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Privacy Policy

We at Affburg Limited and/or any of our related entities (herein referred to as: “Affburg”, “We”, “Our”, “Us”) have created this Privacy Policy to demonstrate our dedication to respecting your privacy. This Privacy Policy sets out our practices with respect to personal information collected from the visitors of Affburg.com (hereafter referred to as the “Site”) as well as registered affiliates (collectively referred to as “you”). The Site operates the Affburg Affiliate Program (hereafter referred to as the “Platform”) and is solely restricted to adults who are capable of entering into contractual relationships.

Persons under the age of eighteen (18) or the age of majority in their respective jurisdiction are prohibited from using the Site or registering for an account with the Program. We do not intentionally collect personal data from individuals under the age of eighteen. If you believe that we may have inadvertently collected personal information from someone under this age, please contact us immediately. Upon verification, we will take steps to delete such information permanently.

By accessing the Site, you acknowledge and agree to the terms of this Privacy Policy, which may be updated periodically, as well as the Terms of Use available on the Site. Additionally, by registering for an affiliate account, you agree to the terms outlined in the Affiliate Terms and Conditions and the Data Protection Addendum.

How We Collect Your Personal Information

The personal information we collect depends on your interactions with us, the Site, or the Platform, your preferences, and the services you use. We primarily collect your data through the information you provide directly to us and data shared by third parties. Below are the methods we use to collect your personal information:

Information You Provide Directly to Us:

When you complete registration forms or other forms available on our Site or Platform.
When you fulfill contractual obligations.
When you reach out to us for inquiries, support, complaints, or for any other reason.
When you share information or content on our Site.

Personal Information Collected from Other Sources:

When you interact with our Site via social media networks.
Through third parties, including our business partners, advertisers, contractors, or vendors, in a manner permitted by law, such as through tags embedded in websites you use or manage.

Automatic Information:

Like many websites, we use “COOKIES” and other unique identifiers. These technologies, on their own, do not identify you personally but help us collect certain types of data, including

When your web browser or device accesses the Site or Platform.
When you engage with content and services available on the Site or Platform.

Collection of Information

We collect the following information to provide you with better services:

Type of Data Collected	Purpose	Legal Basis of Processing
Data about your use of our Site IP address, geographical location, device type, browser type and version, browser language, operating system, referral source, browsing behavior, length of visit, page views, website navigation paths, timing, frequency, click-stream data.	To analyze and improve the operation of our Site and Platform, diagnose server issues, administer services, understand visitor usage, conduct internal reviews (e.g., visitor counts), and safeguard the Site security and integrity.	For purposes related to our legitimate interests, such as managing, monitoring, and enhancing the functionality of our Site, Platform, and services. Consent is obtained where required.
Affiliate’s account data affiliate name, birth date, physical address, phone number, e-mail address, instant messenger address, payment method information such as bank account information (to the extent needed to pay for or receive payment as part of providing services of our Platform), password, and, on occasion, a unique identifier (such as mother’s maiden name, for example), user identifier.	To operate our Site, deliver Platform services, communicate with you, and complete verification procedures.	Legitimate interests in ensuring the proper administration of our Site or Platform and fulfilling our contractual obligations to you.
Data requests	To handle your requests, verify your identity or contact details, and fulfill payment obligations while preventing fraud.	Consent and fulfillment of the contract we have with you.
Commercial and Transaction data. Information such as information about payments made, received, or due as part of the Platform	Transaction data may be processed for the purpose of processing payments and maintaining accurate records of those transactions.	Fulfilling the terms of the contract we have with you.
Cookies and Tracking Technologies	Used to track user behavior, improve functionality, and personalize experience.	Consent, Legitimate Interests

As we collect and protect your personal information, including your email address, we make every effort to respect your time and privacy by limiting the frequency of our mailings. If you receive an email from us or one of our marketing partners, it is because your email address is either on file with us as someone who has explicitly shared it for future communications, or because you have registered, made a purchase, or have an existing relationship with us. By registering for our affiliate program, you consent to receiving occasional mailings.

COOKIES

We automatically collect certain information when you visit, use, or navigate the Site. While this data does not reveal your specific identity (such as your name or contact details), it may include technical information like your IP address, browser and device details, operating system, language preferences, referring URLs, device name, country, location, and usage patterns on our Site. This information is mainly used to ensure the security and functionality of our Site, as well as for internal analytics and reporting purposes.

Additionally, we may use third-party software to display ads on the Site, run email marketing campaigns, and manage other interactive marketing activities. These third-party tools may use cookies or similar tracking technologies to enhance and optimize your online experience with us.

Note: Some cookies are essential for the Site's functionality, and refusing or disabling certain cookies may impact your ability to use the Site effectively.

WHO DO WE SHARE YOUR PERSONAL INFORMATION

We may disclose your personal information to the following types of third parties:

Payment Providers: Who assist us with payment verification and processing.
Web Hosting, Optimization, Email Marketing, Management, and CRM Services: Companies that help with the hosting, operation, optimization, and maintenance of our Site, manage Platform accounts, and provide access to secure areas and functionality on our Site.
Analytics Services: We may use web analytics services, such as Google or other third parties, to track and report website traffic. Google uses the data collected to monitor and analyze the usage of our Site.

We may also disclose information about you:

If required by law or legal process;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity;
If necessary to protect the vital interests or legal rights of another individual;
In the event of a corporate reorganization, sale, or transfer of all or part of our business or assets;
To any other party with your consent to the disclosure.

WHERE WE TRANSFER YOUR PERSONAL INFORMATION

Your personal information may be transferred to and stored on servers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your area. If you are located outside the country where Affburg is based and choose to provide us with personal information, please be aware that we may transfer and process your information in any location where Affburg operates.

THIRD-PARTY LINKS

There may be times when you receive special offers from us or third-party service or content providers, including communications, newsletters, commercial advertisements, or other promotional materials. By consenting to this Privacy Policy, you also consent to receiving occasional mailings from us and our third-party service or content providers.Affburg is not responsible for the use of any information you provide, or that is collected by third-party websites that display ads or links on the Site. We do not control, monitor, or endorse the information-gathering practices or Privacy Policies of those third-party websites. Whenever applicable, we encourage each affiliate to review the Privacy Policy of any third-party website provider that displays an advertising banner, advertises, or includes a link on the Site or in an email.

INFORMATION FOR RESIDENTS OF EUROPEAN COUNTRIES

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), you have certain rights and protections under Regulation (EU) 2016/679 (General Data Protection Regulation) and the United Kingdom General Data Protection Regulation (UK-GDPR) regarding the processing of your “personal data” as defined under applicable law. Some of the information Affburg collects from you through the operation of the Site may qualify as “personal data” under these regulations.

When we determine the purpose or means by which personal information is collected and processed, we act as the “Controller” under the GDPR and UK-GDPR. As a Controller, Affburg has implemented appropriate technical and organizational measures to ensure that data processing is carried out in compliance with the GDPR. These measures will be regularly reviewed and updated as needed, based on the nature of the data collected.

Please note that Affburg will not be held responsible for any data collected by affiliates or advertisers who use Affburg's services. These affiliates and advertisers are responsible for the processing of their own data.

As a Processor under the GDPR classification, Affburg collaborates with our partners (Data Controllers and other Data Processors) to ensure that all user data is handled in accordance with the agreed terms and in compliance with relevant regulations and laws.

What Data Protection Rights Do You Have

As applicable and except as limited by law, residents of European Countries have rights including access, rectification, erasure, restriction, objection, data portability, and protection from automated decision-making, as outlined by relevant data protection regulations.

Exercising Your Rights

To exercise your rights, please refer to Section 12 “REQUEST FOR EXERCISE OF RIGHTS” below; we will process your requests within 30 days and notify the relevant supervisory authority within 72 hours of a breach, with our Data Protection Officer (DPO) available at [email protected] to ensure compliance with data protection responsibilities.

Data retention

We retain personal information only as long as necessary to fulfill the purpose for which it was collected, such as during your registration on our Site or Platform, to address legal claims, or as required by law, and securely delete it when no longer needed, with any data used for statistical purposes anonymized.

Transfer

In the course of business, we may transfer personal information to our related entities and (sub)contracted service providers, both within and outside the European Countries, and when transferring data to countries without adequate protection under EU or UK laws, we ensure that specific contracts with standard contractual clauses are in place to guarantee compliance with data protection laws, including GDPR and UK-GDPR.

CALIFORNIA CONSUMER PRIVACY RIGHTS

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (California Civil Code Section 1798.100 et seq.), grants California residents certain rights regarding the processing of personal data. Under the CCPA, “Personal Information” refers to data that identifies, relates to, describes, or can be associated with California consumers or households. This supplement provides additional privacy disclosures and details on rights and should be read alongside our Privacy Policy.

California residents are defined as individuals in California for other than temporary purposes, or those domiciled in California but temporarily outside, and for employee-related requests, please contact Affburg's HR Department, while rights requests regarding Affburg's clients must be directed to those clients, with information on personal data collection and processing outlined in Section 2 “WHAT INFORMATION IS COLLECTED.”

What Data Protection Rights Do You Have

As a California resident, you have certain rights with respect to the personal information collected by businesses.

Right to Access. You have the right to request information about the types of personal information that Affburg collects, uses, discloses, and sells. This includes the following details: (a) the categories of personal information Affburg collects about you; (b) the sources from which Affburg has obtained your personal information; (c) the business or commercial purposes for collecting or selling your personal information; (d) the categories of your personal information that Affburg sells to third parties; (e) the categories of third parties to whom Affburg sells your personal information; and (f) the specific personal information Affburg has collected about you. Affburg will provide this information to you upon proper verification of your request. You may submit a verifiable request related to your personal information free of charge up to twice every 12-month period.
Right to Correct Inaccurate Personal Information. If you believe that Affburg holds incorrect personal information, you have the right to request that Affburg correct it.
Right to be Forgotten. You have the right to request the deletion of any personal information that Affburg has collected or retains about you, subject to specific exceptions for business purposes under applicable law. Upon receiving and verifying your request, Affburg will delete your personal information, unless an exception applies.
Right to Non-Discrimination. You have the right to exercise your CCPA rights without being discriminated against. Affburg will not discriminate against you in any way if you choose to exercise your rights under the CCPA.

Right to Opt-Out. You have the right to instruct Affburg not to sell or share your personal information with third parties at any time. PLEASE NOTE THAT AFFBURG HAS NEVER SOLD OR SHARED, AND WILL NOT SELL OR SHARE, ANY PERSONAL DATA OBTAINED FROM YOU.

Sensitive Personal Data Processing

The CPRA requires data controllers to obtain consumer consent before processing sensitive personal data. Please note that Affburg does not typically collect sensitive personal data from California residents visiting our Site and will not process such data if collected unintentionally. Therefore, we will not seek consent for the processing of sensitive personal data obtained from the Site.

REQUEST FOR EXERCISE OF RIGHTS

To exercise your rights to know, access, correct, and be forgotten as described above, please submit a verifiable consumer request to Affburg by email at [email protected]

Upon receiving your request, we will need to verify your identity to confirm that you are the person whose information we have in our system. To do this, we may ask you to provide information that can be matched with the details you've previously shared with us. Depending on the type of request, we may also contact you through a communication method you've previously provided. Additionally, we may use other verification methods as necessary based on the situation.

NOTE: We cannot delete your personal information without also deleting your user account. We may also be unable to accommodate a request to change information if we believe the change would violate any law or legal requirement, or result in incorrect information.

REQUESTS MADE THROUGH AGENTS – You may designate an authorized agent, either in writing or through a power of attorney, to submit requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require proof that you have authorized them to act on your behalf, and we may ask you to verify your identity directly with us.

HOUSEHOLD REQUESTS – Affburg does not currently collect household data. If all members of a household submit a Right to Know or Right to Delete request, we will treat each request as an individual request.

WARNING! Please exercise your rights responsibly, as misuse of these rights may result in liability.

SECURITY

At Affburg, we prioritize the protection of your personal information through a combination of organizational and technical security measures. These include Secure Shell Protocol (SSH), multi-factor authentication, access control (physical and technical), and link encryption. We use Secure Socket Layer (SSL) encryption to safeguard sensitive/credit information. While we implement robust security protocols, no system can guarantee complete security, and we cannot warrant the absolute safety of your personal information. The transmission of data to and from our Site or Platform is at your own risk, and we recommend accessing our services in a secure environment. Additionally, we are not responsible for the security of information shared with third-party providers who advertise on our Site but are not affiliated with us.

ACCEPTANCE OF THE PRIVACY POLICY

By visiting or registering as an affiliate with Affburg, you agree to the practices outlined in this Privacy Policy. We may update or modify these terms at any time, with or without notice, depending on the nature of the changes. You are bound by any revisions, so we recommend periodically reviewing this page to stay informed of the current terms. Please note that if you visit third-party sites through our Site, such as those of our advertisers, their privacy practices will govern the collection and use of your information. Affburg is not responsible for the policies, content, or practices of external companies or third-party web service providers that may collect personal information through advertisements or links on our Site.

CHANGES TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in applicable laws, regulations, technology, or our business operations. Any future changes will be posted on this page. If the changes impact how we process your personal information, we will notify you via email or other contact methods where appropriate, and may also post a notice on our homepage to inform you of the update.

Contact Us

If you have any questions about this Privacy Policy, please contact us at: [email protected].