Clickwire

Data Processing Agreement

This Data Processing Agreement lays out the responsibilities of Clickwire B.V., a private company with limited liability, established and existing under the laws of the Netherlands, having its registered office in (3512 BW) Utrecht, the Netherlands, at Boothstraat 2a, registered with the Chamber of Commerce under 83808493 (hereinafter referred to as “Clickwire”) to its customers with regards to data protection in general and the European Union’s General Data Protection Regulation (GDPR) specifically.

Clickwire as a Data Processor:

Clickwire helps affiliate publishers to gain a better overview of their sales performance. In order to do so, Clickwire collects, processes and matches click and sale data, collecting those from different sources on behalf of the affiliate publisher.

1. Definitions

Clickwire is a Data Processor operating on behalf of its customers.

Customers are individuals or organisations paying money to use the Clickwire service.

Clickwire’s Customers are Data Controllers.

2. Processing of Personal Data

Use of the Service implies that Clickwire may process Personal Data on behalf of the Data Controller in accordance with the requirements of Data Protection Laws. The Data Controller will ensure that instructions to Clickwire for the processing of personal data comply with Data Protection Laws. The Data Controller is solely responsible for the accuracy, quality, and legality of Personal Data and the means by which it acquires Personal Data.

The inputs to the Clickwire Service provided by the Data Controller are Session, Click and Sales Data such as, online identifiers (including cookie identifiers, internet protocol addresses and device identifiers), client identifiers, advertiser identifiers, data source identifiers, URLs, action dates, sale information (including sale amount, commission and transaction status), currency information (including currency and exchange rate), processing status and processing date, and Results such as, Clicks report, Transactions report, Advertisers report, Network report, Network accounts report, Status report, and Overview dashboard.

3. Rights of Data Subjects

The Data Controller is solely responsible for the collecting of all necessary consent from Data Subjects to allow Clickwire to process personal data on its behalf.

Clickwire will, to the extent legally permitted, promptly notify the Data Controller if it received a request from a Data Subject for access to, or deletion of, that person’s personal data. Clickwire will not respond to a Data Subject request without the Data Controller’s prior written consent except to confirm that the request relates to the Data Controller. The Data Controller is solely responsible for completing such a request as required by law.

4. Personnel

Clickwire ensures that its personnel engaged in the processing of personal data are informed of the confidential nature of the Personal Data, have received appropriate training on their responsibilities and have agreed to confidentiality obligations that survive the termination of the person’s employment or engagement by Clickwire.

Clickwire shall take commercially reasonable steps to ensure the reliability of any Clickwire personnel engaged in the processing of personal data and that access to personal data by Clickwire is limited to those Clickwire personnel who require such access to perform the Services.

5. Security Measures

6. Security Breach Management and Notification

If Clickwire becomes aware of unlawful access to the Data Controller&quote;s personal data stored through the Services, or unauthorised access to the Services resulting in loss, disclosure, or alteration of the Data Controller&quote;s personal data (“Security Breach”), Clickwire will promptly: (a) notify the Data Controller of the Security Breach; (b) investigate the Security Breach and provide the Data Controller with information known to Clickwire about the Security Breach; and (c) follow its policies and procedures to mitigate the effects and to minimise any damage resulting from the Security Breach.

The Data Controller agrees that an unsuccessful Security Breach attempt will not be subject to the measures above. An unsuccessful Security Breach attempt is one that results in no unauthorised access to the Data Controller&quote;s personal data or to the Services storing your Personal Data, and may include, without limitation, pings and other broadcast attacks on firewalls or edge servers, port scans, unsuccessful log-on attempts, denial of service attacks, packet sniffing (or other unauthorised access to traffic data that does not result in access beyond IP addresses or headers) or similar incidents.

Notification(s) of Security Breaches, if any, will be delivered to one or more of the Customer’s business, technical or administrative contacts by any means Clickwire selects, including via email. It is Customer’s sole responsibility to ensure it maintains accurate contact information on Clickwire’s support systems at all times.

Clickwire’s report of and/or response to a Security Breach under this Section will not be construed as an admission by Clickwire to fault or liability with respect to the Security Breach.

7. Deletion of Customer Data

Clickwire agrees to delete Customer Personal Data in accordance with Clickwire’s procedures and Data Protection Laws. At a Customer’s request, Clickwire will provide the Customer with a certification of deletion of Personal Data.

8. Governing Laws

This Data Agreement is governed by the laws of France.

9. Legal Effect

This Data Agreement comes into effect from the time of purchase of a Clickwire subscription. It expires with cessation of the Customer’s Clickwire subscription.

Privacy Policy

Clickwire (“Us”, “We”, “Our”) operates https://clickwire.io (the “Site”).

Clickwire collects information about its website visitors in order to improve the user experience on the Site, analyse and improve content and services, and for marketing purposes. Sensitive data is encrypted and protected. We only collect and use Personal Data in the ways described below, and in accordance with the law and your rights.

By using the Site, you agree to the collection and use of information in accordance with this policy.

Data collected by Clickwire

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to;

In order to analyse and improve our service we may need to also collect information from website browsers. This is the data that most websites collect in order to use analytical tools, such as Google GA4.

The data we collect includes IP address, user-agent, browser type, operating system, referral URLs, device information, pages visited, links clicked, the requested URL, hardware settings and search terms. This data is merely used for analytical purposes. With your permission, data may also be used for marketing purposes.

As a browser on our website, and/or a user with an account, you have the right to request the deletion of data relating to you. After your deletion request, data related to you will be deleted within three weeks, or will lead to the deletion of your account. You may request the deletion of your data and/or your account by contacting us via info@clickwire.io.

Information from potential business partners

In order to establish new business partnerships we reach out to relevant online businesses via email. We only store the name and email address of the contact person and merely wish to establish contact via the email and follow up email we send. If you do not wish to be contacted by us again or want us to delete the contact details from our end please respond to our email and let us know. We will respect your privacy and remove any information related to your contact details and not contact you again.

How we use your data

If you give us permission, we may optimise our marketing campaigns to target personalised advertisements to you through the following ad platforms:

Google Ads

LinkedIn Ads

Facebook Ads

This is merely done to gain further registrations for our Service. In case you do not permit us to include you in our marketing lists, you will not be targeted with our personalised ads.

By signing up and confirming your email address, you agree to receive emails from Clickwire. You can unsubscribe from updates at the bottom of an email, however you will still receive emails regarding billing and other important aspects that require your attention.

Do we share your data?

We only share our collected data with service providers or tools that we make use of. Those third parties themselves have strict privacy policies in place. The parties we use are:

In case Clickwire is acquired by another company, the ownership of the collected data will be transferred to the company of concern.

How do we protect the data?

Databases and other services besides the web server are running in a private network, which isolates communication from the outside world. The data is also encrypted in transit and at rest. Sensitive user data such as login information, payment details, network API credentials are all encrypted using AES-256.

Cookies

Clickwire does not use cookies.

Changes

Clickwire may update this Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Last updated: 26-04-2024.

Contact

If you have questions, concerns or remarks concerning our Privacy Policy, please do not hesitate to contact us. You can send us an email to info@clickwire.io, and we will answer you as soon as we can.

Terms of Service

Please read these Terms and Conditions carefully before using the https://clickwire.io website operated by Clickwire B.V. Your access to and use of the Service is conditioned on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Service. By accessing or using the Service you agree to be bound by these Terms. If you disagree with any part of the terms then you may not access the Service.

Accounts

When you create an account with us, you must provide us information that is accurate, complete, and current at all times. Failure to do so constitutes a breach of the Terms, which may result in termination of your account on our Service. You are responsible for safeguarding the password that you use to access the Service and for any activities or actions under your password, whether your password is with our Service or a third-party service. You agree not to disclose your password to any third party. You must notify us immediately upon becoming aware of any breach of security or unauthorised use of your account.

Trial

If a Customer has been granted a trial of the Service, Clickwire will make one or more Services available to the Customer on a trial basis until the earlier of (a) the end of the trial period for which the Customer registered or are registering to use the applicable Service or (b) the start date of any purchased Services ordered by the Customer.

Any Data and Results will be permanently lost unless the Customer purchases the same Services as those covered by the trial.

For the duration of the trial period, the Customer has the nonexclusive, non-transferable, non-assignable, limited right to use the Service, subject to the terms of this Agreement, and solely for its internal business purposes to evaluate the Service and not for any production or commercial purposes.

The Customer is solely entitled to make a one-time use of the trial period. In the event the Customer registers for a second trial period (whether or not through different contact details), the Customer will pay Clickwire the then applicable rates for the Service.

Links to other websites

Our Service may contain links to third-party web sites or services that are not owned or controlled by Clickwire B.V. Clickwire B.V. has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party web sites or services. You further acknowledge and agree that Clickwire B.V. shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such web sites or services. We strongly advise you to read the terms and conditions and privacy policies of any third-party web sites or services that you visit.

Intellectual Property

The Service and its original content, features and functionality are and will remain the exclusive property of Clickwire B.V. The Service is protected by copyright, trademark, and other laws of both the EU and the US. Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of Clickwire B.V.

Termination

If you breach these Terms we may terminate or suspend your account immediately, without prior notice or liability. We may terminate your account at the end of your billing cycle for any reason. If you wish to terminate your account, you can do so by contacting us.

Liability

In no event shall Clickwire B.V., nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the Service; (ii) any conduct or content of any third party on the Service; (iii) any content obtained from the Service; and (iv) unauthorised access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.

Governing Law

These Terms shall be governed and construed in accordance with the laws of The Netherlands. All controversies, disputes or claims arising out of or relating to the Agreement or the breach thereof which shall not have been amicably settled by the parties shall be exclusively and finally settled by the competent civil court in Amsterdam, the Netherlands.

CoC: 83808493
VAT: NL862996119B01
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