Privacy policy

1. DEFINITIONS

Before you start reading this document, please, review the explanation of definitions that will be used in the text:

P2W Network (or Network) – is a comprehensive advertising and affiliate (publisher) marketing solution that caters to the needs of both Advertisers and Affiliates (Publishers). In the Network, Publishers (Affiliates) can access various promotional offers, known as “Offers,” presented by Point2Web LLC or/and Advertisers.

When Publishers (Affiliates) decide to engage with an Offer, they explicitly grant permission to showcase these Offers across their Media. The primary objective for the Publishers (Affiliates) within the P2W Network is to generate Leads for the Advertisers effectively. P2W Network serves as a platform where Advertisers gain visibility and potential customers, while Publishers (Affiliates) can earn commissions by directing traffic and generating Leads for the Advertisers.

Media – Publisher (Affiliate) websites and other sources and digital properties they use to showcase the Offers.
Lead(s) – potential customers or prospects who have expressed interest in the products or services offered by the Advertiser.
Lead Data – information of or relating to a specific End User – consumer, that may be interested in getting a product or service from Advertisers. Lead Data means a unique bundle of contact and other information about an End User including, but not limited to Personal Data, and the User’s request for a particular type of product or service that Publishers may collect.
Offer – strategically designed data about Advertiser`s products or services provided to the Network by Point2Web LLC or/and Advertisers to be placed by Publishers via their Media to target audience as part of a marketing campaign with different promotional tactics that aim to attract and engage customers, stimulate sales, and enhance brand visibility.
P2W Website (Website) – a corporate official P2W website located at the address: https://grunge.point2web.com/.
Internal team of Media Buyers – non-outsourced internal P2W Publishers (Affiliates) who manage media buying activities for P2W business, including P2W Network.
P2W Partner(s)(or Partners) – Point2Web Network Members – both outsourced external Advertisers and Publishers (Affiliates) who actively participate in the Network, working collaboratively to drive marketing and advertising initiatives and to achieve mutually beneficial goals.
Advertiser – P2W Partner and P2W Network Member – an individual or business entity that seeks to promote its products, services and places the Offers through the Network. Advertisers typically create marketing campaigns or promotional content, such as advertisements, special offers or products to attract potential customers or leads with the help ofPublishers (Affiliates) within the Network. Advertisers are interested in acquiring leads, customers, or conversions through Network Publishers (Affiliates) efforts.
Publisher (Affiliate) – P2W Partner and P2W Network Member – an individual or business entity that actively participates in the Network by displaying advertisements, promotional content, or marketing offers on their Media. Publishers (Affiliates) collaborate with Advertisers to promote the Advertiser’s products, services (or Offers) to a broader audience by incorporating various advertising materials, such as banner ads, text links, or other promotional assets into their online Media. Publishers (Affiliates) may select Offers from the Network that align with their niche, audience, or content to effectively monetize traffic, facilitate conversions and generate revenue through the Network.
Publishers (Affiliates) earn compensation in the form of commissions for their promotional efforts when the desired actions occur, such as clicks, sales, leads or other pre-defined objectives.
End User(s) – final consumers – individuals who ultimately receive offers about the Advertiser`s products, services being promoted by the Publishers (Affiliates) through the Network. Their role is to potentially engage with the Advertiser`s marketing materials and offers presented to them by the Publishers (Affiliates). They may interact with advertisements, click on links, visit websites, make purchases or provide contact information to express interest in a product or service. End User`s actions represent the conversion point in the marketing funnel, where the desired goals of the Advertisers, such as making a sale or acquiring a lead, are achieved.
End User is the ultimate target audience that the Network’s marketing activities are designed to reach by the Publishers (Affiliates) and convert into customers, clients or leads for the Advertisers participating in the Network.
Everflow – web-based advertising network, affiliate tracking, targeting, reporting and analytics services (“Everflow Platform Services”), owned by Everflow Technologies Inc. P2W is an Everflow customer that uses Everflow Platform Services and provides Everflow Platform Services to P2W Partners.
P2W Partner Program – marketing initiative provided by Point2Web LLC through the Network that offers a structured framework for Advertisers and Publishers (Affiliates) to collaborate as partners within the Network. P2W Partners can become Advertisers to offer their products or services to be promoted or Publishers (Affiliates) to promote various Advertiser`s products, services. The P2W Partner Program aims to create a mutually beneficial partnership, allowing Publishers (Affiliates) to monetize their digital assets (Media) while helping Advertisers reach their marketing goals.
Personal Data – any information that may be used to identify, describe, be reasonably linked to an individual or is associated with an identifiable person. This data is a fundamental component of marketing and advertising, as it helps target and customize marketing efforts for a specific audience – End Users.

2. A PERFORMANCE NETWORK. PRIVACY POLICY PURPOSE

Point2Web LLC (“Point2Web”, “P2W”, “we”, “us”, “our”) is a company that owns P2W Network Platform (or P2W Network) – a global marketing ecosystem that provides the most effective performance solutions for Network Partners – Advertisers, Publishers (Affiliates) and agencies.

P2W offers an intuitive platform where Advertisers and Publishers (Affiliates) can launch, monitor, track, optimize and analyze advertising campaigns.

P2W Network operates with support of

internal team of Media buyers and
P2W Partners

who use P2W Network for web-based advertising network services, affiliate tracking, targeting, reporting, analytics services etc.

P2W also has its corporate Point2Web Website. Please note that this Privacy Policy refers only to P2W Network and does not apply to data we may collect when you visit the P2W Website.

Our Network Platform is designed so that P2W does not interact directly with End Users, at the same time P2W Partners directly interact with End Users and have access to their Personal Data.

2.1. Everflow

We do not directly collect Personal Data from End Users.

However, as a Network we are an Everflow Customer, and we provide our Partners Everflow Platform Services as a tool that processes data from End Users.
P2W Partners may use the Everflow Platform Services to collect and process End User’s Personal Data for the purpose of marketing to them.

To know more about how Everflow processes data from End Users, please visit Everflow Privacy Policy page Privacy Policy (everflow.io).

It is crucial to understand that the direct collection, storage, processing, transfer and storage of End User`s Personal Data is carried out by our Partners and is regulated by their privacy policies and privacy practices.

If P2W collects any Partner`s Personal Data, Everflow does it on our behalf as “data processor” or “service provider”.

We care about the issue of Personal Data, so we created this Privacy Policy (or Policy) to transparently and clearly describe the processes that generally occur in connection with

Partner`s Personal Data that P2W can collect, use and store as a Network and
End User’s Personal Data: by whom it can be collected, for what purposes, how it can be used, to whom it can be transferred and so on.

This Privacy Policy addresses neither P2W Network Partner`s privacy practices or policies, nor any websites, mobile apps or other property owned and/or operated by P2W Partners that can be accessible for End Users, including by displaying advertising materials via the Network.

3. POINT2WEB PARTNERS REQUIREMENTS

Despite the fact that P2W cannot control and be responsible for its Partners, including their actions regarding the End Users’ Personal Data management, we put forward a number of requirements for our Partners and strive to ensure that all of our Partners strictly comply with them.

3.1. Point2Web Partner should:

3.1.1. agree that, where applicable, its marketing and data collection practices shall comply at all times with the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR) 2016/679, as amended and adopted by the member states of the EU, and all related directives, acts, or regulations;

3.1.2. represent and warrant that its End User data collection practices are performed in a manner that obtains the necessary knowing and frequent consents from End Users and that all End User data is stored using industry-standards and the best security protocols;

3.1.3. maintain records evidencing such End User consents for a period of five (5) years including, without limitation: (a) opt-in date; (b) registration source; (c) first name; (d) last name; (e) mailing Address; (f) email address; (g) Privacy Policy of Source Site; (h) any other information collected; and will supply such records to P2W within three (3) business day after the request;

3.1.4. if Partner located outside the United States offering or distributing (or potentially distributing) End User’s Personal Data outside the United States, Partner will be familiar with the particular laws, regulations and industry customs in those countries and will comply with all laws, regulations applicable to the operation of its business, its marketing practices and the collection and/or transfer of End User`s Personal Data to such countries;

3.1.5. comply with all applicable foreign, federal, state or local laws, rules, regulations and ordinances including, without limitation, the Gramm-Leach Bliley Act, the Fair Credit Reporting Act, the Federal Trade Commission Act, CAN-SPAM, the Telephone Consumer Protection Act (TCPA), the Fair Debt Collection Practices Act, the Federal Communications Act, and all rules and regulations promulgated under any of the foregoing, as well as all applicable state laws;

3.1.6. create an internal Stop-list with the numbers of potential End Users who have added their number to the National Do Not Call Registry and have expressed a desire not to receive any unwanted calls or messages on their number by sending a message with the text “Stop” or similar;

3.1.7. create a list of all email addresses and/or domains associated with unsubscribe (opt-out) requests (“Suppression List”) that it receives from End Users. Publisher should update “Suppression Data” not less than every seven (7) days; use any such Suppression Lists to remove all email addresses and/or domains contained therein from future email dissemination; hold any such Suppression List in trust and confidence and use the same solely for the suppression purposes set forth herein.
Publisher agrees that Suppression Lists may NOT be used by Publisher for any purpose other than to comply with applicable laws regulating email marketing. Publisher agrees to maintain tangible records evidencing the removal of any email addresses from all applicable Suppression Lists for verification by P2W upon request.

3.1.8. avoid using any End User’s Personal Data to commit fraud or violate any applicable law.

PW2 has zero tolerance to fraud. If, at any time, P2W suspects or detects fraud, it reserves the right in its sole discretion to immediately terminate Publisher’s approval to participate in the P2W Partner Program pending further investigation.
Publishers agree that P2W, in its sole discretion, shall be responsible for determining the existence of fraud; and Publishers shall be bound by all such determinations.

3.2. We also have some expectations from Partner`s Media:

3.2.1. We ask all Partners to post and make available on their Media to End Users, including prior to the collection of any Personal Data, a privacy policy in compliance with all applicable laws that clearly and thoroughly discloses all information collection, use and sharing practices, including providing collected Personal Data to the third parties (P2W and/or Advertisers) in connection with taking part in any P2W Network program;

3.2.2. Partner`s Media must be fully functional at all levels and in compliance with state and federal rules, regulations and statutes pertaining to internet marketing;

3.2.3. No Media is targeted to End Users under the age of eighteen (18);

3.2.4. Publisher is prohibited from using Media that include or display any content that contains, promotes, references or links to: (i) material that exploits children or otherwise exploits any individuals under eighteen (18) years of age; (ii) material that is grossly offensive, including blatant expressions of discrimination, bigotry, prejudice, racism, sexism, ageism, gender-bias, hatred or excessive profanity or that is abusive, invasive, lewd, lascivious, libelous, defamatory, vulgar, obscene, harassing, threatening or otherwise unlawful or threatening against an individual or group; (iii) false, misleading, illegal or deceptive activity; (iv) pornographic, sexually explicit or otherwise adult-oriented content, including but not limited to magazines, video and software, or escort services; (v) political, religious or charitable organizations, issues or causes; (vi) firearms, weaponry, ammunition, fireworks, explosives hazardous materials, hazardous substances or instructions on how to assemble or otherwise make bombs, grenades or other weapons; (vii) odds making and betting/gambling services, including but not limited to poker, casino games, horse and dog racing and college and pro sporting events; (viii) tobacco and tobacco-related products, alcoholic beverages, illegal drugs or drug paraphernalia; (ix) infringements or misappropriations of the intellectual property rights of any third party; (x) material that introduces viruses, worms, harmful code and/or Trojan horses on the Internet; (xi) material that is unsolicited or unauthorized, including advertising, solicitations, promotional materials, junk mail, spam, chain letters, pyramid schemes or ponzi schemes; or (xii) content otherwise deemed unsuitable.

3.2.5. Other criteria as P2W may from time to time determine, in its sole discretion.

P2W in no way shall be an owner of the End User’s Personal data, P2W can receive only the right to access the End User’s Personal Data solely in connection with the provision of the Network Services to the P2W Partner.

4. PERSONAL DATA COLLECTION

4.1. PARTNER`S PERSONAL DATA COLLECTED VIA THE POINT2WEB NETWORK

Point2Web Partners apply to participate in the P2W Partner Program. In connection with the Partner Program they may see Offers by Point2Web LLC or Advertisers that may link to a specific web site for that particular Offer.

P2W requires personnel contact details to set up a P2W Partner account – including First name, Last name, TAX ID/VAT/SSN, address (including city, country and postal code), email address, social networks contacts or links, phone number, company name, website URL.

We never ask our Partners to share sensitive information.

At our instruction Everflow may collect the following types of information:

Cookies
IP addresses
Browser user agent
Ad Identifiers (unique character strings associated with user devices and may be reset by the user)
Approximate geographic location data derived from IP address and/or wifi networks
Pixel tags

By Everflow we can manage information provided by our Partners.

Personal data. We may receive Personal data of our potential Partners from correspondence with them if they first contact us by email and provide such Personal data by themselves. Please, note, that if you want to become a Partner, it is always your choice whether or not to provide that Personal data to P2W Network.

We may only collect your personal information if you provide it voluntarily by filling out and submitting an application form. By voluntarily providing this personal information to us, by sending us a comment or suggestion, you consent to the collection, use and disclosure of your personal information by us for the purposes set out herein.

Non-personal data. Non-personal data is information that, by itself, cannot be used to track or identify a person, i.e. information without specific reference to the identity of the user from whom it was collected.

When you use the Network, information about your visit and navigation may be collected and stored. This information may include the duration of your visit, the date and time of your visit, the pages you view and the sites you visit before and after leaving. Non-personal information does not include personally identifiable information such as name, postal, e-mail address or telephone number. We use this non-identifiable and aggregate information to better design our Network Platform and to optimize our services and/or our activities. We may also share this general non-identifiable information with our suppliers, partners, and third parties.

When you access the Network, some Technical information may be gathered automatically such as IP address, browser and device characteristics, operating system, preferred language, referring URLs, device name, and other technical information may be included in this information even though it does not specifically identify you. This data is largely required for internal analytics and reporting, as well as to ensure the security and functionality of our services.

How much information we collect depends on the type and settings of the device you use to access the Network. You can always limit the amount of technical information accessible to us by changing your device settings. Still, please note that it can influence your ability to use our Network successfully.

Cookies. P2W Network uses cookies to associate certain internet-related information about Partners who use the Network with information about them in our database.

A cookie is a small amount of data stored on your computer’s hard drive, allowing us to identify you with the corresponding data in our database. Cookies do not reveal any personal information. The only personal information that a cookie can be linked to is information you provide yourself, such as your email address, or information about your actions and behavior while using our Network, such as purchases and preferences. Cookies cannot read data off your hard drive. If you want to delete cookies from your computer, please go to your browser settings and do it manually.

4.2. PARTNERS AND END USER’S PERSONAL DATA

Via Offers Point2Web makes available to Publishers graphic and textual links to the Advertiser`s Web Site and/or other creative content, materials (collectively, the “Links”) which Publishers may display on their Media, in emails sent by them and/or by other online advertisements tactics provided to End Users. This is how Publishers act, interact with End Users and can receive access to their Personal Data.

This Privacy Policy describes P2W as a technology and tools provider that is not engaged in brokering, displaying or executing any Media by advertising campaigns.

P2W Partners collect End User`s Personal Data through the Everflow Platform Services that allow them to collect various kinds of information about their End Users:

“Cookies” – small text files that are saved by your browser) and “pixel tags” or “web beacons” (one-pixel graphic files which are delivered from the Everflow Platform Services web server) that can be placed in advertisements or on websites or other apps to collect information about End User interaction with the advertisements or websites. When an End User views or clicks on an advertisement, goes to a specific web page, or takes any other action that an Partner chooses to monitor, the Everflow Platform Services collect information from the End User’s computer or device.

Log Data. The Everflow Platform Services automatically record certain information (“Log Data”) when an advertisement is displayed to an End User through the Platform Services, or when an End User views a web page with a cookie or pixel tag created with the Platform Services. Log Data may include information such as an End User’s Internet Protocol (IP) address and network status, mobile device identifier, application identifier, browser type, operating system, the pages or page features which an End User browsed and the time spent on those pages or features, frequency with which the Platform Services encounter the same End User, search terms, the links or advertisements on which an End User clicked, and other statistics.

Advertising Identifiers. As part of the Log Data, the Everflow Platform Services may collect advertising identifiers, which are resettable identifiers unique to your mobile device, and which are used in connection with advertising delivered to your mobile device.

Location Information. The Everflow Platform Services may collect and store information about where End Users are located, both by collecting precise geolocation information from mobile device if and as permitted by End User, and by converting IP address into a rough geolocation and utilizing mobile phone number to approximate rough geolocation information (based on area code).

Collection, retention, processing and other use of End User`s Personal Data by P2W Partners, whether or not in connection with the Network services (Everflow Platform Services), is governed by their own privacy policies and applicable laws, rules or regulations. P2W does not control any of P2W Partner`s activities.

To know exactly the list of Personal Data that Partners may collect, we strongly recommend each End User refer to the Privacy Policy of a particular Partner or send a request to them directly.

5. PERSONAL DATA COLLECTION PURPOSES AND USE

5.1. P2W uses Partner`s Personal Data for various purposes, including:

Ensuring that Network Platform remains relevant and is easy to use by obtaining analytics and other data regarding its use;
Sending marketing and promotional communications in compliance with applicable law;
Enhancing, improving, or modifying Network Platform and services,
Enhancing security or combating spam or malware or other security risks;
Providing confirmations, invoices, technical notices, updates, security alerts, and other support and administrative messages, to respond to Partner`s questions;

We can use Non-personal and Technical data to:

Understand and analyze usage trends and preferences of our Partners across different devices;
Perform data analyses (including market and consumer research, trend analysis, financial analysis);
For fraud detection and information security, to protect against, identify and prevent fraud and other criminal activity, claims and other liabilities, and comply with and enforce applicable legal requirements, relevant industry standards and our policies.

We can contact you only if you give us your contact details (email, social network data) directly and voluntarily:

for administrative purposes such as customer service;
to send promotional materials, offers, and/or messages related to the Network and the activities of third parties we work with only after receiving your active consent.
Generally, you can opt out of receiving promotional communications through the links provided in the messages or by contacting us directly by the email below.

We are not selling Personal Data and will not use it to infringe any privacy rights, property rights, or any other rights (yours or of any third party`s).

We can use Personal Data to receive the following types of data analysis functionality within the Everflow Platform Services:

Measuring the performance of advertising campaigns (including fraudulent Peractivity);
Identifying possible relationships among different browsers and devices;
Limiting the number of times a specific advertisement is presented to the same browser or mobile device (frequency capping);
Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region or among a particular demographic); and
Improving the targeting or relevance of advertising to users.

5.2. The primary purpose for which our Partners may collect Personal Data from End Users is to obtain Lead Data .

That is, Personal Data that End Users provide to our Partners must ultimately be generated into a Lead. Publishers (Affiliates) transfer this Lead Date to Advertisers.

How does it work? The End User may be interested in certain goods or services on the Publisher`s Media. In this case, the End User provides his Personal data via the Media. Publisher collects it and transfers it to the Advertiser.

It is important to understand that if the End User shares his Personal Data with the Partner, he must be contacted by them or other third parties.

P2W Partners may use Personal data to provide promotional offers to End Users by means of email advertising, telephone marketing, direct mail marketing, mobile marketing, online banner advertising and package stuffers etc.

6. CAN SPAM ACT. TELEMARKETING. TARGETED ADVERTISING

WE HAVE A STRONG EXPECTATION THAT OUR PARTNERS WILL BE COMPLIANT WITH:

6.1. CAN SPAM ACT

P2W Partners may use End User`s Personal Data to perform email campaigns – to send certain commercial email messages to End Users for products which may be of the End User’s interest.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

P2W Partners must strictly comply with the federal CAN-SPAM Act of 2003 (the “Act”). It is solely the P2W Partner’s obligation to ensure that the email complies with the Act. P2W Partner agrees not to rely upon Point2Web LLC’s approval of P2W Partner’s email for compliance with the Act or assert any claim that P2W Partners are in compliance with the Act based upon Point2Web LLC approval.

We expect from our Partners:

delivering commercial emails only to those End Users who have given appropriate notice and choice regarding the intended use of their Personal Data, and who have not requested not to receive future commercial e-mail communications from that sender at an email address;
identifying the message as an advertisement in some reasonable way.
refraining from falsifying email header and transmission information (including, but not limited to source, recipient, and routing information);
refraining from seeking or gaining unauthorized access to End User`s computer or other device for the purpose of sending any commercial email;
including in all commercial emails sent: clear and conspicuous opt-out notice with the most up-to-date unsubscribe link; a clear and conspicuous identification that the e-mail message is an advertisement (if it is so) and the clear process of how to opt-out from its receiving.
honoring opt-out/unsubscribe requests quickly.

P2W Partners should maintain separate email lists for different purposes.

For all email campaigns, P2W obliges P2W Partners to download the “Suppression List” from the Offers section of Point2Web LLC. P2W Partners shall filter their email lists by removing any entries appearing on the Suppression List and can only send emails to the remaining addresses on its email list.

6.2. TELEMARKETING

P2W Partners may use End User`s Personal Data to advertise, directly or indirectly, to End Users via telemarketing or cell phones.

Notwithstanding that End User`s telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, if End User directly provides his telephone number to the P2W Partner, it means that such an End User have authorized P2W Partner to contact the End User via telemarketing in accordance with the law and expressly agrees to be contacted in any way, including SMS messages (text messages), telephone calls using prerecorded messages or artificial voice, and telephone calls and messages delivered using auto telephone dialing system or an automatic texting system.

Moreover, by providing the telephone number, the End User provides his consent to be contacted by third-party advertisers at or through the Network or other advertising media via telemarketing by such third-party advertiser in accordance with the law.

In the event End User stops using any of the phone numbers, provided to the P2W Partner, or wants to withhold the consent previously provided to be contacted by telephone, End User should promptly alert P2W Partner about this.

6.3. TARGETED ADVERTISING. OPTING OUT OF TARGETED ADVERTISING

Targeted Advertising. P2W Partners may use Personal Data to provide the End User with customized content and advertising (including targeted advertising that is based on the End User’s interests and preferences and is likely to be interesting and relevant to End Users (in the Surveys, for example). At their sole discretion, Partners may target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

End User’s Personal Data may be matched with other information to track a person’s online browsing habits on the Internet. This information may help P2W Partners better understand individuals’ online habits so that P2W Partners can target advertising and promotions to them.

6.3.1. Opting Out of Targeted Advertising

If End Users wish to “opt out” of targeted advertising, they must be provided with the clear options to do so by P2W Partners.

Generally, Partners should create the conditions to End Users to opt out of receiving promotional communications through the links provided in the messages or by contacting Partners directly.

It is important to note that this Privacy Policy does not directly govern the rules for collection, use and disclosure of End User`s Personal Data by P2W Partners.

We have included this section to provide the insights and better understanding of the potential handling of End User`s Personal Data. However, it is imperative to understand that P2W does not possess the capability to fully oversee the actions of its Partners. As a result, the specific procedures concerning the collection, use and disclosure of End User`s Personal Data can be obtained directly from them.

7. RIGHTS REGARDING PERSONAL DATA

7.1. P2W Partners are entitled to the full range of rights under the GDPR, and P2W is committed to respect these rights, including:

7.1.1. access to Personal data (Art. 15 GDPR);

7.1.2. Personal data rectification (Art. 16 GDPR);

7.1.3. Personal data deletion (Art. 17 GDPR; CCPA);

7.1.4. restriction of Personal data processing (Art. 18 GDPR);

7.1.5. Personal data transfer (Art. 20 GDPR; CCPA);

7.1.6. object of Personal data processing (Art. 21 GDPR);

7.1.7. object of Personal data automated processing (if any) (Art. 22 GDPR);

7.1.8. withdraw consent to Personal data processing, if applicable (Article 7(3) GDPR);

7.1.9. lodge a complaint with a national supervisory authority (in the EEA) if privacy rights have been violated (Art. 13(2)(d), 14(2)(e), 15(1)(f) GDPR);

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information.

To exercise these rights, please contact us as indicated in this Privacy Policy`s ‘How To Contact Us’ section.

If you are a California resident, please consult the section 8 below and section 9 below if you are a resident of some other US states for more information about your rights.

Yes, as we mentioned, we do not collect End User’s Personal data. At the same time we want our Partners to know about the rights they can have and to encourage them to provide the End Users with all necessary and applicable rights regarding End User’s Personal Data with an extent no less than the list of rights described in this Policy.

8. SPECIAL NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, then if you provide us with your personal data, you have certain rights under the California Consumer Privacy Act (“CCPA”) regarding your Personal data:

8.1. Access to Personal data Rights. You have the right to request us to provide you with certain information about our collection, use and disclosure of your Personal data. This includes your right to request the specific pieces of Personal data that we have collected about you.

8.2.Deletion Request Rights. You have the right to request us to delete any of your Personal data that we collected from you and retained, subject to certain exceptions provided by law.

To exercise your access or deletion request rights, please submit a verifiable consumer request to us as indicated in this Privacy Policy’s ‘How To Contact Us’ section.

Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal data. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you as the person about whom we collected Personal data or an authorized representative of such a person.

Describe your request with sufficient detail that allows us to understand, evaluate and respond to it properly. We cannot respond to your request or provide you with Personal data if we cannot verify your identity or authority to make the request and confirm that Personal data relates to you.

8.3. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

deny you goods or services;
charge you different prices or rates for goods or services;
provide you a different level or quality of goods or services;

8.4. We also plan to introduce new opportunities for the implementation of the rights of users – residents of California after the entry into force California Privacy Rights Act (CPRA), which introduces four California consumer privacy rights that are not present in the CCPA:

Right to Correct Information
Right to Limit the Use and Disclosure of Personal Data
Right to Access Information About Automated Decision Making (if any)
Right to Opt–Out of Automated Decision-Making Technology (if any).

8.5. We do not sell personal information to third parties for monetary value.

9. INFORMATION FOR NEW YORK, COLORADO, NEVADA, VIRGINIA AND OTHER STATES RESIDENTS

US state privacy regulations provide New York, Colorado, Nevada, and Virginia residents with specific rights regarding their Personal Data. If you are a resident of the mentioned state for more information please see the NY Privacy act (NYPA), Colorado Privacy Rights Act, Nevada Privacy Law (NPICICA) and Amendment SB-220 and Virginia Consumer Data Protection Act and find rules that apply to you:

If you are a resident of the states mentioned above, in case you will provide us your Personal Data your rights will include:

Right to notice – means the right to be informed about: (i) a description of your rights (ii) the categories of personal data processed by us; (iii) the sources from which personal data is collected; (iv) the purposes for personal data processing; (v) the categories of third parties to whom we disclose, share, transfer your personal data (vi) retention period for personal data that we process.

Right to opt out – means the right to opt out, at any time, of your personal data processing concerning: (i) targeted advertising; (ii) personal data sale; and (iii) profiling decisions that produce legal or similarly significant effects on you.

Right to access – means the right to request: (a) whether or not we are processing or have processed your personal data, and have access to a copy of any such personal data; and (b) receive the list of processors or third parties to whom we disclosed, transferred your personal data.

Right to portable data – means the right to: (a) obtain a copy of all of, or a portion of, as designated in a verified request, personal data in a structured, commonly used and machine-readable format and (b) transmit the data to another person of your designation.

Right to correct – means a verified request to conduct a reasonable investigation to determine whether personal data, the accuracy of which is disputed by you, is inaccurate. If personal data is found to be inaccurate or incomplete, or cannot be verified, we will correct the inaccurate or incomplete personal data.

Right to delete – means a verified request to delete any or all of your personal data. Period for deletion is 45 days and may be extended once by 45 additional days where reasonably necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within 45 days of receipt of the request, together with the reasons for the delay.

We also want to emphasize that P2W cares about the privacy of its Partners. We have listed some of the states whose residents have the specific additional rights. However, if you are a resident of another state or territory not listed in this Policy but your local privacy law gives you some special right in the sphere of privacy, you are guaranteed to be able to use it.

10. PERSONAL DATA SHARING

10.1. P2W Partner`s Personal Data will not be shared unless Partner has provided their data to us.

If you are a Publisher (Affiliate), your Personal Data may be shared with P2W Advertisers for their request if they need to know the concrete Publishers who rule their campaigns. If you are an Advertiser, your data may be shared with the Publisher, who accepted your Offer on the Network.

10.2. We may share Technical information such as IP address as well as de-identified information:

with nonaffiliated third-party lending partners (for example, from a rate table or review);
with third-party service providers to support our internal and business operations. In such cases, service providers may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure.

For example:

for hosting, data storage, maintenance, and other services for us.
for internal marketing, delivery of emails, including promotional, marketing and transactional materials, delivery of other promotional materials, including via postal mailers, SMS and text messaging, and online and social media promotions and advertising.
for fraud prevention and security purposes.

10.3. We may share deidentified and/or aggregate analytics with third-party service providers to understand how Partners interact with our Network, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Network.

10.4. By submitting a request through our Network you consent to the disclosure of your information in order for us to carry out your request.

10.5. As this Privacy Policy mentions, P2W does not collect Personal Data from End Users.

Publishers (Affiliates) directly collect such Personal Data and share it with us through the Network for the purpose of further transmitting it to Advertisers, participants of our Network.

End User`s Personal Data disclosure by our Partners is subject to each specific privacy policies. P2W has no control over the means by which third parties further use or disclose your information.

End User’s Personal Data may be transferred to and maintained on computers located outside of their state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in the End User`s jurisdiction.

End Users should be acknowledged that the Personal Data they are providing may be collected and stored in the United States and outside the United States.

We cannot provide complete control over how and where End User’s Personal Data may be transferred by our Partners. Our strong expectation from them is that End User’s Personal Data is transferred only to the countries/territories where an adequate level of protection of such Personal Data can be ensured.

11. PARTNER LINKS

The concept of our Network is constructed in the way that our Publishers can place on/in their Media various links, including our Advertiser`s links. End Users may click on such links when using the Media and be redirected to the other websites, resources, apps etc.

We encourage our Partners to make it crystal clear to the End Users that when they click on a link, they interact with the owner of the resource to which they will be redirected via the link. Before providing any of their Personal Data, they should carefully read the privacy policy of such a resource.

We may also provide some links for our Partners. If you, as a Partner, click on any link available on the Network, you understand that you are leaving the area of P2W Privacy Policy responsibility. Any data that you provide to third parties outside the Network is your relationship with the recipient of your Data. Please read the recipient’s Privacy Policy before providing them with your Personal Data.

12. SECURITY MEASURES

We endeavor to safeguard and protect Personal Data we can obtain.

We can keep information in a variety of places, including electronic storage facilities, paper-based files and other documents.

We implement by ourselves and encourage our Partners to have administrative, organizational, technical and physical security measures in place to guard against the loss, misuse and alteration of the information collected and processed.

In the case of P2W Network, these safeguards apply to all repositories and transfers of Personal Data, including firewalls, digital certificates and encryption technology.

P2W uses servers in which we store Personal Data to be kept in a secure physical environment. We currently use Secure Socket Layer Software (“SSL”) to protect data and secure any transactions.

Authorized personnel and third-party service providers may have limited access to Personal Data, and they will only process data according to our instructions. Access to Personal Data is strictly limited, and not accessible to the public.

We have implemented mechanisms to:

Ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
Restore the availability and access to personal data promptly in the event of a physical or technical incident;
Regularly test, assess and evaluate the effectiveness of technical and organizational measures for ensuring the security of the data;

We take commercially reasonable measures to protect Personal Data from unauthorized access, use or disclosure.

However, please be aware that no method of transmitting or storing information over the Internet is completely secure. Accordingly, no one can guarantee the absolute security of any information.

Any transmission of data at or through our Network is at your own risk.

13. MINORS. CHILDREN ONLINE PRIVACY PROTECTION ACT

When collecting Personal Data from children under the age of 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old. We instruct our Partners not to use the Network services to direct advertising and other actions they may perform to children under 13 (16 in the EU) and we do not knowingly collect personally identifiable information from children under 13 (16 in the EU). If we learn that we have collected Personal Data of a child under the age of 13 (16 in the EU), we will take all necessary steps to delete such information from our files as soon as possible.

If you believe that we may have collected any such Personal Data through our services, please notify us as specified below and we will delete that information from our systems in accordance with applicable law.

We hope that our Partners also follow this rule and do not collect Personal Data from persons under the age of 13 (16 in the EU).

14. PERSONAL DATA RETENTION PERIOD. CHANGES TO THIS POLICY

14.1. P2W retains Personal Data that it processes on behalf of each P2W Partner for as long as needed to provide Network services.

P2W will also retain Personal Data as necessary for legal purposes (for example, to comply with its legal obligations, resolve disputes, and enforce its agreements).

Each P2W Partner sets the Personal Data retention period. If End Users have questions or want more details, they should contact the relevant P2W Partner directly.

14.2. As new services can be added or existing ones can be modified, we may amend or change this Policy.

We may change this Privacy Policy by posting a new version of this Privacy Policy.

When we do change the Policy, we will also update the “Revised” date and may notify you or post a message on the Platform. Modifications and changes are effective upon posting of the updated Privacy Policy. Please revisit this page periodically to stay aware of any changes to this Privacy Policy.

The most updated version of the Privacy Policy is our entire and exclusive Privacy Policy that supersedes any earlier version.

15. HOW TO CONTACT US

Please contact us at [email protected] if you have any requests or questions about our Privacy Policy or any privacy practices we use.