Who are you and what do you want to know?
Commission Factory Pty Ltd (ACN 149 765 631) ("Commission Factory",
"Us", "We", "Our", "Company") is a provider of performance marketing software that gives online
retailers, agencies and affiliates real-time visibility of an affiliate marketing campaign
performance.
We want to get you to the information that is relevant to you as easily as possible. For this
purpose, please scroll to the relevant section below or click the relevant category here:
Questions?
If you have any questions about this Privacy Policy, including any
requests to exercise your legal rights, please contact us using the details set out below:
Privacy Officer
by e-mail at privacy@commissionfactory.com
Advertisers and Affiliates
How we use data from Advertisers and Affiliates?
Providing our services
We provide our Affiliates and Advertisers with
an account in our network interface to access our services. You will need to register there in order
to obtain
access to our technologies. We will collect all data which has been provided by you (both via the
interface or
otherwise), this will likely include your name, (company) address, telephone number or email
address.
We may collect information on the device you
are using to enter our interface pages such as your IP address, operating system and browser of your
device.
We will use such information for providing
and/or making our services available under the terms of use of our services or in the pursuit of our
legitimate
interest of the proper administration of our business.
Marketing to you or your company
We use various forms of marketing to provide
you with promotional materials about our services or those of advertisers and affiliates operating
on
the
network. We may process contact information that you provide to us (either via our website, through
business
cards, or through use of our services) for the purposes of marketing in accordance with our
legitimate
interests
to promote our business. You can always request to be removed from the mailing lists by
unsubscribing
at the
bottom of any marketing email or by contacting us.
Improving and optimising usability for you and
others
Our network interface uses cookies and other
mechanisms, to collect analytical information to help analyse how the interface is used. We process
this
information to improve our understanding and to compile statistical reports regarding that activity.
This
information is not used by us to develop a personal profile of you.
How do we use data to administer our business?
We process personal information for the
legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not
disrupt the
operation of our services, does not harass our staff or other individuals, and to enforce our legal
rights and
comply with our legal obligations.
Where we reasonably believe that you are or
may be in breach of any of the applicable laws, we may use your personal information to inform
relevant third
parties such as your email/internet provider or law enforcement agencies about the content.
With whom do we share your information?
Group members, personnel, service providers:
We keep your information confidential, but disclose it to our group members, our personnel,
suppliers
or
subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy
Policy.
However,
this is on the basis that they do not make independent use of the information and have agreed to
safeguard it.
Activities that are carried out by third party service providers include: website hosting, website
analytics,
customer relationship management, email marketing, and IT support.
Third parties: We may disclose your personal
information to third parties and service providers located overseas in connection with any purpose,
including to
overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of
your personal
information do not breach the privacy obligations relating to your personal information. We are not
responsible
for the privacy or security practices of any third party, including third parties that we are
permitted to
disclose an individual's personal information to in accordance with this Privacy Policy or any
applicable laws.
The collection and use of an individual's information by such third parties may be subject to
separate
privacy
and security policies. Such third parties include YouTube API Services (for further information on
this tool we
direct you to their Terms of Service and
Privacy Policy; you can visit the
Google security
settings page to revoke the access to your data).
Merger or acquisition: If we are involved in a
merger, acquisition or sale of all or a portion of our assets.
Required by law: In addition, we disclose your
information to the extent that we are required to do so by law (e.g. to government bodies and law
enforcement
agencies); in connection with any legal proceedings or prospective legal proceedings; and in order
to
establish,
exercise or defend our legal rights (including providing information to others for the purposes of
fraud
prevention).
Enforcement: We disclose your personal
information to third parties in order to enforce or apply the terms of agreements, to investigate
potential
breaches or to protect the rights, property or safety of Commission Factory, our customers or
others.
How do we keep your data safe?
We will take all reasonable technical and
organisational precautions to prevent the loss misuse or alteration of your personal information.
Please be aware that, although we endeavour to
provide security for information we process and maintain, no security system can prevent all
potential
security
breaches.
For how long do we keep your data?
We will only retain your personal information
for as long as necessary to fulfil the purposes we collected it for, including for the purposes of
satisfying
any legal, accounting or reporting requirements.
To determine the appropriate retention period
for personal data, we consider the amount, nature, and sensitivity of the personal data, the
potential
risk of
harm from unauthorised use or disclosure of your personal data, the purposes for which we process
your
personal
data and whether we can achieve those purposes through other means, and the applicable legal
requirements.
What rights do you have in respect of your
data?
We will honour your rights under applicable
data protection laws. These rights are not absolute, and they do not always apply in all cases. You
may:
- request access to your information
and information related to our use and processing of your information;
- request the correction or deletion
of your information;
- request that we restrict our use
of your information;
- request a machine-readable copy of
your information or that your information be transferred to other IT systems;
- object to the processing of your
information for certain; and
- withdraw your consent to our use
of your information at any time where we rely on your consent to use or process that
information.
Please send your requests to privacy@commissionfactory.com.
If you are unhappy with the way we are processing your personal data, please let us know by
contacting
us. If you do not agree with the way we have processed your data or responded to your
concerns, you can
submit a complaint to a Data Protection Supervisory Authority.
How do we apply external laws?
If you are:
- a resident of the European Union
accessing our online platforms or receiving our services in Australia; or
- accessing our online platforms or
receiving our services from within the European Union,
then in addition to our obligations under the privacy laws, we are required to comply with the
General
Data
Protection Regulation (EU) 2016.679 ("GDPR") with respect to your Personal Information.
If you are a resident of California USA, the California Consumer Privacy Act provides California
consumers with
the right to obtain information about the personal information that we collect, use, and disclose.
You
can
exercise your by contacting us. If you choose to exercise your privacy rights, you have the right to
not to
receive discriminatory treatment or a lesser degree of service.
We take the security and privacy of your personal information seriously and have prepared this
Privacy
Policy and
taken measures to collect, process and hold all personal information in compliance with United
States
privacy
laws and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.
What happens when we make changes to this Privacy Policy?
This Privacy Policy may be updated from time to time. We will notify you of any changes by posting
the
new policy
here and, where feasible, by letting you know by email.
Commission Factory Website Visitors
How we use data from visitors of our website?
To address your enquiries
If you contact us about our services, the forms you complete or the emails you send may include
information about
you, such as your name, your email address and your enquiry.
In line with the legitimate interest we have in promoting and operating our business, we will process
your
enquiries to reply and provide you with information about the services we offer.
To send you news and updates
If you ask to be added to our mailing list, we will keep you updated with information on news by
email
unless you
would like to be removed from that list (in which case please let us know by clicking unsubscribe at
the bottom
of any marketing email that you receive or by contacting us).
Social plugins
Commission Factory participates in and markets via social networks and has implemented certain social
plugins on
our websites. All social media plugins are used in the pursuit of our legitimate interest of
marketing
our
business and communicating with our business partners and the public.
When you enter a page on our website that contains a social network plugin, your browser or app will
establish a
direct connection to the social network's servers. The information that your browser has visited the
Commission
Factory page will be transmitted to the social network, even if you do not have an account with that
social
network or are not logged into your account. If you are logged in to your account at the same time,
a
page
impression may be assigned to your profile there.
How do we use data to administer our business?
We process personal information for the
legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not
disrupt the
operation of our services, does not harass our staff or other individuals, and to enforce our legal
rights and
comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may
use
your
personal information to inform relevant third parties such as your email/internet provider or law
enforcement
agencies about the content.
With whom do we share your information?
Group members, personnel, service providers: We keep your information confidential, but disclose it
to
our group
members, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the
purposes set
out in this Privacy Policy. However, this is on the basis that they do not make independent use of
the
information and have agreed to safeguard it. Activities that are carried out by third party service
providers
include: website hosting, website analytics, customer relationship management, email marketing, and
IT
support.
Third parties: We may disclose your personal information to third parties and service providers
located
overseas
in connection with any purpose, including to overseas cloud computing hosts. We take reasonable
steps
to ensure
that the overseas recipients of your personal information do not breach the privacy obligations
relating to your
personal information. We are not responsible for the privacy or security practices of any third
party,
including
third parties that we are permitted to disclose an individual's personal information to in
accordance
with this
Privacy Policy or any applicable laws. The collection and use of an individual's information by such
third
parties may be subject to separate privacy and security policies. Such third parties include YouTube
API
Services (for further information on this tool we direct you to their Terms of Service and Privacy
Policy; you
can visit the Google security settings page to revoke the access to your data).
Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our
assets.
Required by law: In addition, we disclose your information to the extent that we are required to do
so
by law
(e.g. to government bodies and law enforcement agencies); in connection with any legal proceedings
or
prospective legal proceedings; and in order to establish, exercise or defend our legal rights
(including
providing information to others for the purposes of fraud prevention).
Enforcement: We disclose your personal information to third parties in order to enforce or apply the
terms of
agreements, to investigate potential breaches or to protect the rights, property or safety of
Commission
Factory, our customers or others.
How do we keep your data safe?
We will take all reasonable technical and organisational precautions to prevent the loss misuse or
alteration of
your personal information.
Please be aware that, although we endeavour to provide security for information we process and
maintain, no
security system can prevent all potential security breaches.
For how long do we keep your data?
We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it
for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal
data, the
purposes for which we process your personal data and whether we can achieve those purposes through
other means,
and the applicable legal requirements.
What rights do you have in respect of your data?
We will honour your rights under applicable data protection laws. These rights are not absolute, and
they do not
always apply in all cases. You may:
- request access to your information
and information related to our use and processing of your information;
- request the correction or deletion
of your information;
- request that we restrict our use
of your information;
- request a machine-readable copy of
your information or that your information be transferred to other IT systems;
- object to the processing of your
information for certain; and
- withdraw your consent to our use
of your information at any time where we rely on your consent to use or process that
information.
Please send your requests to privacy@commissionfactory.com.
If you are unhappy with the way we are processing your personal data, please let us know by
contacting
us.
If we have a dispute regarding an individual's personal information, we both must first attempt to
resolve the
issue directly between us. If we become aware of any unauthorised access to an individual's personal
information, we will inform them and any supervisory authority as required, at the earliest
practical
opportunity once we have established what was accessed and how it was accessed.
How do we apply external laws?
If you are:
- a resident of the European Union
accessing our online platforms or receiving our services in Australia; or
- accessing our online platforms or
receiving our services from within the European Union,
then in addition to our obligations under the privacy laws, we are required to comply with the
General
Data
Protection Regulation (EU) 2016.679 ("GDPR") with respect to your Personal Information.
If you are a resident of California USA, the California Consumer Privacy Act provides California
consumers with
the right to obtain information about the personal information that we collect, use, and disclose.
You
can
exercise your by contacting us. If you choose to exercise your privacy rights, you have the right to
not to
receive discriminatory treatment or a lesser degree of service.
We take the security and privacy of your personal information seriously and have prepared this
Privacy
Policy and
taken measures to collect, process and hold all personal information in compliance with United
States
privacy
laws and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.
What happens when we make changes to this Privacy Policy?
This Privacy Policy may be updated from
time to time. We will notify you of any changes by posting the new policy here.
Job Applicants
How do we use data from job applicants?
As part of any recruitment process, we collect and process personal data relating to job applicants.
Such
information includes:
- your name, address and contact
details, including email address and telephone number;
- details of your qualifications,
skills, experience and employment history;
- information about your current
level of remuneration, including benefit entitlements
We may collect this information in a variety of ways. For example, it might be contained in
application
forms,
CVs or resumes, obtained from your passport or other identity documents, or collected through
interviews or
other forms of assessment, including online tests.
We need to process this information to take steps at your request prior to entering into an
employment
contract
with you. We also have a legitimate interest in processing personal information during the
recruitment
process
and for keeping records of the process.
Processing data from job applicants allows us to manage the recruitment process, assess and confirm
an
applicant's suitability for employment and decide to whom to offer a job.
How do we use data to administer our business?
We process personal information for the legitimate interests of ensuring that use of our services is
lawful and
non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other
individuals,
and to enforce our legal rights and comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may
use
your
personal information to inform relevant third parties such as your email/internet provider or law
enforcement
agencies about the content.
With whom do we share your data?
Group members, personnel, service providers: We keep your information confidential, but disclose it
to
our group
members, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the
purposes set
out in this Privacy Policy. However, this is on the basis that they do not make independent use of
the
information and have agreed to safeguard it. Activities that are carried out by third party service
providers
include: website hosting, website analytics, customer relationship management, email marketing, and
IT
support.
Third parties: We may disclose your personal information to third parties and service providers
located
overseas
in connection with any purpose, including to overseas cloud computing hosts. We take reasonable
steps
to ensure
that the overseas recipients of your personal information do not breach the privacy obligations
relating to your
personal information. We are not responsible for the privacy or security practices of any third
party,
including
third parties that we are permitted to disclose an individual's personal information to in
accordance
with this
Privacy Policy or any applicable laws. The collection and use of an individual's information by such
third
parties may be subject to separate privacy and security policies.
Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our
assets.
Required by law: In addition, we disclose your information to the extent that we are required to do
so
by law
(e.g. to government bodies and law enforcement agencies); in connection with any legal proceedings
or
prospective legal proceedings; and in order to establish, exercise or defend our legal rights
(including
providing information to others for the purposes of fraud prevention).
Enforcement: We disclose your personal information to third parties in order to enforce or apply the
terms of
agreements, to investigate potential breaches or to protect the rights, property or safety of
Commission
Factory, our customers or others.
How do we keep your data safe?
We will take all reasonable technical and organisational precautions to prevent the loss misuse or
alteration of
your personal information.
Please be aware that, although we endeavour to provide security for information we process and
maintain, no
security system can prevent all potential security breaches.
For how long do we keep your data?
We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it
for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity
of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal
data, the
purposes for which we process your personal data and whether we can achieve those purposes through
other means,
and the applicable legal requirements.
As a general rule, your personal information collected as part of your recruitment process will be
retained for
[6 months] following the notification on an unsuccessful application. In case of a successful
application, your
personal information will be retained as part of your personnel records and subsequent employee data
retention
periods will apply.
What rights do you have in respect of your data?
We will honour your rights under applicable data protection laws. These rights are not absolute, and
they do not
always apply in all cases. You may:
- request access to your information
and information related to our use and processing of your information;
- request the correction or deletion
of your information;
- request that we restrict our use
of your information;
- request a machine-readable copy of
your information or that your information be transferred to other IT systems;
- object to the processing of your
information for certain; and
- withdraw your consent to our use
of your information at any time where we rely on your consent to use or process that
information.
Please send your requests to privacy@commissionfactory.com.
If you are unhappy with the way we are processing your personal data, please let us know by
contacting
us. If we have a dispute regarding an individual's personal information, we both must first
attempt to
resolve the issue directly between us. If we become aware of any unauthorised access to an
individual's
personal information, we will inform them and any supervisory authority as required, at the
earliest
practical opportunity once we have established what was accessed and how it was accessed.
How do we apply external laws?
If you are:
- a resident of the European Union
accessing our online platforms or receiving our services in Australia; or
- accessing our online platforms or
receiving our services from within the European Union,
then in addition to our obligations under the privacy laws, we are required to comply with
the
General
Data Protection Regulation (EU) 2016.679 ("GDPR") with respect to your Personal Information.
If you are a resident of California USA, the California Consumer Privacy Act provides
California
consumers with the right to obtain information about the personal information that we
collect,
use, and
disclose. You can exercise your privacy rights by contacting us. If you choose to exercise
your privacy
rights, you have the right to not to receive discriminatory treatment or a lesser degree of
service.
We take the security and privacy of your personal information seriously and have prepared
this
Privacy
Policy and taken measures to collect, process and hold all personal information in
compliance
with
United States privacy laws and GDPR regardless of the user. Therefore, no additional terms
for
GDPR
users are required.
What happens when we make changes to this Privacy Policy?
This Privacy Policy may be updated from time to time. We will notify you of any changes by
posting the
new policy here and, where feasible, by letting you know by email.
Commission Factory Consumers
How do we use data from end users?
Commission Factory primarily uses end user data for the purpose of tracking an end user from
an
Affiliate
to an Advertiser. Tracking enables us to see that an end user has visited an Affiliate's
service, found
a product, and clicked the link to be taken to the Advertiser's service to review or
purchase
the
product.
The purpose of tracking is to attribute sales and marketing effort by an Affiliate to a
particular
transaction, to enable Advertisers to reward Affiliates on a per transaction basis. Tracking
also allows
Commission Factory to provide Affiliates and Advertisers with related reports. The majority
of
these
reports contain only aggregated statistical data.
Commission Factory doesn't know who the end user is, simply that the same end user started
their journey
with the Affiliate and completed it with the Advertiser and that the affiliate marketing
campaign was
therefore successful in respect of that end user.
By maintaining a limited user profile which does not reveal an end user's name or identity,
Commission
Factory can also understand an end user journey when it starts on one device and ends on a
different
device. Through this functionality, Commission Factory can understand whether a referral is
commenced on
one device and completed on another device. The profile is only used to attribute sales and
marketing
effort to an Affiliate, even if the end user has changed devices before completing a
transaction.
Commission Factory permits Affiliates to enquire as to whether an action by a user ought to
have
generated a commission for that Affiliate. This necessitates the sharing of information,
between
Affiliates and Advertisers. Advertisers use the information provided by Affiliates to verify
against
their own records. Commission Factory enables this data sharing and the payment of any
commission due to
the Affiliate as a result.
How do we collect data from end users?
The main technologies used for Commission Factory's tracking are Tracking Domain Cookies,
Journey Tags
and Device Fingerprinting.
Commission Factory Tracking Domain Cookies: These are cookies served by Commission Factory's
own domain
when an end user clicks on an advertisement displayed by an Affiliate. We use this
information
to
understand which end users are referred by which Affiliates to which Advertiser. Please find
some
general information on cookies here.
Advertiser Journey Tag: This is JavaScript code integrated into the Advertiser's service to
enable
Commission Factory to receive transactional information from Advertisers. Commission Factory
uses this
information to record, validate and report the completion of transactions, for the purposes
of
apportioning commissions to Affiliates.
Fingerprinting: This is a method by which Commission Factory can uniquely identify a device
by
considering certain attributes of the browser or the device (incl. screen size/resolution
and
user
configurations).
What data do we collect from end users?
We take care not to collect data that we don't need. The majority of the data Commission
Factory uses is
machine generated. It lets us single out a person, but it does not reveal who that person
is.
We do not
use this data to make predictions or evaluations of users' interest or personalities.
Commission Factory is one part of the affiliate marketing ecosystem (see our Agreement with
Advertisers
and Affiliates below) and does not always have absolute control over the personal data that
it
receives
from users, Affiliates or Advertisers.
Commission Factory stores an individual sequence of figures in respect of a transaction that
does not
reveal the name of a particular end user and contains information on the Advertiser's
campaign, the
Affiliate, the end user action (i.e. a click or a view and in which country it occurred),
and
the device
that is used.
Commission Factory also receives limited transactional information via the Journey Tag, to
confirm that a
transaction has occurred and carry out accurate commission allocating, billing and
reporting.
Such
information includes the order value, whether a voucher has been used, product type, and
sales
channel.
Commission Factory's data processing activities relating to end user data, do not require the
direct
identification of an individual and therefore Commission Factory mostly holds what is known
as
"pseudonymous" data in this respect. Pseudonymisation is privacy-enhancing. It is the
separation of data
from direct identifiers so that data can no longer be attributed to a specific individual
without the
use of additional information.
Pseudonymisation, therefore, reduces the risks associated with data processing, while also
maintaining
the data's utility.
Does Commission Factory have legitimate interest in using data?
We have carried out a balancing exercise and have identified legitimate interests as a basis
for
processing user data for the purposes set out in this section of the Privacy Policy.
When assessing Commission Factory's legitimate interest, the interests of the full affiliate
ecosystem
were considered. A balancing test was carried out and it was confirmed that tracking carries
no risk or
a very low risk of undue negative impact on the end user's interests or fundamental rights
and
freedoms.
Legitimate interests are not limited to the interests of Commission Factory but can be
legitimate
interests of a third party or to society as a whole. In the context of our service, we
consider that:
- Advertisers have an interest in
carrying on an online advertising campaign, paid for on a performance basis, whereby third-party
referrers
of customers or potential customers of the Advertiser are compensated for referrals which
generate
revenue
for the Advertiser, or which undertake another act desired by the Advertiser.
- Affiliates have an interest in
monetising their content, services or other aspects of the Affiliate website by generating
advertising
revenue which is paid on a performance basis.
- Advertisers and affiliates have an
interest in obtaining reports relevant to their respective business revenue generation.
- Commission Factory has an interest
in operating an affiliate marketing network, and to provide technology, services and reporting,
in
return
for payment from Advertisers.
- Commission Factory, Advertisers,
Affiliates and society at large have an interest in preventing fraud, misuse of services, or
money
laundering.
What is our arrangement with Affiliates and Advertisers on our network?
Commission Factory's affiliate marketing network connects Advertisers and Affiliates, so that
they can
work together to run affiliate marketing campaigns.
In running the campaign each party plays their part in pursuing the common purposes and each
party can
make certain decisions about the way data is used.
Commission Factory contractually requires that its whole network is compliant with data
protection law
and that they each fulfil their obligations to respond to requests to exercise data subject
rights. You
can approach each party, if you intend to exercise your rights in respect of the data which
that party
controls.
Commission Factory works with these Advertisers. For guidance on how to make a request to an
Affiliate or
an Advertiser, please check their respective privacy notices. For more information of how to
make a
request to Commission Factory, "What rights do you have in respect of user data" below.
For how long do we keep end user data?
We will only retain your personal information for as long as necessary to fulfil the purposes
we
collected it for, including for the purposes of satisfying any legal, accounting or
reporting
requirements.
To determine the appropriate retention period for personal data, we consider the amount,
nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or
disclosure of your
personal data, the purposes for which we process your personal data and whether we can
achieve
those
purposes through other means, and the applicable legal requirements.
As a general rule, Commission Factory retains tracking data for 5 years after collection.
What rights do you have in respect of user data?
We will honour your rights under applicable data protection laws. These rights are not
absolute, and they
do not always apply in all cases. If you wish to make a request in respect of your user
data,
as
described in this section of the Privacy Policy, please contact
privacy@commissionfactory.com
you may:
- request access to your information
and information related to our use and processing of your information;
- request the correction or deletion
of your information;
- request that we restrict our use
of your information;
- request a machine-readable copy of
your information or that your information be transferred to other IT systems;
- object to the processing of your
information for certain; and
- withdraw your consent to our use
of your information at any time where we rely on your consent to use or process that
information.
Please note that, as described under "What data do we collect from users?", Commission
Factory
mostly
holds what is known as "pseudonymous" data in respect of users. Pseudonymisation means that
we
may not
be in a position to identify the individual behind the data we hold and that we therefore
cannot provide
them with access, rectification, erasure or data portability without the provision of
additional
information (for example your IP address, or Device ID).
How do we use data to administer our business?
We process personal information for the legitimate interests of ensuring that use of our
services is
lawful and non-fraudulent, does not disrupt the operation of our services, does not harass
our
staff or
other individuals, and to enforce our legal rights and comply with our legal obligations.
Where we reasonably believe that you are or may be in breach of any of the applicable laws,
we
may use
your personal information to inform relevant third parties such as your email/internet
provider or law
enforcement agencies about the content.
With whom do we share your information?
Group members, personnel, service providers: We keep your information confidential, but
disclose it to
our group members, our personnel, suppliers or subcontractors insofar as it is reasonably
necessary for
the purposes set out in this Privacy Policy. However, this is on the basis that they do not
make
independent use of the information and have agreed to safeguard it. Activities that are
carried out by
third party service providers include: website hosting, website analytics, customer
relationship
management, email marketing, and IT support.
Third parties: We may disclose your personal information to third parties and service
providers
located
overseas in connection with any purpose, including to overseas cloud computing hosts. We
take
reasonable
steps to ensure that the overseas recipients of your personal information do not breach the
privacy
obligations relating to your personal information. We are not responsible for the privacy or
security
practices of any third party, including third parties that we are permitted to disclose an
individual's
personal information to in accordance with this Privacy Policy or any applicable laws. The
collection
and use of an individual's information by such third parties may be subject to separate
privacy and
security policies.
Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a
portion
of our
assets.
Required by law: In addition, we disclose your information to the extent that we are required
to do so by
law (e.g. to government bodies and law enforcement agencies); in connection with any legal
proceedings
or prospective legal proceedings; and in order to establish, exercise or defend our legal
rights
(including providing information to others for the purposes of fraud prevention).
Enforcement: We disclose your personal information to third parties in order to enforce or
apply the
terms of agreements, to investigate potential breaches or to protect the rights, property or
safety of
Commission Factory, our customers or others.
How do we keep your data safe?
We will take all reasonable technical and organisational precautions to prevent the loss
misuse
or
alteration of your personal information.
Please be aware that, although we endeavour to provide security for information we process
and
maintain,
no security system can prevent all potential security breaches.
How do we apply external laws?
If you are:
- a resident of the European Union
accessing our online platforms or receiving our services in Australia; or
- accessing our online platforms or
receiving our services from within the European Union,
then in addition to our obligations under the privacy laws, we are required to comply with
the
General
Data Protection Regulation (EU) 2016.679 ("GDPR") with respect to your Personal Information.
If you are a resident of California USA, the California Consumer Privacy Act provides
California
consumers with the right to obtain information about the personal information that we
collect,
use, and
disclose. You can exercise your by contacting us. If you choose to exercise your privacy
rights, you
have the right to not to receive discriminatory treatment or a lesser degree of service.
We take the security and privacy of your personal information seriously and have prepared
this
Privacy
Policy and taken measures to collect, process and hold all personal information in
compliance
with
United States privacy laws and GDPR regardless of the user. Therefore, no additional terms
for
GDPR
users are required.
What happens when we make changes to this Privacy Policy?
This Privacy Policy may be updated from time to time. We will notify you of any changes by
posting the
new policy here.
Artificial Intelligence (AI) Interaction
We employ Artificial Intelligence (AI) technologies to enhance the efficiency and
responsiveness of our
services, including but not limited to customer support functionalities. This section
outlines
how we
collect, use, share, and protect information in the context of your interactions with our AI
systems.
Data Collection through AI Interactions
- When you interact with our
AI-driven services, we may collect personal information that you voluntarily provide, such
as
your
name,
email address, and the content of your inquiries.
- Our AI systems may also gather
data regarding your usage patterns, preferences, and feedback to improve our services.
-
Use of Information
- The information collected through
AI interactions is used to provide personalized responses, improve the accuracy and
efficiency
of
our AI
systems, and enhance the overall user experience.
- Aggregated and anonymised data
from AI interactions may be used for analytical purposes to identify trends, usage patterns,
and
to inform
new features or services.
-
Information Sharing
- Information collected through AI
interactions is not shared with third parties without your explicit consent, except as
necessary
to provide
the services requested or when required by law.
- We may share anonymised or
aggregated data that cannot be used to identify you with partners or for research purposes,
adhering to
applicable laws and regulations.
-
Data Protection
- We implement robust security
measures to protect the data collected through AI interactions against unauthorised access,
alteration,
disclosure, or destruction.
- Your personal information is only
retained for as long as necessary to fulfil the purposes outlined in this policy, unless a
longer
retention
period is required or permitted by law.
-
User Rights and Choices
- You have the right to access,
correct, or delete your personal information collected through AI interactions. You may also
object to or
restrict the processing of your data.
- If you wish to exercise these
rights or have concerns about your data's privacy and security, please contact us at
privacy@commissionfactory.com.
-
Changes to the AI Interaction Clause
- We reserves the right to update or
modify this AI Interaction Clause at any time. We will notify you of any significant changes
through our
website or through direct communication.
By using our AI-driven services, you acknowledge and agree to
the terms outlined in this AI Interaction Clause. We are committed to ensuring the privacy
and
security of your
data and enhancing your experience with our innovative AI technologies.
