Introduction

This Privacy Policy applies to the NetRefer website (www.NetReferAffiliates.com) and any of its pages (“our website”).

Who are we?

Arnold Media Limited, trading as NetRefer, is the industry leader in the provision of Unified Performance Marketing. We power the most successful and high-volume partner programs through a centralized and scalable platform of products.

We understand that you are aware of and care about your own personal privacy interests, and we take that very seriously. This Privacy Policy describes NetRefer’s policies and practices regarding its collection and use of your personal data on our website and sets forth your privacy rights.

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

Information we collect and how we process it

We collect personal information you give us such as your name, e-mail or contact details when you actively fill in the Contact Us & Request A Demo form. This data is then sent to sales@netrefer.com, a NetRefer mailbox to which only the NetRefer Sales and Marketing team has access.

We also collect personal information when you use the NetRefer services or products or otherwise interact with NetRefer such as by mail, chat, forms or social media. With your consent and as otherwise permitted by law, we use your email address and other information we receive from and about you to contact you with information about our products, services and other news, including by sending newsletters and marketing material that may be of interest to you. You may withdraw your consent at any time by unsubscribing from such communications.

We may also ask you to provide your contact number in order to apply multifactor authentication. Furthermore we collect information automatically through the use of Google Analytics and Hotjar. The information may include: internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our website, including a history of the pages you view and user interactions such as mouse events (movements, location and clicks) and keypresses.

All information is anonymized prior to storage and hence no personal data is stored through cookies on our website.

We use this information to help us design our website to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

This Privacy Policy will be updated with any new services that may be added in future.

Google Analytics and Hotjar

This site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) and Hotjar, a web analytics service provided by Hotjar Limited (“Hotjar Limited”). Google Analytics and Hotjar use “cookies”, which are text files placed on your computer, to help our website analyse how users make use of it. The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States, and by Hotjar on servers in the EU. You can find out more about Google’s and Hotjar’s position on privacy as regards its analytics service at google.com/intl/en_uk/analytics/privacyoverview and hotjar.com/privacy.

By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Facebook Pixel

On grounds of our legitimate interests in and for these purposes of analysis, optimisation and economic operation of our services, we use the so-called “Facebook pixel” by the Facebook social network, operated by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA or, if you are an EU resident, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).

The Facebook pixel is a code placed on our website. Facebook Pixel allows Facebook to identify the visitors of our online content as a target group for displaying advertisement (known as “Facebook ads”). Accordingly, we use Facebook Pixel to display our posted Facebook ads only to Facebook users who have shown an interest in our services or who share certain factors (such as interests in certain topics or products determined on the basis of visited web pages), which we transmit to Facebook (which is known as Custom Audiences). Facebook Pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes, by showing whether users have been redirected to our services after clicking on a Facebook ad (known as conversion, and allowing to determine on which devices a user is performing an action), in order to create so-called lookalike audiences or statistical twins (i.e. to broadcast ads to target groups that are similar to existing customers) and to obtain comprehensive statistics about the use of the website. Facebook Pixel establishes a direct connection to the Facebook servers when you visit our website. This way, the Facebook server is notified that you have visited our website and Facebook assigns this information to your personal Facebook user account.

The personal information collected by the pixel is anonymized to us, but is processed and stored by Facebook, Inc. You should read Facebook’s Privacy Policy to learn more about how Facebook uses your personal information. You may opt out of Facebook pixel tracking at any time by visiting facebook.com/settings. You can also opt out of tracking by visiting aboutads.info/choices and yourchoices.eu.

LinkedIn

We also use “LinkedIn” which is used by us to track inbound link clicks. LinkedIn’s ability to use and share information is governed by the LinkedIn Terms of Use, available at linkedin.com/legal/user-agreement, and the LinkedIn Privacy Policy, available a linkedin.com/legal/privacy-policy. You can opt-out of LinkedIn’s services by clicking on the following link: linkedin.com/legal/cookie-policy.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track the use of our website and to compile statistical reports on its activity. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit aboutcookies.org or allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Information we share with Partners

We do not share your information or data with third parties outside NetRefer except in the following limited circumstances:

1. When required in order to:

• meet any applicable law, regulation, legal process or enforceable governmental request;
• enforce applicable policies, including investigation of potential violations;
• detect, prevent, or otherwise address fraud, security or technical issues;
• protect against harm to the rights, property or safety of our users, the public or to NetRefer and/or as required or permitted by law.

2. To help us provide certain aspects of our services we use trusted third parties to:

• provide our e-mail services;
• deliver and help us track our marketing and advertising content;
• help us track website conversion success metrics;
• manage our sales and customer support services to you.

We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.

Security of your information

To help protect the privacy of data and personally identifiable information you transmit through the use of our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to carry out a related function. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

Data storage and retention

Your personal data is stored by NetRefer on its servers and on the servers of the cloud-based providers which NetRefer engages. When personal data is involved, NetRefer always selects processors within the EU or in countries that ensure an adequate level of protection. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact NetRefer at dpo@netrefer.com.

Changes and updates to the Privacy Policy

By using our website, you agree to the terms and conditions contained in this Privacy Policy. If you do not agree to any of these terms and conditions, you should not use our website. We reserve the right to amend the Privacy Policy, for any reason, without notice to you, other than the posting of the amended Privacy Policy on our website.

You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by and construed in accordance with the laws of Malta. The parties agree that any dispute or claim arising out of or in connection with this Privacy Policy or its subject-matter, shall be subject to the exclusive jurisdiction of the Malta Arbitration Centre in accordance with the Arbitration Act (Cap. 387 of the Laws of Malta) and the arbitration rules of the Malta Arbitration Centre in force at the time of the dispute.

Your Rights

Under the General Data Protection Regulation 2016/679 you have rights which you can exercise over your personal data. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request). Rights which you are entitled to are:

• Data access rights
• Right to restrict processing
• Right of rectification
• Right to erasure (Right to be Forgotten)
• Right to object to processing
• Right to withdraw consent; and
• Data portability rights

Exercising your Rights

Contact details
NetRefer is located in Msida, Malta. In case you have any questions or concerns regarding our personal data policies or practices or if you would like to invoke one of your rights under the General Data Protection Regulation, you can contact us by email at dpo@netrefer.com


Complaints
If you are resident in the European Union and you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority. As NetRefer operates its business in Malta, it operates under the remit of the Maltese Office of the Information and Data Protection Commissioner.