Effective Date: August 11, 2020
Thank you for visiting the CPX Affiliate Network website and or Mobile Application (the "Site"). CPX ("we", "us") is committed to protecting the privacy of your personally identifiable information. We provide this privacy policy ("Privacy Policy") in order to explain our online information practices and the choices you can make about the way your information is used by us. You must agree to this Privacy Policy, in its entirety, including our use of cookies in order to: register an account ("Account") with us and log in to your Account as a member of the CPX Affiliate Website. If you do not agree to this Privacy Policy in its entirety, you are not authorized to register for an Account with us.
When you register for an Account on the Site, we may 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 Site. other data: we may also collect data regarding the Mode of Promotion: what accounts on social media platforms, coupon websites or apps or any other mode of promotion you use to promoting Ads including but not limited to, Social media platform account, username, handle, URL of website, mobile application
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, individual 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 may require in order to pay any amounts due to you or invoice you, IP address and/or any other information requested on the applicable Subscriber registration form. And for individuals we may also collect personal information including but not limited to, Passport Copy and information within passports, bank account & billing details, mobile number, address etc. whenever is required to create an IO with the Affiliate for payment and any other purpose.
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 Site, 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 we may 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 experience on the Site. We also may use this information in the aggregate to analyze Site usage.
We may also collect or be provided with informations related to offers and sales and we may share such information fully or partially with our Affiliates including and limited to, Geo targeting locations, Order date, Coupon Code, Number of orders (gross + net), Sale amount, Commission, Customer type (new/return customers), Country, Order Number, Pay type (COD/Paypal/Aramex, etc), Order status, Platform (mobile app/web), Categories, and products, Client/Advertiser Description Product feeds, Bestsellers, Stocks, Average order value, Product performance to ensure the best performance of any Ads or Campaigns and for the Affiliates to plan the promotions effectively.
To enhance your experience with the Site, we use "cookies." Cookies are small packets of data stored on your computer used to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. You may set your browser to warn you that cookies are in use, or to block the use of cookies. We use strictly necessary cookies to allow you to move around the Site and log in to your Account, and functional cookies to improve the services and support available to you. Accepting strictly necessary cookies is a condition of using the Site. You can control whether or not functional cookies are used, though preventing them may mean some services and support will be unavailable. Cookies may be managed for us by third parties; where this is the case, we do not allow the third party to use the cookies for any purpose other than as necessary to provide the services.
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.
End users can disable cookies in most internet browsers. An overview of the process is available at http://www.allaboutcookies.org/manage-cookies/. Disabling cookies will not, however, stop receipt of all advertisements. If an end user would like to opt out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option.
End users can also disable collection of ad identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the ad identifier altogether using their smartphone’s privacy settings.
We may be a participant of the Google Third Party Serving Compatibility Program, in which case we would abide by the Third-Party Ad Serving Policy available at
http://adwords.google.com/support/bin/answer.py?answer=94230
We use your personally identifiable information:
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 Performance Marketing Partner Network and/or any other information that we may deem appropriate for you to receive in connection with your Account on the Performance Marketing Partner Network. You may update your contact preferences as set forth below.
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 may, from time to time, provide such information to certain third-party administrative vendors, including HasOffers, for efficiency purposes in providing administrative or program management services in connection with your Account. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us.
Further, we reserve the right to share your personally identifiable information:
We may transfer information that we collect about you and your end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your end users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your end users, including personal information, as described in this Privacy Policy.
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:
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.
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.
Your acceptance of the terms of this Privacy Policy, in their entirety, shall extend to your employees. You agree that any of your employees that access your Account or visit the Site under the scope of their employment with you agree to the terms of this Privacy Policy.
We endeavor to safeguard and protect our Account holders' information. When Account holders submit personally identifiable information to the Performance Marketing Partner 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.
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.
You may at any time choose to stop receiving emails containing general information regarding cpx 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.
We reserve the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the Site explaining that we are changing our Privacy Policy. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us.
Effective Date: August 11, 2020
Thank you for visiting the CPX Affiliate Network website and or Mobile Application (the "Site"). CPX ("we", "us") is committed to protecting the privacy of your personally identifiable information. We provide this privacy policy ("Privacy Policy") in order to explain our online information practices and the choices you can make about the way your information is used by us. You must agree to this Privacy Policy, in its entirety, including our use of cookies in order to: register an account ("Account") with us and log in to your Account as a member of the CPX Affiliate Website. If you do not agree to this Privacy Policy in its entirety, you are not authorized to register for an Account with us.
When you register for an Account on the Site, we may 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 Site. other data: we may also collect data regarding the Mode of Promotion: what accounts on social media platforms, coupon websites or apps or any other mode of promotion you use to promoting Ads including but not limited to, Social media platform account, username, handle, URL of website, mobile application
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, individual 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 may require in order to pay any amounts due to you or invoice you, IP address and/or any other information requested on the applicable Subscriber registration form. And for individuals we may also collect personal information including but not limited to, Passport Copy and information within passports, bank account & billing details, mobile number, address etc. whenever is required to create an IO with the Affiliate for payment and any other purpose.
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 Site, 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 we may 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 experience on the Site. We also may use this information in the aggregate to analyze Site usage.
We may also collect or be provided with informations related to offers and sales and we may share such information fully or partially with our Affiliates including and limited to, Geo targeting locations, Order date, Coupon Code, Number of orders (gross + net), Sale amount, Commission, Customer type (new/return customers), Country, Order Number, Pay type (COD/Paypal/Aramex, etc), Order status, Platform (mobile app/web), Categories, and products, Client/Advertiser Description Product feeds, Bestsellers, Stocks, Average order value, Product performance to ensure the best performance of any Ads or Campaigns and for the Affiliates to plan the promotions effectively.
To enhance your experience with the Site, we use "cookies." Cookies are small packets of data stored on your computer used to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. You may set your browser to warn you that cookies are in use, or to block the use of cookies. We use strictly necessary cookies to allow you to move around the Site and log in to your Account, and functional cookies to improve the services and support available to you. Accepting strictly necessary cookies is a condition of using the Site. You can control whether or not functional cookies are used, though preventing them may mean some services and support will be unavailable. Cookies may be managed for us by third parties; where this is the case, we do not allow the third party to use the cookies for any purpose other than as necessary to provide the services.
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.
End users can disable cookies in most internet browsers. An overview of the process is available at http://www.allaboutcookies.org/manage-cookies/. Disabling cookies will not, however, stop receipt of all advertisements. If an end user would like to opt out of a particular ad network, publisher, or advertiser’s ads, they will need to contact those companies directly to inquire whether they have an opt-out option.
End users can also disable collection of ad identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the ad identifier altogether using their smartphone’s privacy settings.
We may be a participant of the Google Third Party Serving Compatibility Program, in which case we would abide by the Third-Party Ad Serving Policy available at
http://adwords.google.com/support/bin/answer.py?answer=94230
We use your personally identifiable information:
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 Performance Marketing Partner Network and/or any other information that we may deem appropriate for you to receive in connection with your Account on the Performance Marketing Partner Network. You may update your contact preferences as set forth below.
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 may, from time to time, provide such information to certain third-party administrative vendors, including HasOffers, for efficiency purposes in providing administrative or program management services in connection with your Account. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us.
Further, we reserve the right to share your personally identifiable information:
We may transfer information that we collect about you and your end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your end users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your end users, including personal information, as described in this Privacy Policy.
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:
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.
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.
Your acceptance of the terms of this Privacy Policy, in their entirety, shall extend to your employees. You agree that any of your employees that access your Account or visit the Site under the scope of their employment with you agree to the terms of this Privacy Policy.
We endeavor to safeguard and protect our Account holders' information. When Account holders submit personally identifiable information to the Performance Marketing Partner 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.
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.
You may at any time choose to stop receiving emails containing general information regarding cpx 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.
We reserve the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the Site explaining that we are changing our Privacy Policy. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site and/or acceptance of our e-mail communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.
If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us.
This General Data Protection Regulation Data Processing Addendum ("GDPR Addendum") is incorporated by reference into the Partner Network Advertiser Agreement by and between You (“Advertiser”), and Us (“Network” or Processor”), (collectively, the "Agreement"). This GDPR Addendum is entered into as of the date of the Advertiser Program Operating Agreement.
This GDPR Addendum sets out the terms that apply when Personal Data, as defined in the Data Protection Legislation, is processed by Network under the Agreement. The purpose of the GDPR Addendum is to ensure such processing is conducted in accordance with applicable laws, including EU Data Protection Legislation, and with due respect for the rights and freedoms of individuals whose Personal Data are processed.
Capitalized terms used but not defined in this GDPR Addendum have the same meanings as set out in the Agreement.
Data Protection Legislation: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.
Applicability. This GDPR Addendum shall only apply to the extent Advertiser is established within the European Union (“EU”) or Switzerland or the United Kingdom and/or to the extent Network processes Personal Data of Data Subjects located in the EU or Switzerland or the United Kingdom on behalf of Advertiser.
Both parties will comply with all applicable requirements of the Data Protection Legislation. This Section 1 is in addition to, and does not relieve, remove or replace, a party's obligations under the Data Protection Legislation.
The parties acknowledge that for the purposes of the Data Protection Legislation, the Advertiser is the data controller and Network is the data processor (where Data Controller and Data Processor have the meanings as defined in the Data Protection Legislation).
Without prejudice to the generality of clause 1.1, the Advertiser, as Controller, shall be responsible for ensuring that, in connection with Advertiser Personal Data and the Services, (i) it has complied, and will continue to comply, with all applicable laws relating to privacy and data protection, including EU Data Protection Legislation; and (ii) it has, and will continue to have, the right to transfer, or provide access to, the Personal Data to Network for processing in accordance with the terms of the Agreement and this GDPR Addendum.
Without prejudice to the generality of clause 1.1, Network shall , in relation to any Personal Data processed in connection with the performance by Network of its obligations under this agreement:
1. process that Personal Data only for the purposes set forth in the Agreement and Schedule 1 and only in accordance with the lawful, documented instructions of Advertiser, except where otherwise required by applicable law. Any processing required outside of the scope of these instructions (inclusive of the rights and obligations set forth under the Agreement) will require prior written agreement of the parties. Where Network is relying on laws of a member of the EU or EU law as the basis for processing Personal Data, Network shall promptly notify the Advertiser of this before performing the processing required by the Applicable Laws unless those Applicable Laws prohibit Network from so notifying the Advertiser;
2. ensure that it has in place appropriate technical and organizational measures, available for review and approval by the Advertiser , to protect against unauthorized or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorized or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organizational measures adopted by it);
3. ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential; and Network complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred;
4. assist the Advertiser, at the Advertiser's cost, in responding to any request from a Data Subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators. For the avoidance of doubt, Advertiser is responsible for responding to Data Subject request for access, correction, restriction, objection, erasure or data portability of that Data Subject's Personal Data;
5. notify the Advertiser without undue delay on becoming aware of a Personal Data breach;
6. upon termination or expiration of the Agreement, in accordance with the terms of the Agreement and within a reasonable amount of time, delete or make available to Advertiser for retrieval all relevant Personal Data in Network's possession; except to the extent that Network is required by any applicable law to retain some or all of such data. Network shall extend the protections of the Agreement and this GDPR Addendum to any such Personal Data and limit any further processing of such Personal Data to only those limited purposes that require the retention; and
7. maintain complete and accurate records and information to demonstrate its compliance with this Section 2.4.
The Advertiser consents to Network appointing third-party processors of Personal Data under this agreement, including TUNE (“Sub-processors”). Network confirms that it has entered or (as the case may be) will enter with the third-party processor into a written agreement substantially similar to those set out in this Agreement. As between the Advertiser and Network, Network shall remain fully liable for all acts or omissions of any Sub-processor appointed by it pursuant to this Section 2.5.
Network may, at any time on not less than 30 days' notice with email sufficing, add or make changes to the Sub-processors. Advertiser may object in writing to Network's appointment of a new Sub-processor within five (5) business days of such notice, provided that such objection is based on reasonable grounds relating to data protection. In such event, the parties will discuss such concerns in good faith with a view to achieving resolution. If Network cannot provide an alternative Sub-processor, or the parties are not otherwise able to achieve resolution as provided in the preceding sentence, Advertiser, as its sole and exclusive remedy, may terminate the Agreement.
Except as stated in this GDPR Addendum, the Agreement will remain in full force and effect. If there is a conflict between the Agreement and this GDPR Addendum, the terms of this GDPR Addendum will control.
Any claims brought under this GDPR Addendum shall be subject to the terms and conditions, including by not limited to, the exclusion and limitations set forth in the Agreement.
Details of Data Processing
1. Subject Matter: The subject matter of the data processing under this GDPR Addendum is the Advertiser Personal Data.
2. Duration: As between Network and Advertiser, the duration of the data processing under this GDPR Addendum is until the termination of the Agreement in accordance with its terms.
3. Purpose: The purpose of the data processing under this GDPR Addendum is the provision of the Services to the Advertiser and the performance of Network's obligations under the Agreement (including this GDPR Addendum) or as otherwise agreed by the parties in mutually executed written form.
4. Nature of the processing: Network provides performance marketing solutions and such other Services as described in the Agreement, which process Advertiser Personal Data upon the instruction of the Advertiser in accordance with the terms of the Agreement.
5. Categories of data subjects: Advertiser may submit Advertiser Personal Data to the Services, the extent of which is determined and controlled by Advertiser in its sole discretion, and which may include, but is not limited to, Personal Data relating to the following categories of data subjects:
1. Employees, agents, advisors, freelancers of Advertiser (who are natural persons); and/or
2. Advertiser's end-users authorized by Advertiser to use the Services.
6. Types of Personal Data: Advertiser may submit Advertiser Personal Data to the Services, the extent of which is determined and controlled by Advertiser in its sole discretion, and which may include, but is not limited to identification and contact data; financial information; and/or certain information about Advertiser's end users (such as IP address and device identifier).
7. Sensitive Personal Data (if applicable): Advertiser shall not send Network any Sensitive Personal Data (as defined in the Data Protection Legislation).
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