Affiliate Program Privacy Notice
Last Updated: 02.February 2023
This MNTD Affiliate Program Privacy Notice (the “Privacy Notice”) explains how your personal data is collected and processed when you participate in our MNTD Affiliate Program (the “Affiliate Program”). We kindly ask you to read this Privacy Notice carefully before participating in the Affiliate Program or creating an affiliate account at https://getmntd.goaffpro.com (the “Affiliate Account”).
1. Contact Information
The Affiliate Program is operated by MNTD PTE. LTD. (“we”, “our”, “us”), a company registered in Singapore, having Unique Entity Number 202124287C and registered address at 1 Marina boulevard #28-00, One Marina Boulevard, 018989, Singapore.
With respect to the personal data collected in relation to the Affiliate Program, we act as a data controller.
Data Protection Officer
MNTD has appointed the external Data Protection Officer (DPO) — Sekürno OÜ (an information security and data protection firm). The DPO can be reached at [email protected].
Please contact us or our DPO to receive answers to any data protection-related questions. Please note that we may record any communication to preserve the evidence of your request and our response.
MNTD has appointed an EU Representative (as required by Article 27 of the GDPR) — Rickert Rechtsanwaltsgesellschaft mbH. EU Representative may be reached at [email protected]. The representative acts as a contact point for supervisory authorities and data subjects located in the European Union.
2. What Personal Data Is Collected
In order to participate in the Affiliate Program, you have to create an Affiliate Account. The Affiliate Account is created within the GoAffPro platform (“GoAffPro Platform”). The operator of the GoAffPro Platform is a controller of the personal data you provided within the GoAffPro Platform. According to the applicable data protection legislation, we may be deemed joint controllers with respect to the personal data collected in the MNTD space of the GoAffPro Platform available at https://getmntd.goaffpro.com. You may exercise your data protection rights against both us and the operator of the GoAffPro Platform. However, if you exercise your data protection rights against us, this will affect only the personal data processed by us. If you want to exercise your data protection rights in relation to the GoAffPro Platform, you should contact the operator of the GoAffPro Platform.
Also, please note that the operator of the GoAffPro Platform may have different grounds, purposes, and means of processing your data. For more details, please see GoAffPro Platform Privacy Notice or contact the operator of the GoAffPro Platform.
In order to create an Affiliate Account, you have to provide your name, email address, password, your country, and PayPal email address.
You may also sign up using your Google or Facebook account. In this case, Google or Facebook will provide your name, email address, and profile photo.
When you create an Affiliate Account, you are automatically assigned with a unique profile ID, which is a set of random numbers. Profile ID by itself is not personal data and is used to count you as a user of the GoAffPro Platform.
In order to receive payments from us, you must provide us with your payment data, particularly your PayPal email. The payments may be executed only via PayPal.
Within the GoAffPro Platform you may also provide the following optional data:
The mandatory data is processed based on the performance of the contract with you, i.e., to ensure the performance of our arrangements in relation to the Affiliate Program. The optional data is processed based on our legitimate interest to know you, our affiliate, better.
Please note that we may also use your personal data to resolve disputes, or protect our or third-party rights.
When you contact us, you may provide us with your full name, email address, and other personal information that (a) you chose to provide us or (b) is necessary for resolving the requested issue.
This data is necessary to address your issue, answer your request, contact you back, or address you properly, where and as applicable depending on the type of personal information. The legal basis for processing such data — is our legitimate interest to assist you with your request regarding the Affiliate Program or GoAffPro Platform.
When you visit the GoAffPro Platform, certain personal data is collected automatically via Google Analytics (the “Analytical Data”). The Analytical Data is collected via cookie technology. Cookies are small text files that are placed on your device while you visit the GoAffPro Platform. The data stored in cookies uses identificators unique to your device, so a specific device may be identified.
The Analytical Data is collected by the operator of the GoAffPro Platform, it is not controlled by us. However, we receive the reports containing the Analytical Data.
Please note the following information regarding the Analytical Data:
The Google Analytics cookies allow us to better understand users’ behaviour within the GoAffPro Platform, e.g., how many users visited the GoAffPro Platform, how long they stayed, and how they interact with the GoAffPro Platform and its content. The information gathered by Google Analytics includes the following:
the type of device used;
the device’s operating system; and
the browser used.
The IP address of the user is anonymised (masked). After collecting the aforementioned personal data, Google Analytics creates reports about the use of the GoAffPro Platform, which contain aggregated information where no one can see any data pertaining to a particular person. In other words, neither we nor anyone cannot identify you from the other visitors. Google Analytics prescribes users with a unique, randomly generated string that will allow them to further associate concrete users with their devices, but only for single browsing sessions.
For information regarding the retention periods, please see the Google Analytics documentation.
You may learn more about Google Analytics in the Google Analytics Privacy documentation.
Google Analytics is operated by Google Analytics, represented by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA, United States. Note that since Google is based in the US, competent US authorities may have access to the personal data collected via Google Analytics. In addition, Google may use this personal data for any of its own purposes, such as profiling and cross-platform tracking.
The Analytical Data is collected by the operator of the GoAffPro Platform, we process the Analytical Data based on our legitimate interest to know your activity in relation to the Affiliate Program.
3. How Your Personal Data Is Shared
Your data is shared as follows:
The Account Data and Analytical Data are processed by the operator of the GoAffPro Platform.
The Account Data, Contact Data, and Analytical Data are shared with our marketing team.
Your payment data is shared with our finance department and the relevant financial institution engaged to make the payments.
The Analytical Data is shared with the operator of Google Analytics — Google Inc, as well as with its affiliates.
We may share your Account Data with our affiliates if it is necessary due to our corporate and operational structures.
We may share your Account Data with government institutions that may request access to your personal data.
Please note that we and the aforementioned recipients may be located in jurisdictions that do not ensure the same level of data protection as the country of your residence. We will endeavor to protect your personal data while it is processed, stored, or transferred.
If and to the extent we are subject to the General Data Protection Regulation, when we transfer personal data to a country that does not ensure the same level of data protection as the country of your residence, we will use additional safeguards, namely, Standard Contractual Clauses.
4. How Long Your Personal Data Is Stored
As a general rule, we store your data as long as it is necessary for the purposes it was collected and according to the requirements of the applicable legislation. Following the expiration of the storage period, such data will be either erased or anonymised. In particular, your personal data will be processed as follows:
mandatory Account Data is processed by us as long as you participate in the Affiliate Program and further as long as it is necessary under the requirements of the applicable legislation. According to the laws of Singapore, such data is stored for a period of five (5) years from the date it was collected.
optional Account Data is processed by us as long as you participate in the Affiliate Program.
Contact Data is processed by us as long as you participate in the Affiliate Program and further for one (1) year. This retention period is established due to the statutes of limitation established in the MNTD Affiliate Program Terms.
Analytical Data is processed in accordance with the Google Analytics documentation. Reports created by Google Analytics may be stored permanently, as they do not contain any personal data, only aggregated information.
5. Your Rights
According to the applicable data protection legislation you may have the following data protection rights:
right to access:
You are able to request us if we process your personal data. If this is the case, you may request access to your personal data that we store about you. Among others you may ask us regarding:
the purposes for collecting personal information about you;
categories of personal information concerned;
who receives your personal information or categories of such recipients;
how long we are going to store the information about you and if not possible criteria to determine the storage period;
when your personal information was obtained not from you directly, the source where it came from;
the existence of either profiling activities or automated decision making based on your personal information. Where such activities are performed, we should also inform you about the importance, and expected consequences of them;
a copy of your personal information processing. For such requests further, we may charge you with a reasonable fee. We generally provide users with an electronic copy of their personal information unless they request otherwise.
right to rectification:
You have the right to correct inaccurate (for example, old or incorrect) personal information related to you.
right to erasure or the right to be forgotten:
You have, under certain circumstances, the right to request the erasure of your personal information. Please note, that this right only applies to the data available at the time of request and is not applicable to future data.
Request to the erasure of personal information is possible when:
personal information is no longer needed for the purposes it was primarily collected or processed;
when you have already withdrawn your consent for processing your personal data, and we do not have other legal ground to process it;
when your personal data is processed under legitimate interest and you object to such legal ground. Moreover, there is no overriding legitimate interest to proceed to process your personal data;
your personal information was unlawfully processed;
when your personal data has to be erased due to legal obligation.
right to restrict processing:
You may request us to stop processing your personal information when:
you have reasonable doubts that your information is accurate, and we are verifying the accuracy of such information;
your personal information was unlawfully processed;
the purpose of your personal information collection no longer exists, but you wish to store it longer to defend a legal claim.
Moreover, you may request us to stop processing your personal data while we are working on a rectification request or request to object to processing your personal information.
right to data portability:
You have the right to obtain from us and further reuse your personal data for your own purposes within other services. You will also be able to transfer your personal information from one IT environment to another in a safe and secure way, when certain conditions apply, such as:
the processing is based on your consent or needed for the performance of a contract with you;
the processing is made only electronically, without any paper-based files included.
right to object:
You have the right to object to the processing of your personal information at any time. This allows you to prevent us from (stop) processing your personal information. This right applies only when one of the following conditions are met:
your personal information is used for direct marketing purposes;
the processing is based on our legitimate interest;
we are performing tasks carried out for the public interest or by governmental authority;
your personal information was processed for either research or statistical purposes.
right not to be subject to automated decision-making and profiling:
Currently, we do not use your personal data for profiling or decisions made solely by automated means.
right to lodge a complaint with a supervisory authority:
You have a right to lodge a complaint with a data protection authority in a country you either reside, permanently live, work, or in a country where data protection infringement takes place.
6. Personal Information of Minors
The Affiliate Program is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use the personal data of children, and in case we receive such data, we will erase it within a reasonable timeframe.
We keep this Privacy Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please, review this Privacy Notice regularly.