Personal information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our website (affiliate.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A:Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
• Marketing partners.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data
Portability Rights
• You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us
[email protected]Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
Contact Information:
[email protected]
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
[email protected].
Section 2: Publishers
This section describes what information is collected by Affiliate.com from Publishers, and how that information is used by Affiliate.com.
What information we collect from Publishers
When a Publisher signs up to use the Service, we collect and store various pieces of Personal Information about the Publisher, which may include:
• Company Name
• Name and related contact details
• Email address
• Phone number
• Address
• Telephone number
• Website information
• Payment details
We also collect and store information about when and how a Publisher uses the Publisher Hub, including reports and other tools and interfaces provided by us.
How we use Publisher information
We use this Publisher information to perform our obligations under the Agreement, including:
• To assess the suitability of Affiliate.com Enabled Sites for the Service
• To contact Publishers to help them with registration, use and optimization of the Service
• To pay Publishers their share of the commissions earned through the Service
• To communicate with Publishers on Affiliate.com-related matters
• To provide Publishers with performance and billing information
• To improve the service we provide to Publishers based on how Publishers use our service and the tools which we provide to them.
• To introduce Merchants and Advertisers who may wish to purchase services from or partner with the Publisher.
Updating Publisher information
Publishers can edit any of their Personal Information within the Publisher Hub. It is the Publisher’s responsibility:
• To protect against unauthorized access to their details and the Publisher Hub
• To log-off from the Publisher Hub when not using it
• To keep its password secret.
What does Affiliate.com do on Affiliate.com Enabled Sites?
Depending on which of the Tools has been enabled via the Publisher Hub, this JavaScript file will do the following:
• Collect and store information about Users behaviors on a site (including impressions and links clicked), so we can monetize such behaviors from participating Merchants, and report on them for Publisher and Merchant reports.
• Collect and store information about Affiliate.com Enabled Sites, to provide the Service.
• Drop an Affiliate.com cookie when a User visits a web page or clicks an outbound link.
What information relating to Users does Affiliate.com collect?
Affiliate.com will not knowingly collect or store any information which enables us to determine the actual identity of Users visiting an Affiliate.com Enabled Site.
Affiliate.com uses cookies to collect Usage Data relating to Users. This Usage Data is used by Affiliate.com to optimize the performance and yield of the Service, to provide comprehensive reporting to Publishers, and to provide reporting and targeting services to Merchants, Advertisers and other third parties. Usage Data cannot generally be used to identify a specific person. For more information regarding cookies, please see Section 1 of this Privacy Policy.
Affiliate.com provides an opt-out service for Users who do not wish for their Usage Data to be used for advertising targeting purposes.
Do Publishers need to update their own privacy policies if they use Affiliate.com?
It is the responsibility of the Publisher to ensure that its privacy policy, ‘About Us’ or other relevant website section includes the following information, and that the Publisher gives notice to each User (whether in a privacy policy or otherwise) containing these provisions:
• A statement regarding use of the Service on the Affiliate.com Enabled Site(s). For example: “Our website contains some affiliate marketing links, which means we get paid commission on sales of those products or services we write about. Our editorial content is not influenced by advertisers or affiliate partnerships. We use Affiliate.com and more information about their data collection is set out in their privacy policy located at www.affiliate.com.”
• Full details about cookies which are dropped by Affiliate.com onto Users’ Computers when Users view a web page or click on an affiliate link on Affiliate.com Enabled Sites. Publishers must at a minimum include the information that can be found in Section 4 below under the heading of ‘What information does Affiliate.com collect about Users through its technology and how does it use this information?’. Publishers should also provide a link for Users with information regarding how they can disable the use of Affiliate.com optimization cookies, as set out in Section 4 below under the heading of ‘How can I disable Affiliate.com cookies?’.
What we share with third parties
We may share with certain key partners and advertisers some anonymous Publisher information in order to optimize our Advertiser and Merchant relationships and increase revenue yields for Publishers.
Data retention
We retain Personal Information we collect from the Publisher indefinitely for fraud prevention and regulatory compliance.
Section 3: Merchants
This section describes what information is collected by Affiliate.com from Merchants, and how that information is used by Affiliate.com.
What information we collect from Merchants
When a Merchant signs up to use the Service, we collect and store various pieces of Personal Information, including:
• Full name of the Merchant and, if different, the name of the Merchant contact
• Email address
• Telephone number
• Website information
• Address
• Payment details
How we use Merchant information
We use this Merchant information to perform our obligations under the Agreement, including:
• To assess the suitability of the Merchant for the Service
• To contact Merchant to help them with registration, use and optimization of the service
• To communicate with Merchants on Affiliate.com-related matters
• To provide Merchants with order and billing history information
• To improve the service we provide to Merchants based on how Merchants use our service and the tools which we provide to them.
• To introduce Publishers who may wish to enter into agreements with the Merchant.
What does Affiliate.com do on Affiliate.com Enabled Sites?
Once a Merchant’s application is accepted, we will:
• Collect and store information about content available in the browser on the Merchant’s Affiliate.com Enabled Site; including but not limited to URLs, product names, SKUs, prices, order value, order identifier and customer identifier tokens.
• Drop an Affiliate.com cookie when a User visits a Merchant’s Affiliate.com Enabled Site, so we can record non-identifiable information about the pages and products viewed by Users.
Do Merchants need to update their own privacy policies if they use Affiliate.com?
It is the responsibility of the Merchant to ensure that its privacy policy, ‘About Us’ or other relevant website section includes information about the use of cookies, and that the Merchant obtains each User’s consent to cookies. The Merchant should share full details about cookies which are dropped by Affiliate.com onto Users’ Computers. Merchants should at a minimum include the information that can be found in Section 4 below under the heading of ‘What information does Affiliate.com collect about Users through its technology and how does it use this information?’.
Merchants should also provide a link for Users with information regarding how they can disable the use of Affiliate.com cookies, as set out in Section 4 below under the heading of: ‘How can I disable Affiliate.com cookies?
If the Merchant is based in the European Union or offers goods and services to customers based in the European Union, the Merchant must also seek the consent of Users before Affiliate.com cookies are dropped via their site. Merchants can decide how to obtain consent but Affiliate.com suggests that Users are requested to consent to the terms of the Merchant’s privacy policy the first time they arrive on the Merchant’s site. After initial provision of consent by a User, it need not be provided again, unless the purpose of cookies dropped via the Merchant’s sites is changed. If Affiliate.com makes relevant changes to its cookies, we will notify you accordingly.
For properties in other regions, if the above rules are not sufficient for compliance with local legislation or regulation, please provide a link to the Affiliate.com Privacy Policy.
What we share with third parties
We may disclose your personal data to third parties: In the event that Affiliate.com identifies a Publisher with which a Merchant could have a commercial relationship, to make introductions.
Data retention
We retain Personal Information we collect from the Merchant indefinitely for fraud prevention and regulatory compliance.
Section 4: Users
This section explains how Affiliate.com operates through Affiliate.com Enabled Sites, and how information about Users is obtained and used by Affiliate.com.
What is Affiliate.com?
Affiliate.com offers a service to Publishers to help them earn an income and gain insights from their commerce-related content. The service works by creating/tagging links within content that a User is reading which, if clicked, takes the User to a Merchant website where the products and/or services can be purchased. If the User then buys something as a result of clicking on these links, the Publisher is paid a referral fee. This referral fee does not come out of Users’ pockets, nor does it affect the price Users pay or the experience Users have on the Merchant’s site.Affiliate.com also offers Merchants and Advertisers a service that helps them to better understand and target Users’ behaviors, and to identify and work more effectively with Publishers and third parties on marketing campaigns.
What information does Affiliate.com collect about Users through its technology and how does it use this information?
• We store Users’ IP addresses, from which we can determine a User’s approximate geographical location (e.g. country or region). We need this information to optimize the links that are created/monetized to suit the geography of the User, and to provide aggregate reporting to Publishers, Merchants and Advertisers on the location of users visiting Affiliate.com Enabled Sites. We also use IP addresses as part of our efforts to reduce fraud and identify non-human browsing patterns.
• We store information about the device that a User uses to access sites within our Publisher network, such as the browser type, browser version, and type of device. This helps us ensure we can diagnose and fix browser compatibility issues more swiftly, optimize our service to suit the preferred browsing environments, and provide aggregate reporting to Publishers, Merchants and Advertisers.
• We store non-identifiable information, using cookies and device identifiers, about the websites within our Publisher network that Users visit, which of our links Users click on, and whether Users make a purchase. This enables us to provide Users with relevant and useful links and advertising to products and/or services in which they are likely to be interested, and to Merchants and Advertisers from whom they are likely to want to buy.
• As part of the information available in standard web serving logs, we also store information about the referrer, i.e. the website page from which the User linked to the Affiliate.com Enabled Site.
• To provide Publishers and Merchants with the Service, we collect information on visits and sales on Affiliate.com Enabled Sites, including but not limited to order value, products bought, and order identifiers. These are used to help Publishers, Merchants and Advertisers make better marketing and content creation decisions.
• At no time do we know who a User is, nor do we make any attempt to try and identify a User.
We use cookies to collect the information we need to optimize the product/Merchant links we monetize/create, and improve the service we provide to Publishers, Merchants, Advertisers and Users. Cookies also enable us to carry out audience segmentation, i.e., we divide Users into groups based upon defined criteria such as product usage, demographics, communication behavior and media use. We synchronize cookie identifiers with third parties in order to enrich the Service and offer personalized experiences across the web. As you browse Affiliate.com Enabled Sites, cookies will be placed on your Computer so that we can understand what you are interested in. These anonymous profiles allow for the customization of websites and targeting of content, including but not limited to advertising.
How can I disable Affiliate.com cookies?
If you no longer want to work with Affiliate.com you must terminate your account.
In order for referral fees and commissions to be paid by Merchants to Publishers, Affiliate.com works with affiliate networks and other ad networks that manage the relationships between Affiliate.com and the Merchants. As set out above, Users who receive Affiliate.com cookies are also assigned a unique identifier number.
When a User clicks on a link created by a Tool, Affiliate.com attaches the User’s unique identifier number so it passes to the appropriate affiliate network for the purpose of tracking whether that User makes a purchase on the Merchant website they visit. Note that at no time do we pass any Personal Information, nor make any attempt to determine the actual identity of an individual User; all information is completely anonymous and used only for the purposes of optimizing the service provided to the User. The affiliate and ad networks that work with Affiliate.com also use their own cookies in order to track if a sale has occurred, as most of these parties will only pay Publishers when a referral has been successful, i.e. a sale was completed. We do not have control over or access to these cookies and they are dropped by the affiliate and ad networks via our Affiliate.com Enabled Sites.
Data Retention
We retain Personal Information we collect from you for up to three years. After that we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
