, see section 7.

6. International transfer of your information

To facilitate our global operations, we may transfer, store and process your information within our affiliates and share it with service providers outside of Europe for the purposes described in this Privacy Policy. When we transfer your personal data outside the EEA, within our Group or to business partners, we will take all reasonable steps to ensure that appropriate measures are in place to keep your personal data as secure as it is within the EEA, including the use of standard contractual clauses, binding corporate rules or other acceptable means of protecting your data in accordance with the standards required by the EEA and in accordance with this Privacy Policy. You may contact us at any time to obtain a full list of our service providers outside the EEA who process your data.

7. Contacting us

If you have any questions about this Policy or our information processing practices, or if you wish to exercise your rights under the General Data Protection Regulation, please contact our Data Protection Officer at [email protected]. The data controller responsible for your information is *Company Name*, Registration Number*, *Registration Number*, *Address*.

8. Complaint

If you are not satisfied with the way we manage your personal data, you also have the right to lodge a complaint with your local data protection authority.