Privacy Policy

⚠️ DRAFT — placeholder, not legal advice. This page is scaffolding so the signup consent links resolve. It is not a binding policy and has not been reviewed by a lawyer or a privacy specialist. Replace every section below with counsel-approved copy before launch. Do not rely on anything here.

Last updated: DRAFT — replace with the effective date.

1. What we collect

Account details (name, email), authentication data, the publisher and payout information you provide, and usage/click/conversion data generated as you use the service. [Placeholder — enumerate every category and its source.]

2. How we use your data

To operate the service, attribute conversions, calculate and send payouts, prevent fraud, and communicate with you. [Placeholder — full list of purposes.]

3. Legal bases

[Placeholder — GDPR/UK-GDPR legal bases (contract, legitimate interest, consent) per processing purpose. Draft with counsel.]

4. Sharing and processors

We share data with the affiliate networks required to fulfil attribution and with infrastructure processors (for example hosting, email, and edge providers). [Placeholder — name the processors and the safeguards.]

5. Cookies and tracking

We use cookies and edge tracking to attribute clicks to publishers. [Placeholder — cookie table and consent approach; reconcile with any cookie banner.]

6. Data retention

We keep data for as long as needed to provide the service and meet legal and financial obligations. [Placeholder — concrete retention periods.]

7. Your rights

Depending on your location you may have rights to access, correct, delete, or port your data, and to object to certain processing. [Placeholder — how to exercise them and the response timeline.]

8. Security

We use encryption at rest for sensitive fields such as payout details and access controls around your data. [Placeholder — describe the security programme accurately; do not overstate.]

9. International transfers

[Placeholder — describe cross-border transfers and the transfer mechanism.]

10. Changes and contact

We may update this policy and will notify you of material changes. Questions or requests: [Placeholder — privacy/DPO contact address.]