Privacy Notice

Last update: May 25, 2021

This notice describes how we collect and processes users’ data through (“Platform”). The terms “we”, “us”, “our” refer to Affigate OÜ, a legal person incorporated under the laws of Estonia.

We are committed to safeguarding the privacy of our users. We are not going to misuse your data.

Controller details: Affigate OÜ

Address: Harjumaa, Tallinn, Punane tn 6-219, 13619

Registry code: 16018462

Contact email address:

Please note, that this privacy notice covers our processing activities as a data controller, namely those relating to your account and information collected through the Platform.

Whenever you collect and otherwise process personal data of others via the Platform e.g., tracking clicks on your advertisements, our role is a data processor on your behalf as we rely on your instructions for processing this data. You as a data controller are responsible to process this data with applicable data protection requirements. Our obligations as data processor can be found in our data processing agreement.

This Privacy Policy does not address the practices or policies of our users, nor of any website, mobile app, or other property on which ads are displayed using the Platform. Affigate OÜ is solely a technology and tools provider and does not engage in brokering, displaying or executing any marketing campaign. Our users use the Platform to collect and process their End user personal information and data for the purpose of marketing to individuals. The collection, retention, processing and other uses of data by our users, whether or not in connection with the Platform Services, is governed by their own privacy policies and applicable laws, rules, or regulations. We do not control those user activities.

All capitalized terms not defined herein shall have the meanings set forth in the Terms of Use.

Table of contents:

  • Information we collect from you;
  • Third-party Access to Information;
  • Your rights;
  • Security of information;
  • Changes to this Notice.

Information we collect from you

Account and profile set up

If you want to use Platform functionality, you need to have a registered account.
For setting up the account of Advertising Agent we will ask you for your first name, last name, username, email address, and your contact details (type of messenger you use and your nickname there). Further, Advertising Agent is authorised to establish accounts for its managers on its own. 

For setting up the account of Affiliate we will ask you for your first name, last name, email address, username, contact detail (skype, telegram nickname), and country of residence.

For setting up the account of Advertiser we will ask you for your first name, last name, email address, username, and contact detail (skype, telegram nickname).

Without this information, we will be unable to provide Platform Services to you.

We use your account information to:

  • create and maintain your user account. The applied legal basis for this is the performance of the contract (Terms of Use) between you and us (GDPR Art. 6.1.b);
  • contact you regarding the work of the Platform or your account, including by email and sending you web notifications (GDPR Art. 6.1.b);
  • analyse the efficiency of our Platform in our legitimate interests (GDPR Art. 6.1.f);
  • upon receiving the consent from you, to send you marketing or promotional materials (GDPR Art. 6.1.a).

We will store your account data, including the categories from the below sections (Platform functionality and technical support) for as long as you have the account with us. If you become inactive, we will delete or anonymise your information 24 months after your last user session.

Platform functionality

Via the Platform, you will be able to perform different actions to use our partner marketing software solution. We will store and process the following categories of information:

  • marketing campaigns that you create, manage and participate in as well as their specification and settings;
  • information about your conversions;
  • information about Affiliates, Advertisers or Advertising Agents associated with you;
  • reports on your marketing campaigns and your collaboration with Affiliates, Advertisers or Advertising Agents;
  • number of payments needs to be settled with Affiliates, Advertisers or Advertising Agents;
  • payment information you provided for the invoice generating tool (you are able to generate invoices for the Affiliates, Advertisers or Advertising Agents directly in your profile).

The applied legal basis for this is the performance of the contract (Terms of Use) between you and us (GDPR Art. 6.1.b). We will also analyse this information as a part of our business intelligence, i.e., to track our marketing efficiency in our legitimate interests (GDPR Art. 6.1.f).

Technical support (for Advertising Agents only)

You may leave a request for support via the support form on the Platform or by email. We use this information to provide you with the help you might need, fix and improve the Platform, and analyse our efficiency in marketing and product efforts, including by creating statistics of inquiries.

The applied legal basis for this is the performance of the contract (Terms of Use) between you and us (GDPR Art. 6.1.b) and our legitimate interest to improve the Platform (GDPR Art. 6.1.f).

Logging of users and statistics activities

The following data collection activities are present on our website:

  • Collection of visitor logs (device, browser information, IP address, country of geolocation, user ID, date, time, and duration of the user session, pages viewed) to ensure fraud prevention, manage user session, debugging, and for Platform improvement purposes stored for 6 months of your last visit. The applied legal basis is our legitimate interests (GDPR Art. 6.1.f);
  • Cookies – for more information please visit our Cookie Policy;

Third-party access to information

We use the following third-party software providers:

  • analytics providers and logs aggregation & monitoring provider to analyse our efficiency;
  • errors tracking providers;
  • technical support and ticket management software;
  • cloud hosting providers to store and process collected data;
  • fraud prevention tools.

The providers listed before process personal data based on our instructions only.


When using the analytics services, we collect details of the use of the Platform, including, but not limited to traffic data, location data, length visit, and other communication data.

Non-personally identifiable information is collected and processed, among other services, by Google Analytics in an anonymised and aggregated way to improve our app’s usability and for marketing purposes. Google Analytics is a web analytics service that tracks and reports user traffic on apps and websites. Google Analytics uses the data collected to track and monitor the use of the Platform. This data may also be shared with other Google services. For more information on the privacy practices of Google, you can check its Policies at

Integrated third-party tools

The Platform allows using third-party Fraud Analytics tools. Please note, that whenever you interact with those third-party providers, you provide your information directly to them. The collection, retention, processing and other uses of data by third-party tools are governed by their own privacy policies and applicable laws, rules, or regulations.

Other disclosures

In addition to the disclosures for the purposes identified before, we may disclose information about you:

  • if we are required to do so by law, in connection with any legal proceedings or to establish, exercise or defend our legal rights; and
  • in case we sell, license or otherwise assign our company, corporate rights, the Platform or its separate parts or features to third parties.

Except as provided in this privacy notice, we will not sell, share or rent your information to third parties.

Your rights

You may exercise GDPR rights regarding your personal data. In particular, you have the right to:

  • The right to object against the processing of your information. If we process your information for our legitimate interests (e.g., for direct marketing emails or for our marketing research purposes), you can object against it. Let us know what you object against and we will consider your request. If there are no compelling interests for us to refuse to perform your request, we will stop the processing for such purposes. If we believe our compelling interests outweigh your right to privacy, we will clarify this to you.
  • The right to access your information. You have the right to know what personal data we process. As such you can obtain the disclosure of the data involved in the processing and you can obtain a copy of the information undergoing processing.
  • The right to verify your information and seek its rectification. If you find that we process inaccurate or out-of-date information, you can verify the accuracy of your information and/or ask for it to be updated or corrected;
  • Restrict the processing of your information. When you contest the accuracy of your information, believe we process it unlawfully or want to object against the processing, you have the right to temporarily stop the processing of your information to check if the processing was consistent. In this case, we will stop processing your data (other than storing it) until we are able to provide you with evidence of its lawful processing;
  • The right to have your personal data deleted. If we are not under the obligation to keep the data for legal compliance and your data is not needed in the scope of an active contract or claim, we will remove your information upon your request.
  • The right to have your personal data transferred to another organisation. Where we process your personal data on the legal basis of consent you provided us or on the necessity to perform a contract, we can make, at your request, your data available to you or to an organisation of your choosing.

You can formulate such requests or channel further questions on data protection by contacting us at

If you believe that our use of personal information violates your rights, or if you are dissatisfied with a response you received to a request you formulated to us, you have the right to lodge a complaint with the competent data protection authority of your choice.

Security of information

We will take all necessary measures to protect your information from unauthorised or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. As we use the services of third-party software providers across several countries outside of the European Union, we may transfer the collected data to those countries for further processing. In such cases, we will make sure that relevant safeguards are in place. More information on taken international safeguards can be provided upon request.

Immediate access to the data is only allowed to our authorised employees involved in maintaining the application. Such employees keep strict confidentiality and prevent unauthorised third-party access to personal information.

While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorised parties.

Changes to this notice

We may update this privacy notice from time-to-time by posting a new version on our Platform.
We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavour to provide you with an announcement about any significant changes.