Privacy Policy

 

vCommission, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the “Company”), offers online marketing services, and operates the affiliate marketing campaigns in respect of same (collectively, the “Services”). The Group is deeply committed to safeguard the privacy expectations of its users (“User(s)”, “you” or “your”). Accordingly, we have put in place this Privacy Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.

We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By visiting the Group’s websites, mobile apps or other online properties, or by creating an account through our Services, you hereby agree to the Privacy Policy.

1. The group

The Group includes the following companies: Adways VC India Private Limited, vCommission Media Private Limited.

The Group provides the Services through the following applications and platforms (collectively the “ Platforms”):

  • This internet website;
  • The Affiliate Dashboard (Hasoffers platform);
  • Downloadable applications and software (“Software”), such as Hasoffers reporting application

2. What information we collect?

We collect two types of information from our Users:

  • Personal Information
    The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“ Personal Information”). Personal Information which is being gathered may consist of the following:

    • Registration details: When you open an account and register to use the Services, you will be asked to provide us certain details about yourself, such as: first and last name, email address, physical address, ID number, phone number, etc. In addition, we may collect your bank account information.
    • Governmental-issued ID: In all instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process. Please note that this information is required for certain features of our Services.
    • Transaction information: in order for us to provide the Services, we automatically record different information related to your account and use of our Services, including with respect to your promotion methods, referrals, and balances, as applicable.
    • Payment information: In order for us to pay for your publisher commissions, payment information will be collected from you, such as your currency, and bank account details.
    • Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services.
    • Device information: We collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
    • Telephone calls: We may record or monitor telephone calls for affiliate support, for training and/or security purposes.
  • Non-personal information
    The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.For avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.Types of Non-personal Information we collect from or about you:

    • Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.).
    • Transaction information: We record financial transaction information including, amongst other things, commissions, payouts etc. and share and publish such information through any of our Platforms.

3. Minors

The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact vCommission Affiliate Support at support@vcommission.com

4. How we use the collected information?

We use your Personal Information for the purposes listed below:

  • To set up, manage and update your account;
  • To provide and operate the Services (such as for payment processing);
  • To communicate with you and to keep you informed of our latest updates to our Services and special offers;
  • To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
  • To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
  • To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
  • To provide you with a responsible affiliate marketing environment;
  • To communicate with your and to process any of your requests to exercise your User Rights;
  • To identify and authenticate your access to certain features of the Services;
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
  • To investigate violations of our policies and vCommission Affiliate Terms and Conditions as well as enforce our policies and vCommission Affiliate Terms and Conditions;
  • To investigate and resolve disputes in connection with your use of the Services; and

5. Marketing

The Group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) or (ii) the Group’s business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.

We may also share and disclose Personal Information with our Advertisers as and when needed to verify your promotional methods and publisher commissions. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.

You may at any time decline receiving further marketing offers from us or from Marketing Affiliates by contacting vCommission Affiliate Support at: support@vcommission.com, or by unsubscribing from receiving marketing materials by following the guidelines available on the marketing communications (such as clicking on an “unsubscribe” button). Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

6. With whom we share information?

We do not rent, sell, or share your Personal Information with third parties (“Recipients”) except as described in this Privacy Policy. The Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

We share Personal Information with any of the following recipients:

  • Companies within the Group and other affiliated companies;
  • Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
  • Auditors, contractors or legal/financial/other advisers of any of the Group’s business processes;
  • Any third parties who investigate, detect or prevent fraudulent or illegal activity

In addition to the purposes listed in this Privacy Policy, we share Personal Information with those Recipients for any of the following purposes:

  • Storing such information on our behalf, for example by using cloud computing service providers;
  • Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
  • Performing research, technical diagnostics or analytics;
  • Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see above, in the section titled “Marketing”); and
  • Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our User Agreement and Privacy Policy), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

7. Transfer of information

Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.

We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at Customer Service.

8. Third party tracking technologies

When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies”).

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.

We also allow third parties to collect information about you through Tracking Technologies. To learn more please see our Cookie Policy below.

9. Third party services

While using the Services you may encounter links to third party websites, services or applications. Please keep in mind that this Privacy Policy does not apply to any third party websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

Please be advised that such third party websites, services or applications are independent from the Group. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.

You should always review their privacy practices carefully before providing Personal Information to such third parties.

You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.

10. Retention of personal information

If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations.

In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping.

11. Your rights

You may contact us at any time by email at: support@vcommission.com and request:

  1. To access or delete any Personal Information relating to you;
  2. To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
  3. That we will restrict or cease any further use of your Personal Information;
  4. That we will provide the Personal Information you volunteered to us in a machine-readable format.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

12. How we keep your information secured

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:

  • Secure network topology, which includes intrusion prevention and Firewall systems;
  • Encrypted communication;
  • Authentication and Access Control;
  • External and Internal audit tests; etc.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

13. Changes to the privacy policy

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy on the Services and/or we will send you an e-mail regarding such changes to the applicable e-mail address that you provided to us. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14. Cookies policy

We use cookies in order to provide you with a high-quality and personalised experience.

A cookie is a small text file that is stored on your computer, laptop or mobile device when you visit a website or use applications. Cookies may be used for many different purposes such as remembering your preferences, following your use of our website and improving your user experience.

We use three different types of cookies:

Essential Cookies- These cookies are necessary for the website to function properly or to provide a service which you request. These cookies are usually only set in response to your actions, such as in the case of auto form filling or logging in. Your browser can be set to block these cookies but the website will not perform properly if you decide to do so.

Functionality Cookies – These cookies help to provide you with a more personalised user experience and are used by us and select third parties whose services feature on our pages. Blocking these cookies will disable these services and may affect your Website experience.

Performance Cookies – These cookies collect information about how you use a website or application and assist us in improving the performance of our website. Blocking these cookies means that we cannot work effectively to improve the usability of our website.

Cookies may be stored either for the duration of your visit to the website or for repeat visits:

Session Cookies – These cookies allows us to link your actions during a browser session. A browser session starts when you open the browser window and finishes when you close it. Session cookies are created temporarily and are deleted once the browser window is closed.

Persistent Cookies – These cookies remains on your device for a set period of time specified in the cookie and activated each time you visit the website that created that particular cookie.

You may modify your browser so that it will not accept cookies. Please see the “Help” section of your browser for instructions.

15. How to contact us

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at: support@vcommission.com

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.

Last revised: May 24, 2018