Affiliate Program Privacy Policy

3. What Personal Data We Collect

We collect Personal Data from different sources depending on how you interact with the Affiliate Program.

Data Affiliates Provide to Us

• Identity and contact Details: name, business name, website or social channels, email address, phone number, country, and preferred language.

• Account and Program Details: username, Affiliate ID, Tracking Link information, program status, and preferences.

• Payment and Financial Details: Payout method, bank account or payout account details, currency, and payment history.

• Tax and invoicing information (where applicable): Tax ID, VAT details, invoicing preferences, and related records as required for accounting and payment.

• Verification and Compliance Details: If necessary, information needed to verify identity, prevent fraud, or meet legal requirements.

• Audit and Admin Information: Internal notes, approval status, and logs of key account actions

Data Collected Automatically Through Affiliate Tracking

When someone clicks a Tracking Link or interacts with tracking technology connected to the Affiliate Program, we (and our tracking platform) may collect:

• Referral and Click Identifiers: name, business name, website or social channels, email address, phone number, country, and preferred language.

• Account and Program Details: username, Affiliate ID, Tracking Link information, program status, and preferences.

• Payment and Financial Details: Payout method, bank account or payout account details, currency, and payment history.

• Tax and invoicing information (where applicable): Tax ID, VAT details, invoicing preferences, and related records as required for accounting and payment.

• Verification and Compliance Details: If necessary, information needed to verify identity, prevent fraud, or meet legal requirements.

• Audit and Admin Information: Internal notes, approval status, and logs of key account actions

Communications Data

If you contact us about the Affiliate Program, we may collect:

• Emails, messages, chat transcripts, and support tickets

• Call notes where applicable

• Attachments you send to us

Compliance and Recordkeeping Data

Depending on our setup and legal obligations, we may collect:

• We may collect KYC and verification information where required, such as identity and business verification details and, where relevant, beneficial ownership information, to help us meet legal and compliance obligations and to process Commission payouts.

• Sanctions and restricted party screening results if required: We may perform sanctions and restricted party screening where required by applicable law, requested by our banking partners, or necessary to process Commission payouts.

• Accounting and payment records, including confirmations from payment providers: Our banking partners and any payment service providers we use to pay Commissions to Affiliates (such as for bank transfers and international payouts). The data shared typically includes the Affiliate’s name, payout details, payment amount, currency, and payment reference information.

• Security and access logs related to Affiliate Program systems

4. Cookies and Similar Technologies Used for Affiliate Tracking

Affiliate tracking commonly relies on Cookies and similar technologies to remember that a visitor arrived via a Tracking Link and to help attribute a later Conversion.

We use Post Affiliate Pro to support affiliate tracking and reporting. Depending on configuration, tracking may involve:

• Cookies or local storage style identifiers placed on the visitor’s device after a click on a Tracking Link

• Tracking scripts or tags that record referral events and conversion events on relevant pages

• Pixel based events that signal a conversion event

• Server to server notifications (sometimes called postback) if configured, which can attribute conversions using referral identifiers without relying only on browser storage

The exact technologies used can vary based on our implementation, device settings, browser restrictions, and user cookie choices.

How You can Control Cookies

You can control Cookies in several ways:

• Use browser settings to block or delete Cookies

• Use private browsing modes, noting they may limit tracking persistence

• Adjust device level advertising or tracking settings where available

If you disable Cookies, some Affiliate Program tracking and reporting may not work as intended.

5. Sharing and Disclosures

We share Personal Data only where needed for the purposes described above, and only with appropriate safeguards.

Categories of recipients may include:

• Post Affiliate Pro and related service providers that operate the tracking and reporting platform

• Hosting and infrastructure providers used to run compensky.com and related services

• Analytics and measurement providers used to understand performance, where enabled and lawful

• Payment processors and banks involved in paying Commissions: Our banking partners and any payment service providers we use to pay Commissions to Affiliates (for example, for bank transfers and international payouts). The data shared typically includes the Affiliate’s name, payout details, payment amount, currency, and payment reference information.

• Professional advisors such as lawyers, accountants, and auditors, under confidentiality obligations

• Authorities and regulators where required by law or where necessary to protect rights, safety, and security

• Business transfers: If we undergo a merger, acquisition, restructuring, or sale, Personal Data may be shared as part of that process, subject to applicable law

What Affiliates can See

Affiliates can access their own Dashboard data. An Affiliate does not receive access to other Affiliates’ Personal Data or detailed information about individual Referred Users beyond what is necessary for performance reporting. Reporting typically uses aggregated metrics and identifiers relevant to attribution.

6. International Transfers

Your Personal Data may be processed in countries outside the country where you live, depending on where our service providers operate and where our systems are hosted.

Where cross border transfers apply, we use appropriate safeguards, such as: the European Commission Standard Contractual Clauses, and where applicable, adequacy decisions and other lawful safeguards recognised under data protection law. Relevant locations may include: Türkiye, the European Economic Area, the United Kingdom, and the United States, depending on where our service providers and infrastructure are located.

7. Data Retention

We keep Personal Data only for as long as needed for the purposes described in this policy, unless a longer period is required by law.

Examples of retention logic:

• Affiliate account records: Kept while the account is active, and for a period after closure to handle disputes, audits, and recordkeeping

• Commission and accounting records: Kept for statutory accounting and tax retention periods

• Support communications: Kept for a reasonable period to manage ongoing support and improve service quality

• Security logs: Kept for a limited time appropriate for security monitoring and investigation

8. Security Measures

We use a mix of organisational and technical measures designed to protect Personal Data, including:

• Access controls and role based permissions

• Least privilege access for staff and service accounts

• Encryption in transit, and encryption at rest where appropriate

• Monitoring and logging of system activity

• Backups and recovery procedures

• Staff training and confidentiality obligations

• Incident response processes and escalation procedures

No system is completely secure, but we work to reduce risk and improve our controls over time.

9. Rights and Choices

Depending on your location and the laws that apply, you may have rights regarding your Personal Data, including:

• Access to your Personal Data

• Correction of inaccurate or incomplete data

• Deletion of Personal Data in certain situations

• Restriction of processing in certain situations

• Data portability where applicable

• Objection to processing based on legitimate interests

• Withdrawal of consent where processing relies on consent (for example, certain Cookies)

• The right to complain to a data protection authority or regulator

How to Make a Request

To submit a privacy request, email us at: privacy@compensky.com

To protect you and others, we may ask for verification before we respond. This may include confirming access to the Affiliate account email address, requesting additional information to confirm identity, or asking questions to clarify the request. We will respond within the timeframes required by applicable law.

10. Affiliate Obligations

Affiliates have their own responsibilities when promoting Compensky. In particular, Affiliates must:

• Follow applicable privacy, electronic communications, and marketing laws (for example, rules about email marketing, tracking technologies, and targeted advertising)

• Provide clear notices to their audiences about how they collect and use Personal Data on their own websites, apps, and channels

• Disclose the affiliate relationship where required by law, platform rules, or advertising standards

• Not use unlawful tracking methods, hidden redirects, unauthorised Cookies, fingerprinting that violates applicable rules, or similar practices

• Not scrape, harvest, or buy contact lists in ways that violate privacy laws

• Not send spam or misleading messages that could cause unauthorised or unfair processing of Personal Data

• Use Tracking Links only as permitted by the Affiliate Program terms

Affiliates act as independent Controllers for Personal Data they collect in their own marketing activities.

11. Children

The Affiliate Program is intended for adults and business partners. We do not knowingly collect Personal Data from children in connection with the Affiliate Program. If you believe a child has provided Personal Data to us, contact us at privacy@compensky.com

12. Changes to this Policy

We may update this policy from time to time. We will post the updated version on this page and update the effective date at the top. If changes are significant, we may also provide additional notice through the Affiliate Dashboard or by email, depending on our setup and legal requirements.