Effective Date: May 25, 2018
1. THE GROUP
The Group includes the following companies: GLOPSS International Pte Ltd., GLOPSS 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. PRIVACY POLICIES USED IN CONNECTION WITH YOUR SUBSCRIPTION
When you register for an Account on the Affiliate Network, we use a password-protected third-party portal to store your personal information, and we may share your personal information with such third party (“Third Party Agent”) as is necessary for the performance of your Account and the Affiliate Network.
3. WHAT INFORMATION WE COLLECT?
a. Personally Identifiable Information Collected: We collect personally identifiable information when you register for an Account or otherwise choose to provide personally identifiable information to us. Personally identifiable information is any information that can be used to identify or locate a particular person or entity. This may include but is not limited to: business entity name and/or your title with the applicable business entity, as well as your personal and/or business entity related e-mail address, mailing address, daytime and/or cellular telephone numbers, fax number, account information (or other information that we require in order to pay any amounts due to you under the Affiliate Network), IP address and/or any other information requested on the applicable Subscriber registration form.
b.Non-Personally Identifiable Information Collected: We may collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or register for an Account on the Affiliate Network, such as the type of browser you are using (e.g., Chrome, Internet Explorer), the type of operating system you are using, (e.g., Windows or Mac OS) and the domain name of your Internet service provider (ISP) and share such information with our Third-Party Agent. We use the non-personally identifiable information that we collect to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.
We may additionally collect information using Web beacons, which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs. Web beacons are electronic images that may be used on the Site, in your Account, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon.
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 GLOPSS Affiliate Support at firstname.lastname@example.org
5. USE OF INFORMATION?
We use your personally identifiable information: (a) to send you information regarding your Account and the Affiliate Network; (b) to track your compliance with the Terms and Conditions (“Terms and Conditions”); and/or (c) for validation, suppression, content improvement and feedback purposes. In addition, we may use your IP address for the purposes identified above, as well as to analyze trends, administer the Site, track users’ movements, gather broad demographic information for aggregate use, and to confirm that a particular individual affirmed his/her consent to specific legal terms (e.g. a clickwrap license agreement). You agree that we, or our Third Party Agent, may contact you at any time regarding your Account or the Affiliate Network and/or any other information that we may deem appropriate for you to receive in connection with your Account on the Affiliate Network. You may update your contact preferences as set forth below.
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 GLOPSS Affiliate Support at: email@example.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.
7. INFORMATION SHARING
8. INTERNATIOANL TRANSFER OF DATA
Where we act as a controller under European data law, our lawful basis for collecting and using the information described in this Privacy Notice will depend on the information concerned and the specific context in which we collect or use that information. We normally collect or use information from you only where we have collected your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, when we:
a.use information to create or manage an account, we need it in order to provide relevant services;
b.use contact information for marketing purposes, we do so with your consent (which you can revoke at any time); and
c. gather usage data and analyze it to improve the Site, we do so based on our legitimate interest in safeguarding and improving the Site.
If you have any questions or concerns about how information is processed, including questions about how to exercise your rights as a data subject, please contact us at the contact information provided in this Privacy Notice.
9. DATA RETENTION
Subject to any mandatory obligations to delete data, your information may be retained by us and in our Third-Party Agent portal, server logs, databases and records. We will keep your information for no longer than necessary for the purposes for which it is processed. Where there are technical limitations that prevent deletion or anonymization, we will safeguard and limit the use of information as required by applicable law.
10. YOUR EMPLOYEE
We endeavor to safeguard and protect our Account holders information. When Account holders submit personally identifiable information to the Affiliate Network, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit information such as bank account information and/or credit card information (“Sensitive Information”), and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected. The Third-Party Agent servers that we utilize to store personally identifiable information are kept in a secure physical environment. The Third-Party Agent has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
You acknowledge that you provide your personally identifiable information to us with knowledgeable consent and at your own risk.
12. DELETING OR UPDATING YOUR INFORMATION
If you would like to delete or update the personally identifiable information that we have collected from you, simply email us. We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
13. OPTING OUT RECEIVING E-MAIL
You may at any time choose to stop receiving emails containing general information regarding [Network Name] by following the instructions at the end of each such email or by contacting us. Should you be contacted by our Third-Party Agent through email, you can follow the instructions at the end of each such email to stop receiving such emails. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Account, as well as to respond to any inquiry or request made by you.
14. NOTIFICATON OF CHANGES
15. CONTACT US