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Privacy Policy

Last update: 30 March 2023

Introduction

This Privacy Policy applies to your use of the NetRefer website (www.netrefer.com) and any of its pages and/or to use of the NetRefer platform (admin and affiliate interface), software, online courses and/or any supporting services, features and functions that are made accessible to you (hereinafter: the “Services”). By using any of the Services, you agree to the terms and conditions contained in this Privacy Policy.

We recognize that data privacy is an ongoing responsibility, and so we may from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies, by positing the new Privacy Policy on this page.

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 our policies and practices regarding the collection, use and disclosure of your personal data when using any of our Services, and sets forth your privacy rights.

Most of the information (both personal and non-personal) is processed by NetRefer in our capacity as a data processor.

Information we Collect

NetRefer may collect and process different types of both personal and non-personal information relating to you, depending on the capacity in which you engage or interact with NetRefer (e.g. website visitor, client, affiliate, by chat, social media, etc.).

Types of Data Collected

Personal Data: Personal data may include first and last name, title, date of birth, email address, phone numbers, Skype, Messenger, address, passwords, payments (IBAN), device data (such as IP), audit data (actions performed in the admin / affiliate platform), Usage Data and Cookies.

Usage Data: Usage Data is data collected automatically when using the Service either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). We may collect data on how the Service is being accessed and used. This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifies and other diagnostic data.

Tracking Cookies Data: We use cookies and similar tracking technologies to track the activity on our Services and store certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Furthermore we may 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.

Please also refer to our Cookie Policy for details on how we collect, use, or disclose information in respect of cookies at netrefer.com/cookie-policy

Use of Data

NetRefer will process the personal data as necessary to perform the Services and as further instructed by you (controller) in your use of the Service. We may use the collected data for various purposes:

  • to provide and maintain our Services, including to monitor the usage of our Services;
  • to gather analysis or valuable information so that we can improve our Services;
  • to detect, prevent and address technical issues, fraud and financial crimes;
  • to help us design our website to better suit our users’ needs;
  • 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;
  • to provide customer support;
  • to notify you about changes to our Services;
  • 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, unless you have opted not to receive such information;
  • to manage and enforce our rights, terms of use or any other contracts with you, including to manage any disputes, manage, investigate and resolve complaints, or recover debts.

We also 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 may also ask you to provide your contact number in order to apply multifactor authentication.

Legal Basis for Processing

NetRefer is primarily subject to the European General Data Protection Regulation (GDPR). We will collect and use your personal data described in this Privacy Policy depending on the personal data we collect and the specific context in which we collect it. NetRefer may process your personal data because:

  • we need to perform a contract with you;
  • you have given us permission to do so;
  • the processing is in our legitimate interests and it is not overridden by your rights;
  • to comply with the law.

Data Retention

NetRefer will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

NetRefer will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

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.

Data Storage and Transfer

Your personal data is stored by NetRefer on its servers and on the servers of the cloud-based providers which NetRefer engages. Our service providers, and other parties with whom we may share your personal information (as described herein), may process your personal information in territories that are outside the European Economic Area (“EEA”) or otherwise outside of the territory in which you reside. These countries may have data protection standards that are different to (and, in some cases, lower than) those of the territory in which you reside.

Disclosure of Data

Under certain circumstances, NetRefer may be required to disclose your personal data:

  • to meet any applicable law, regulation, legal process or enforceable governmental request;
  • to enforce applicable policies, including investigation of potential wrongdoing in connection with the Services;
  • to detect, prevent, or otherwise address fraud, security or technical issues;
  • to 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;
  • to protect against legal liability;
  • for purposes of a merger, acquisition or asset sale.

Security of Data

To help protect the privacy of data and personally identifiable information you transmit through the use of our Services, 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.

The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights

Under the General Data Protection Regulation 2016/679 you have certain rights which you can exercise over your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us.  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). Some of your rights may be subject to some exceptions or limitations. Rights which you may be entitled to are:

  • Right of access: You have the right to obtain a copy of the personal information that we hold about you.
  • Right of restriction: You have the right to restrict the use we make of your personal data. As a consequence, we will not be able to further process your data.
  • Right of rectification: You have the right to have your information rectified if that information is inaccurate or incomplete.
  • Right to erasure: You have the right to request that we delete your personal data, subject to certain exceptions (such as if NetRefer is legally required to keep the information).
  • Right to object: You have the right to object to our processing of your personal data.
  • Right to withdraw consent: You have the right to withdraw your consent at any time where NetRefer relied on your consent to process your personal information.
  • Right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • Right to know: You can request that NetRefer disclose to you (1) the categories and/or specific pieces of personal information we have collected about you; (2) the categories of sources for that personal information; (3) the purposes for which NetRefer uses that information; (4) the categories of third parties with whom NetRefer discloses the information; and (5) the categories of information that NetRefer discloses to third parties.
  • Right to opt-out of sharing: You may request NetRefer to stop sharing your personal information (“opt-out”).

Service Providers

We may employ third party companies and individuals to facilitate our Services, provide the Services on our behalf, perform Service-related services or assist us in analysing how our Services are used. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We use trusted third parties to help us provide certain aspects of our Services such as:

  • 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;
  • provide services, including but not limited to data storage.

We enter into confidentiality and data processing terms with such third parties 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.

Third Party Modules

We may use third party service providers to monitor and analyse the use of our Services.

Google Analytics and Hotjar: We use 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.

Links to Other Sites

Our Services may, from time to time, contain links to and from the websites of third parties. If you follow such a link, please note that these websites have their own privacy and cookies policies and NetRefer does not accept any responsibility or liability for these third-party websites

Children’s Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

Governing Law

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.

Contact Us

If you have any questions or concerns about this Privacy Policy, or about our personal data policies or practices, or if you would like to invoke one of your rights under the General Data Protection Regulation, please 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.