Last updated: January 21, 2019
Our Privacy Commitment
We value your privacy and strive to protect it. We are committed to adhere to the principles of lawfulness, fairness, and transparency in how we collect and use your data as well as how we secure it.
You have the choice to share your personal information with or not, if you choose not to provide us your personal information, etailerhub may not be able to provide you with access to certain information, services, or products, and/or customise your use of our Platform.
We are the data controller for all personally identifiable information that we collect from you and Clickbank is one of our chosen data processors.
General Information and Terminology
Whenever you use our Website, create an account and purchase any product from our Website, we process your personal data in compliance with the General Data Protection Regulation and local privacy laws. We will not process your personal data unless we have a lawful basis for such processing.
- ‘Personal Data’ –
“Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
- ‘Processing’ –
“Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.
Personal data we collect and process
Personal Data you provide to us voluntarily
Information we collect when you create an account on our Website
When you create an account on the Platform, you are required to provide us with your full name, your email address and your profile picture.
We use this information to create your account and to enable you to login to your account. The legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We will retain your personal information for the entire duration that your account is active on our website. We will purge your personal data from our records two years after you terminate your website account.
Information we collect about our Users’ customers
We also collect certain personal information about our Users’ customers such as the Customer’s shipping address and recipient’s full name.
We also collect some non-personal information such as the store name, the delivery status, payment status of each order and MSRP.
We process the above personal information to process our Users’ customer orders. The legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We retain the above personal information and purchase history for a maximum period of three years from the time of your order. We will purge your personal data from our records after the three year period unless we are required to keep this information on other lawful grounds.
Information we collect from you when you contact us
We enable our Users to contact us through the online forms on our website as well as via email at email@example.com. We will collect your name, email address and the content of your enquiry when you send us an email or contact us through our contact form.
We process this information to respond to your enquiries/requests and to correspond with you. The legal basis for our processing of this personal data is your consent as provided in Article 6(1)(a) of the GDPR.
Data Retention Duration
We retain your personal information associated with your enquiry for a maximum period of two years from the date of last communication. We will remove all your personal data from our records after the lapse of the two year period unless we are required to keep this information on other lawful grounds.
Collection of payment information
All your payment information that you provide through our website is collected, encrypted and processed by the payment processor.
This personal information is used for processing orders. The legal basis for our processing is the performance of our contract with you in accordance with Article 6(1)(b) and legitimate interest as set out in Article 6(1)(f) of the GDPR.
Data Retention Duration
Collection of personal information from affiliate program participants
When you apply to participate in the Affiliate Program, we will collect and process the personal information that you voluntarily provide us by completing and submitting your application form.
We use this information to assess your application and where you are successful to enable you to participate in our Affiliate Program.
Data Retention Duration
We will only keep this information on our database as long as you are an active member of our Affiliate Program. We will not retain this personal information for more than two years after you cease to be a member of our Affiliate program.
Automatically collected information
We may automatically collect certain personal information about you when you use our Platform, such as your browser type, your IP address, the device you use to access our website, the pages you visit on our website, time and date of your visit. We only use this information to improve our services and your user experience. Our legal basis for the collection of this information is our legitimate interest.
In order to enhance your user experience when you access your account, we place a cookie on the computer from which you access the Website. When you revisit the website from the same device, this cookie enables us to recognise you as a previous member or as the account holder and provide you with direct access to your account without requiring you to retype any password or other member identification.
You can decline cookies from our website by clicking the decline button in the cookie banner on our website or by changing your browser settings to decline all third-party cookies.
Please note that Google analytic may collect data about your use of other websites. However, we do not use Google analytics in a way that will identify you except for your IP address.
You can stop these cookies from being stored on your computer by installing the browser plug-in available here.
The legal basis for our use of Google Analytics is our legitimate interest in accordance with Article 6(1)f of the GDPR.
We use Facebook Pixel on our Website. Facebook Pixel enables us to track user behaviour when they visit our website after clicking on our Facebook ad and to retarget ads to such users after they leave our website.
The legal basis for our use of Facebook Pixel is our legitimate interest in accordance with Article 6(1)f of the GDPR. If you do not wish for Facebook Pixel to use your data for the Facebook ads display, please contact Facebook the link provided here. Facebook is currently taking steps to ensure compliance with GDPR and is also certified under the Privacy Shield Agreement.
Sharing your data
We do not sell or rent your personal information to any third-party.
We may disclose your personal information in the following circumstance:
- If required to do so for the performance of our service;
- If we are required to do so by law;
- If such disclosure is made to protect the vital interest of a data subject or another natural person;
- To operate our affiliate program through a third-party platform;
- Your customer’s order and shipping details will be shared with our distributors to deliver the ordered products;
- Your data may also be shared with our developers and other sub-contractors we use to deliver our services to you;
- We may also be required to share certain personal data with any governmental body and regulatory authority where we are required to provide such personal information by law.
Processing and Transfer of data to third countries
The General Data Protection Regulation grants data subjects more control over their personal data and here are some of the rights that you can exercise regarding your data that we collect and process:
Your right to access your personal information
Your right to rectify your personal information
Your right to be forgotten
Your right to object to the processing of your data
Your right to withdraw your consent
To exercise any of the rights listed above, please contact us at firstname.lastname@example.org with your request.
When you subscribe to receive a newsletter on our Website, we may send you marketing material and other relevant communication by email. Our legal basis for processing your personal information is your consent which you grant us at the time of your subscription. You can choose to unsubscribe from receiving such communication from us at any time by simply clicking the unsubscribe link at the bottom of the email. Please note that when you unsubscribe from receiving communication from us, you will no longer receive marketing communication from us however we will still send you any necessary service related emails.
If you believe that our processing of your personal information is infringing on your privacy rights, we will appreciate it if you would contact us to discuss the matter first. However, if we do not respond to your requests, you do have the right to file a complaint with a supervisory authority responsible for data protection in your country of residence (if you are living in the EEA) by contacting your local Data Protection Authority here.
Security of your personal information
We take all reasonable and commercially viable steps to secure your personal information and to reduce the risk of any data breach or unauthorised access. We use access controlled servers, and only authorised personnel are allowed to access your information.
You are solely responsible for maintaining the confidentiality of your username and password and not to share this information with any other person. If you suspect that there has been a security breach, please change your password immediately and contact us.
Although we make our best efforts to protect your personal information, you understand that any transmission of data over the internet is vulnerable to hacking and similar data breaches and we are unable to offer any guarantees as to the security of your personal information.
We do not target our Website to persons under the age of thirteen years (children), and we do not knowingly collect any personal information from a person under the age of thirteen years. If you are the parent or legal guardian of a child who has provided us with his/her personal information, please immediately contact us, and we will take steps to remove such information from our records immediately.