1. Data Controller: After your registration with the Affiliate Program, the Bluf entity which you are contracting with under the Affiliate Program Terms is responsible for your data, in particular, Blufpartners.
2. Privacy Policies Used in Connection with Your Subscription: When you or entity you represent register for an Account on the Affiliate Program, we use a password-protected third party portal to store your personal information, and we share your personal information with such third party (“Third Party Agent”) as is necessary for the performance of your or your represented entity’s Account and the Affiliate Program.
3. Personally Identifiable Information: We collect personally identifiable information when you or your represented entity register for an Account or otherwise choose to provide personally identifiable information to us. We collect personally identifiable information directly from you and / or entity you represent. Personally identifiable information is any information that can be used to identify or locate a particular person. This include: 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 or your represented entity under the Affiliate Program) and/or any other information requested on the applicable subscriber registration form. You have to provide us with the information which we need to maintain Affiliate Program related business relations with you or your represented entity. Such provision of personal data is a contractual requirement, or a requirement necessary to enter into a contract. In case you do not provide us with this information, we will not be able to cooperate with you or your represented entity on Affiliate Program related matters.
4. Non-Personally Identifiable Information: We collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or register for an Account (or your represented entity registers for an Account) on the Affiliate Program, such as the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider, 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 use this information in the aggregate to analyze Site usage.
7. Purposes of Use of Information: We use your personally identifiable information:
(a) to create and administrate your or your represented entity’s Account with the Affiliate Program;
(b) to send you information regarding your or your represented entity’s Account and the Affiliate Program;
(c) to track your or your represented entity’s compliance with the Affiliate Program Terms;
(d) to process payments to you or your represented entity;
(e) for validation, suppression, content improvement and feedback purposes;
(f) to establish, exercise, or defend legal claims;
(g) to conduct business planning, reporting, and forecasting;
(h) to detect fraudulent activity; and/or
(i) to comply with legal obligations and law enforcement requests.
We, or our Third Party Agent, may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your or your represented entity’s Account on the Affiliate Program.
We process your data because you enter into contract with us and because we have a legitimate interest to process your information (i.e., your represented entity has entered into contract with us and we need to maintain business relations; we need to improve content on the Site).
8. Information Sharing: As a general rule, and other than in connection with the limited exceptions set forth below, we will not sell, share or rent your personally identifiable information to or with others. Notwithstanding the foregoing, we provide such information to certain third-party vendors for efficiency purposes in providing administrative or program management services in connection with your Account. Such third-party vendors may be our partners that provide payment processing, email automation, website and app diagnostics, analytics and other services. Any third-party vendor so used protects the confidentiality of information provided by us. Further, we reserve the right to share your personally identifiable information: (a) to the group companies in our corporate structure; (b) where required by law, or requested by a court of competent jurisdiction; (c) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; (d) where you are in violation of the Affiliate Program Terms and/or Services Agreement; (e) in case of a dispute; or (f) where we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.
9. International Transfer of Data: As part of your membership in the Affiliate Program, we transfer information that we collect about you and your or your represented entity’s end users, including personal information, to affiliated entities, or to other third parties (e.g., our vendors) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. If we transfer your personal information to such territories, we will make sure that:
a) country ensures an adequate level of protection for your personal information;
b) the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal information; or
c) we have put in place appropriate safeguards to protect your personal information, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission;
d) the transfer is permitted by applicable laws; or
e) you explicitly consent to the transfer.
If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal information, please contact us at af[email protected] (for Blufpartners).
10. Data Retention: Your personally identifiable information is retained by us for as long as you or your represented entity have a business relationship with us and no more than 10 years after the end of such relationship. Your personally non-identifiable information is retained by us and in our Third Party Agent portal, server logs, databases and records for as long as you or your represented entity have the Account with the Affiliate Program.
13. Minors: We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. We will never knowingly collect any personal information about individuals under eighteen (18) years of age. If we obtain actual knowledge that we have collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from its database.
14. Security: We endeavor to safeguard and protect your Account information. When Account holders submit personally identifiable information to the Affiliate Program, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit sensitive information (such as bank account information and/or credit card information), and when we transmit such information, that information is encrypted and protected with SSL encryption software. While we use SSL encryption to protect your sensitive information online, we protect all other user information online and offline. The Third Party Agent servers that we utilize to store personally identifiable information in 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.
Access to your personally identifiable information is strictly limited, and not accessible to the public. Our employees are dedicated to ensuring the security and privacy of all user information. Employees not adhering to our written firm policies are subject to disciplinary action. In compliance with applicable 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 at your own risk.
15. Your Rights: Data protection laws give you certain rights in relation to your personal data. You may request us to inform you about the personal data that we have collected about you, to request any changes or correction of inaccurate information, to object to certain processing of personal data (e.g. for marketing purposes), to provide you with a copy of your personal data in a structured, commonly used and machine-readable format, to transmit (if technically feasible) your personal data to another controller, or to erase your personal data. You also may request to restrict the processing of your personal data (when there is a legal basis for that). In cases where your personal data is processed on a separate consent basis, you have the right at any time to withdraw your consent to the processing of your personal data. You have a right to lodge a complaint with a supervisory authority. If you wish to execute any of these rights, please contact us first at [email protected] (for Blufpartners).
16. Opting Out of Receiving E-mail: You may at any time choose to stop receiving emails containing general information regarding Blufvpn by following the instructions at the end of each such email or by contacting us at [email protected] (for Blufpartners). 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.
17. Automated Decision Making: We do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.