Social plugins

click2commission participates in and markets via social media networks and has implemented certain social media plugins and links to social networks on our websites.

These social networks are operated exclusively by third parties. If you follow the links, data may be transferred to these providers.
All social media plugins are used so that you can interact with us using social network features.
When you enter a page on our website that contains a social network plugin, your browser or app will establish a direct connection to the social network’s servers.

This processing of (personal) data is necessary for our legitimate interests (i.e., marketing by increasing the range of our website/services).

Analytics tools

We use Google Analytics, Microsoft Clarity, and Yandex.Metrica tools on our website for the purposes of the adequate design and continuous optimization of our website, as well as reporting on website usage.

You can learn more about how they use your data and find out how to opt out here (Cookies Policy).

Personal data in the “contact details” form.

For the purpose of receiving feedback or any questions you may have, we may collect data about you that may include:

• Full Name
• Email
• Country
• I am interested in
• Anything else you’d like to tell us? data that you might in an email or comment. You provide this data to us by using the “Contact us” form or by the email you send.

3.2.   for publisher or advertiser

3.2.1. If you’re a publisher or advertiser

Registering and participating in our network
To obtain access to our technologies and services, you must register in our network. After that, in addition to the data described in the policy for visitors, we collect and process:

• Personal data you provide in the registration form: your name, country, email address, username, etc. The username will be available to other Internet users when working with certain programs.
  
• Data you provide during your participation with click2commission, e.g., your phone number, postal address, and/or tax number.

The processing of personal data is necessary for the performance of a contract.
We do not collect or use any personal data other than the data that you voluntarily provide.

3.2.2. The click2commission Extension for Publishers

The click2commission Extension allows publishers to generate deeplinks and manage their accounts.

click2commission Extension Store
The click2commission Extension can be downloaded through the Chrome Web Store. This service is offered to third parties. If you visit the Chrome Web Store, your data may be disclosed to them. For information on the volume of data processed and the reasons for which it is processed, as well as on your rights and setup options, please see Google’s Privacy Policy: https://policies.google.com/privacy?hl=en

click2commission Extension for Browsers
When you download and use the click2commission Extension, your personal data is processed as described in this section. Below, you can find information about the legal bases and purposes for the processing of your personal data and, if applicable, the legitimate interests involved and the necessity of doing so.

Downloading the click2commission Extension
The app can be downloaded through browser web stores (Google Chrome Web Store, Opera, Microsoft Edge, and others). This service is offered by third parties. When you download click2commission Extension, Chrome Web Store may collect your personal data. For information on the volume of data processed and the reason for processing it, as well as on your rights and setup options, please see the stores’ respective privacy policies.
Here is an example of some stores:

Chrome Web Store
The app can be downloaded through the browser web store (Chrome Web Store). This service is offered by third parties. When you download click2commission Extension, the Chrome Web Store may collect personal data strictly necessary to allow you to download and install the app. For information on the volume of data processed and the reasons for processing it, as well as on your rights and setup options, please see Google’s Privacy Policy: https://policies.google.com/privacy?hl=en

Opera Addons
The app can be downloaded through the browser web store (Opera Addons). This service is offered by third parties. When you download click2commission Extension, Opera Addons may collect personal data strictly necessary to allow you to download and install the app. For information on the volume of data processed and the reasons for processing it, as well as on your rights and setup options, please see Opera Privacy Statement: https://www.opera.com/en/privacy

Microsoft Edge Add-ons
The app can be downloaded through the browser web store (Edge Add-ons). This service is offered by third parties. When you download click2commission Extension, Microsoft may collect personal data strictly necessary to allow you to download and install the app. For information on the volume of data processed and the reasons for processing it, as well as on your rights and setup options, please see Microsoft’s Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement

Legal bases and purposes for the processing of your personal data and the necessity of doing so, We process your personal data in order to fulfill our obligations under the terms of use . We may also process your personal data with your permission in the instances and to the extent described below. You are not obliged to download or use the extension.

If you do not provide your personal data, some features of click2commission Extension may be unavailable. There will be no other consequences for you.

Using the click2commission Extension

If you use the click2commission Extension, we will process your personal data to facilitate your use of the app for internal analytics and direct marketing.
To work, the app needs to be given access to your account.
For the click2commission Extension to work properly, it needs:
To be given access to the following data in your personal account:

• User ID, login, name, personal account settings
• Email address
• Telephone number
• List of ad spaces
• List of programs connected to your ad spaces
• Reports on ad spaces, actions, time, and programs (affiliate, referral, and any other)
• Financial data (payment info, payment methods, funds being processed, confirmed funds, funds ready to be withdrawn, ability to request payments)

To collect the following information:

• URLs of websites you visit
• Data on the installing/registering/initializing of the extension
• Deeplinks you generate with your SubID, affiliation with your ad space, and affiliate program.

You can block the app’s access in the API and app  section in account settings at any time.
The click2commission Extension creates cookies in your browser and collects additional information to evaluate the app’s functionality and carry out statistical analysis through Google Analytics. This includes:

• Information about the device (type, OS, language setting, device ID, app ID, location)
• Initialization of the extension, clicks on various elements in it, values chosen, and data entered
• URLs of websites you visit.
• ID issued by Google Analytics
• Session ID
• Action ID (a timestamp with the time of the local action is used)
• ID for all of the user’s actions.

You can also set up an add-on that deactivates Google Analytics: http://tools.google.com/dlpage/gaoptout?hl=en.

Data transfer from the click2commission Extension to third parties
Your data may be disclosed to the following third party to facilitate the use of deeplinks:
TakeAds  GmbH, Germany

For the purposes of statistical analysis, your data will be sent to the Google Analytics platform:
Google (Google LLC (“Google”), located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States.
https://policies.google.com/privacy?hl=en-US

3.2.3. Integration with Google Ads for publisher

This is a tool for Publishers who buy traffic from the Google Ads contextual advertising service and drive it to our advertisers’ websites directly or through the landing page. For information on the volume of data processed and the reasons for which it is processed, as well as on your rights and setup options, please see Google’s Privacy Policy: https://policies.google.com/privacy?hl=en
When you use the integration with Google Ads, your personal data is processed as described in this section. This integration type allows us to access data from your Google Ads advertising campaigns. Below, you can find information about the legal bases and purposes for the processing of your personal data and, if applicable, the legitimate interests involved and the necessity of doing so.
When you use the integration with Google Ads, we collect your personal data, including your Google account ID and Click ID (GCLID). This allows you to configure the sending of actions from click2commission to the corresponding advertising campaigns in the Google Ads advertising account.
If you choose not to provide personal data, the Integration with Google Ads tool will not be able to function. There will be no other consequences for you.

3.2.4. Use of Tracking URLs for publisher

What are tracking URLs?
A tracking URL is a special web address that we use to monitor user activity within our affiliate programs. This tool assists both us and our partners in understanding how specific traffic sources, activities, or user actions are associated with user registrations, purchases, and other target actions.

Purpose of tracking
Tracking URLs are fundamental to the services we provide on our platform to our partners as part of our contract with third parties (Advertisers and Publishers) in accordance with Article 6(1)(b) of the GDPR. These URLs are optimized to analyze user click behavior and supply our partners with valuable feedback on their advertising strategies.

Data we collect
When a user interacts with a tracking URL, we may collect the following information:
click_id: A distinct online identifier generated when a user clicks a link.
referrer_url: It identifies the web page from which the resource was requested.
The country where the click was made.
The date and time of the user’s visit to the URL.
Information about the user’s device and browser.
Other parameters related to specific affiliate programs.

We also collect the following data components: website_id, website_name, banner_id, publisher_id, publisher_name, channel_id, group_id, uid (synonymous with click_id), referrer_url, country_code, and timestamp (a component that converts the time of the click into a UNIX timestamp).

For our publishers’ users (users who follow a publisher’s affiliate link):
User privacy is our priority. We do not collect the personal data of users who click on a publisher’s affiliate link (such as names or email addresses) using tracking URLs. We only aggregate anonymized data about these users.

For publishers:
We do not collect the personal data of publishers (publisher_name, email addresses) using tracking URLs unless explicitly stated in the context of a specific affiliate program.

Third parties
We collaborate with various partners and advertisers. Some of them may use our tracking URLs to evaluate the effectiveness of their affiliate programs.

3.2.5. Stripe for advertiser

We use Stripe, a payment processing software, for billing advertisers. Stripe may store your bank account and/or credit card details (referred to as “Payment Information”). We connect with those third parties to bill you for payments associated with using the Service. We do not store or process payment information, such as your credit or debit card number, or your bank account number.

3.2.6. Userflow for advertiser

We use Userflow, a user onboarding software, for onboarding advertisers. To tailor the onboarding process to user specific needs and preferences, we pass to Userflow the following information: username, email, country, date of registration, and type of subscription. Userflow does not collect any information from users’ browsers.

3.3.   for publisher and advertiser users

3.3.1. Behavioral targeting
click2commission does not conduct behavioral advertising and does not collect data for these purposes. However, our Publishers may use cookies for behavioral advertising purposes.

For this reason, we would like to draw your attention to your ability to object to the collection of data for purposes of targeted advertising on the following websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/en/ (for the European Economic Area).

3.3.2. Online identifiers
If a Publisher installs the script/API from https://api.click2commission/, the Publisher is obliged to send data regarding online identifiers after receiving in advance your consent to send such data to click2commission. click2commission processes your data based on the agreement with the Publisher and at the instruction of the Publisher, who transfers this data with your consent.

3.3.3. Newsletters

With the following information, we will inform you of the contents of our newsletter and the procedure for the registration and dissemination of newsletters, and the evaluation of statistics thereof, as well as your right to object to the procedure. By subscribing to our newsletter, you agree to the receipt of the newsletter and the procedures described.

We send out newsletters, emails, and other electronic notifications with promotional information (hereinafter “Newsletter”) subject to the recipient’s consent or legal permission.

Registering for our newsletter is handled through a so-called double opt-in procedure, which means you will receive an email after you register, in which you will be asked to confirm your registration once again. Registrations for the newsletter are recorded to prove adherence to the precise registration process according to legal requirements. This includes storing the time of logon and confirmation. Furthermore, changes to the data stored by Mindbox, a third-party service, are also recorded.

The newsletters can be sent by click2commission or Mindbox.

Mindbox is a newsletter platform of the Dutch company Mindbox.Cloud B.V. (a Dutch private limited company) located at Strawinskylaan 613, 1077XX Amsterdam, The Netherlands.

The email addresses of our newsletter recipients and further data described in the context of this information are stored on click2commission’s and Mindbox’s respective servers. Mindbox uses this information to send out and evaluate the newsletters on our behalf. In addition, Mindbox can use this data to optimize or improve its services, e.g., for the technical optimization of the dissemination and the presentation of the newsletter or for economic purposes to determine from which countries the recipients come. However, Mindbox does not use the data of our newsletter recipients to contact them independently or transfer data to third parties except in cases prescribed by Mindbox’s Privacy Policy (https://mindbox.cloud/documents/privacy-policy/).

To register for the newsletter, we only need your email address. Any other voluntarily provided information about you is only used to personalize the newsletter. You can change the personal data you share with us at any time.

There are cases when we direct newsletter recipients to Mindbox’s websites. For instance, our newsletters contain a link with which newsletter recipients can access newsletters online (for example, in case of problems displaying the newsletter in the email program).

You may terminate the receipt of our newsletter at any time, which means you revoke your consent to receive it. By doing so, your consent to the dissemination of the newsletter via Mindbox and statistical analysis thereof expires at the same time. Unfortunately, it is not possible to cancel the dissemination of the newsletter via Mindbox or the statistical evaluation thereof through other means. You may withdraw your consent to receive our newsletter at any time by changing the notification settings in your account. In addition, you can find a link to unsubscribe from our newsletter at the bottom of each newsletter.

4. Legal Basis
The processing of your personal data relies on the following legal bases:

• Your consent, if you have given us such consent.
• The initiation or execution of a contract with you.
• The fulfillment of legal obligations The implementation of our legitimate interests.
• Data protection and transmission to third parties.

click2commission takes all technical and organizational security measures required to protect your personal data from loss, unauthorized disclosure, or other forms of misuse. Data is stored in a safe environment that is not open to public access. Your personal data may be encrypted before transmission in certain cases (e.g., processing your login data). This means that communication between your device and our servers will include recognized encryption measures if your browser supports doing so.

Our staff has been trained in privacy matters and responsibly handling personal data and information to which they gain access.

Please be aware that should you contact us via email, the confidentiality of the information therein may not be ensured. Third persons may have access to the contents of emails.

For click2commission to execute its business processes in a convenient and optimal manner, it may be necessary for certain data to be processed by trusted third parties and reliable partners. These third parties may:

• Process payments
• Fulfill orders
• Send emails
• Manage communications (e.g., newsletters, security notifications, chat, etc.)
• Host websites

Conduct other related activitieson behalf of click2commission. However, click2commission only shares data that is needed to serve the specific purpose for which the third parties are engaged. click2commission ensures that these third parties are under similar obligations to maintain privacy and confidentiality as click2commission’s own employees and that they will handle your information in the way and to the extent click2commission is permitted to click2commission does not allow any third party to use your information for any purposes for which the information was not collected.

click2commission will only disclose your personally identifiable information (PII) outside the country you live in if it is necessary for the intended purpose of processing. However, as a member of the worldwide click2commission group of companies, each local click2commission entity may maintain or perform data processing operations in countries outside the European Economic Area (EEA) or in countries without an adequate level of data protection if doing so is required for the fulfillment of our obligations or the underlying contract with you. Furthermore, subcontractors of click2commission, which click2commission engages to act on its behalf concerning the processing of your PII, may be domiciled in such areas.

To secure the transfer and processing of PII, click2commission has implemented and requested the required technical and organizational measures and has entered into the appropriate contractual frameworks with click2commission Group companies and subcontractors, which ensure that the data recipient has implemented an adequate level of data privacy in its organization. This includes the signing of Data Processing Agreements and European Union standard contractual clauses issued by the EU Commission. These precautions are appropriate safeguards ensuring that your information will be treated securely, confidentially, and under the applicable data protection laws.

If click2commission is acquired by or merges with a third party, we reserve the right, in either of these circumstances, to transfer or assign the information we have collected from you as part of such a merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your information is treated, transferred, or used.

 5. Data Transfer

We only transfer personal data to third countries where we can ensure the careful handling of personal data by employing contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.

5.1. User Rights

You have the following rights concerning our processing of your personal data:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object (on grounds related to your particular situation) if your personal data is processed based on our legitimate interest
• The right to withdraw your consent at any time in the event of any consent-based processing of your personal data without affecting the lawfulness of processing said data based on consent before your withdrawal
• The right to lodge a complaint with a supervisory authority.

You may exercise your legal rights by contacting us via email at [email protected].

If you are registered as a publisher or an advertiser on our website, you may access your account and correct or delete some of your data by yourself.

While observing applicable privacy legislation, we will erase your data without any action required by you if retention of your data is no longer necessary for the purpose pursued or retention is no longer allowed for any legal reason. We may restrict processing instead of erasing your data where it is legally not allowed to erase (e.g., legal obligations to maintain your personal data).

Amendments

We may modify this Privacy Policy and our data security provisions at any time, particularly if new laws and/or regulations need to be adopted or if we regard amendments as reasonable.

Questions/Contacts

For all questions and requests related to the security of your personal data, please contact our Privacy Officers and us at [email protected].