Refersion™ Privacy Policy


SHORT VERSION

Here at Refersion, we take privacy seriously.

The Categories of personal data that we process depends on how you use our services. We use your personal data to provide our online services in alignment with your preferences, to process your requests, to contact you regarding our products and services which may be of interest to you, or to carry out our relevant administrative services. All personal data is processed in accordance with applicable data protection laws.

We only disclose your personal data to third parties that assist us with providing you with our services and, if you authorize us explicitly, to our affiliated companies for the purpose of customer relationship management, analytics and marketing.

With your consent we also use cookies to personalize your experience and track sales.

As our valued customer, we also offer you various choices to control how your personal data is used. If you would like more information about the processing of your personal data by us and on the cookies that we use, see below the full version of our Privacy Policy.


FULL VERSION

We here at Refersion are committed to safeguarding your privacy rights and ensuring that your personal data is protected.

This Privacy Policy explains the types of personal data we collect and how we process and protect that data in connection with the services we offer. This includes information collected both offline and online through our websites, including www.refersion.com, and those domains directly associated with any of them, and all related services, applications, components, programs, software, listings, directories, tools, message boards, databases, usernames, passwords, and information offered by Refersion and made available and utilized through each of the foregoing (“Site”).

This Privacy Policy applies to the use of the Site and governs data collection and usage, whether the Site accessed via computer, mobile device or otherwise. For the purposes of this Privacy Policy, unless otherwise noted, all references to Refersion include the Site and Refersion.

The Site includes a cloud platform that tracks sales from referrals made by merchants’ affiliates. By registering to use our Site and by continuing to use our Site, you are consenting to the terms of this Privacy Policy and acknowledge that information you provide to us through the Site will be subject to our information practices disclosed herein. If you do not agree to be bound by this Privacy Policy, you should not use our Site.


Privacy Policy Navigation:

Who is responsible for what happens with your data?

What is Personal Data and what do we collect?

What do we do with your Personal Data?

Who do we share your Personal Data with?

Our use of Cookies

To which countries do we transfer your Personal Data?

How long do we process your Personal Data?

What are your rights?

Can you withdraw your consent to the processing of Personal Data?

Security of Your Personal Information

Children

Third Party Websites

Changes to this Privacy Policy

Information for California residents

Contact Information


1. Who is responsible for what happens with your data?

The website is owned or controlled by Refersion Inc. (“Refersion,” “we,” “our” or “us”). We are responsible for processing your personal data on our Site. This Privacy Policy will service to assist you in making an informed decision about how you will use our Site. References to "you" in this Privacy Policy means you, your duly authorized representatives and any entity you may represent in connection with your use of the Site.


2. What is Personal Data and what do we collect?

Personal Data means information that can directly or indirectly identify you (“Personal Data”).

Refersion collects personally identifiable information that you provide to us in the course of registration or otherwise, such as your name, e-mail addresses, telephone and fax numbers, home or work addresses, birth date or gender, unique identifiers such as username, account number or password, payment and account information, preference information such as order history or marketing preferences and similar information. We may gather additional personal or non-personal information in the future.

Sometimes, we combine personally identifiable information you provide with information about you from third-party sources. For example, we may confirm your address with the postal service or verify your personal information with a credit-reporting agency. We will treat the combined information in accordance with the terms of this Privacy Policy.

We also collect information other than personally identifiable information that does not reveal your identity or directly relate to a person. We may collect the following information from you:

  • Information about you or your business such as company name, company size, or business type;
  • Demographic information, such as age, gender, interests and ZIP code; and
  • Information about your computer or mobile device.
  • Information about your computer or mobile device hardware and software may be automatically collected by Refersion. This information can include: your IP address, browser type, domain names, access times, referring website addresses, device identifiers, operating system, or information gained from cookies, pixels or other tracking technologies. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Refersion website.

3. What do we do with your Personal Data?

Refersion collects and uses your personal information to operate its Site and deliver the services you have requested. In particular, we may use such information as follows:

Context

Types of Data

Primary Purpose for Collection and Use of Data

Account Registration

We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.

We have a legitimate interest in providing account related functionalities to our users. Accounts can be used to save your preferences and transaction history, conduct online transactions, and secure your personally identifiable information.

Client Information

We collect the name, and contact information, of our clients, including merchants and their employees, as well as affiliates, with whom we may interact.

We use this information to perform our contractual obligations with our clients and communicate with them concerning normal business administration such as projects, services, and billing.

Cookies and first party tracking

We use cookies and other tracking mechanisms. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.

We have a legitimate interest in making our website operate efficiently.

Cookies and Third Party Tracking

We participate in behavior-based advertising, this means that a third party uses technology (e.g.,a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policyfor more information.

We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.

Demographic Information

We collect personal information, such as your age or location.

We have a legitimate interest in understanding our users and providing tailored services.

Feedback/Support

If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.

We use this information to perform our contract and act upon your feedback or issues regarding the services we provide to you. We also have a legitimate interest in receiving, and acting upon, your non-service related feedback or issues.

Mailing List

When you sign up for one of our mailing lists we collect your email address or postal address.

We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Operational Information

We collect your name, billing address, shipping address, e-mail address, phone number, and credit card number when you utilize our services.

We use information collected from merchants, affiliates, and merchant’s customers to perform our contract to provide you with services and to send you important information about your subscription such as changes to terms, conditions, and policies and/or other administrative information. We use your information in connection with the tracking of your merchant affiliate transactions.

Partner Promotion

We may collect information that you provide as part of a co-branded promotion with another company.

We have a legitimate interest in fulfilling our promotions.

Social Media

We may collect information that you provide on our social media pages and combine this information with information we already have.

We have a legitimate interest in verifying your identity and account status when you contact us through our social media pages.

Surveys

When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in understanding your opinions of current services or of potential new services that may be offered.

Website interactions

We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

Web logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.


In certain instances, we only process your Personal Data if you have given us permission to do so, for example in most cases where we process your Personal Data for marketing purposes, use cookies or location data or where we process your sensitive personal information. In other instances, we may rely on other legal grounds for processing your personal data, such as performance of the contract with you or legitimate interests, like fraud prevention.

Where we process your Personal Data on the basis of your consent, we will ask for your consent explicitly and only for a particular purpose. We will also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Privacy Policy.


4. Who do we share your Personal Data with?

Refersion may share data with its business partners, vendors and service providers for various tasks related to the provision of our services, including to help perform statistical analysis, send you email or postal mail, or provide customer support. All such third parties are prohibited from using your personal information except to provide services to Refersion, and they are directed to maintain the confidentiality of your information.

Refersion may share your personal information if it is involved in a merger, acquisition, or sale of all or a portion of its assets, including during the negotiation stage. You will be notified by email and/or by a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices you have regarding your personally identifiable information.

Refersion will otherwise disclose your personally identifiable information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the statutory, administrative or other legal requirements or comply with legal process served on Refersion or the Site; (b) protect and defend the rights or property of Refersion; and, (c) act under exigent circumstances to protect the personal safety of users of Refersion, or the public, investigate fraud or respond to a government request.

Refersion does not sell, rent or lease your personal data with third parties. If we plan to disclose your personally identifiable information to a third party for a reason not mentioned in this Privacy Policy, we will obtain your consent first.


5. Our use of Cookies

We use cookies and similar technologies (“Cookies”) to help better personalize your online experience and track sales. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on the Site, or register with the Site or Refersion services, a cookie helps Refersion to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to our Site, the information you previously provided can be retrieved, so you can easily use the Refersion features that you customized.

You have the ability to accept or decline our use of cookies. If you consent to our use of cookies, but want to adjust that preference, you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Refersion services or websites you visit. Please note that we do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.


6. To which countries do we transfer your Personal Data?

Refersion is a U.S. based company and we store information we collect from you via our website on servers located in the United States. We may also handle your data in order to process it for a third party that is not located in the United States. Therefore, your information may be transferred to and stored in other countries outside of the jurisdiction you are in. Any international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this privacy policy.


7. How long do we process your Personal Data?

Refersion will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, terms of service, terms of use and other policies.

Note that, as required by law, we will require you to prove your identity. We may conduct an identity verification by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

Authorized Agent

You may use an authorized agent to submit a request to access your information, delete your information, or opt out of the sale of your information. To designate an agent for these purposes:

  1. You must provide us with a copy of a written and signed permission given to your authorized agent; and
  2. You must verify your own identity directly with us.

8. What are your rights?

Depending on your jurisdiction, you may have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

  • (i) confirmation of whether, and where, we are processing your personal information;
  • (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  • (iii) information about the categories of recipients with whom we may share your personal information; and
  • (iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you are a resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.

If you wish to exercise one of these rights, please contact us at [email protected].

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.


9. Can you withdraw your consent to the processing of Personal Data?

Where your consent is the legal basis for the processing of your Personal Data, you can withdraw your consent for:

  • Marketing communications: by using the unsubscribe link in any of our marketing communications.
  • Use of Cookies: via your web browser.

Please note that withdrawing your consent will not affect the lawfulness of the processing before the withdrawal.


10. Security of Your Personal Information

Refersion maintains appropriate technical and organizational measures to protect your personally identifiable information submitted to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data. This takes place both during transmission and once it is received. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. If you have any questions about the security of your personal information, you can contact us at [email protected].

In particular, the Site is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to the Site as safe as reasonably possible. Refersion uses regular malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/financial information you supply is encrypted via Secure Socket Layer (SSL) technology provided by Comodo. To secure your personal information from unauthorized access, use or disclosure, Refersion also uses the SSL services of Amazon and Cloudflare.

You are responsible for keeping your password for certain of the Site confidential and secret. Anyone given your password will have the ability to edit your user settings at any time. As such and for other important security reasons, we urge you to keep your password secure and safe at all times if you are assigned or create one. By using our Site, you acknowledge that you and you alone are responsible for the security of your username and password if you are assigned or create one.


11. Children

The Site is intended for adults and as such we do not expect children under the age of sixteen (16) to be accessing this website or our services. Refersion does not knowingly collect personally identifiable information from children under the age of 16. The Site is not directed to individuals under the age of sixteen (16), and we request that such individuals do not provide personally identifiable information through the Site. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information.

We do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization.


12. Third Party Websites

In connection with our tracking and other services, you will be able to connect your Refersion account to third party accounts. BY CONNECTING YOUR REFERSION ACCOUNT TO YOUR THIRD PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THE THIS FEATURE.

You may disconnect your account from a third party account at any time. Users may learn how to disconnect their accounts from third-party websites by accessing their account settings.

In addition, our Privacy Policy addresses only our practices with respect to information we collect about you in the course of using our Site and does not apply to information about you that might be collected by a third party website or an offering linked to or otherwise accessible from our Site or offline by Refersion (unless specifically stated). Any information collected, obtained and/or used by any such third parties is subject to the privacy policies of those third parties. This Privacy Policy explains Refersion’s information practices at the Site, such as the types of information we collect regarding visitors to the Site and how we use that information. Please review this Privacy Policy carefully. In addition, please review the Site’s Terms of Service which govern your use of the Site.

Refersion encourages you to review the privacy statements of websites you choose to link to from Refersion so that you can understand how those websites collect, use and share your information. Refersion is not responsible for the privacy statements or other content on websites outside of the Site.


13. Changes to this Privacy Policy

Refersion will occasionally update this Privacy Policy to reflect company and customer feedback. Refersion encourages you to periodically review this Privacy Policy to be informed of how Refersion is protecting your information. If we make changes, we will revise the “Last Revised” date at the bottom of this page. Any changes will become effective when we post the revised Privacy Policy. If we make any material changes we will notify you by means of a notice on the Site prior to the change becoming effective.

This Privacy Policy is subject to our Terms of Service with respect to governing law, venue, dispute resolution, limitation of damages and intellectual property ownership.


14. Information for California residents

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.


Contact Information

Refersion welcomes your questions or comments regarding this Privacy Policy. You may contact us at:

  • Refersion Inc.
  • 242 West 38th St.
  • Floor 10
  • New York, New York 10018

  • Email Address:
    [email protected]


Updated and effective on June 15th, 2020