01 Operator & Operational Scope
This Privacy Policy describes how personal information is collected, used, shared, and protected by [LEGAL ENTITY NAME] ("Swakly", "we", "us", or "our") when you interact with our websites at https://swakly.com/en, access our software application at https://app.swakly.com, or interact with our partner management, campaign tracking, attribution, and payout features.
This policy applies to all users who interact with Swakly, including:
- Merchants / Vendors: Businesses running partner and affiliate programs on Swakly.
- Partners / Affiliates: Individuals or entities marketing Merchant products/services.
- End Users / Shoppers: Consumers who click affiliate links or perform conversion events tracked via Swakly technology.
- Website Visitors: Individuals browsing our marketing sites and documentation.
02 Platform Roles: Data Controller vs. Data Processor
Under European data protection laws (GDPR/UK GDPR) and similar privacy regimes, the legal classification of processing activities depends on Swakly's relationship with the specific dataset:
Swakly acts as a Data Controller for direct Account Information, Billing Records, Platform Usage Logs, and Direct Marketing Communications associated with Merchants and Partners registering on app.swakly.com.
When Merchants use Swakly to operate their affiliate programs, collect tracking telemetry, log conversions, and process referral payouts, Swakly acts as a Data Processor (or "Service Provider" under CCPA) operating strictly under the instructions of the respective Merchant (the Data Controller). End Users seeking to exercise privacy rights regarding tracked orders must contact the respective Merchant directly.
03 Information We Collect
We collect information directly from you, automatically through your interaction with our service, and from third-party integrations connected to the platform.
A. Information Provided Directly
- Account Registration: Name, professional email address, password hash, company name, website URL, and time zone submitted during account setup at app.swakly.com/register.
- Profile & Onboarding: Partner vertical, promotional channels, tax identification numbers (e.g., W-9/W-8BEN metadata), preferred payout details, and contact preferences.
- Customer Support & Communications: Messages, feedback, ticket history, and survey responses submitted to our support team.
B. Information Collected Automatically
- System Telemetry & Device Info: IP address, browser type, operating system, language preferences, device orientation, and referring URL.
- Usage & Audit Logs: Access logs, feature usage, API call counts, dashboard interaction, login times, and security audit event records.
04 Affiliate Tracking, Attribution & Conversion Data
Swakly provides infrastructure for tracking affiliate referrals, computing commissions, detecting fraud, and validating conversion credit. When an End User clicks a referral link or completes an eligible transaction on a Merchant's store, Swakly processes attribution metadata.
| Data Category | Technical Attributes Processed | Primary Purpose |
|---|---|---|
| Tracking Telemetry | Click IDs, Partner IDs, Campaign IDs, Referral Parameter Strings, Timestamp | Accurate multi-touch or last-click referral attribution. |
| Conversion Events | Order ID, Transaction Value, Currency, Product SKU, Discount Codes used | Calculating accurate partner commission payouts. |
| Verification & Fraud Data | Anonymized/Hashed IP address, User-Agent string, HTTP Referrer, Geolocation (Country/City level) | Detecting self-referral fraud, click farming, bot traffic, and VPN spoofing. |
Note on IP Processing: Where IP addresses are collected during referral link redirects, Swakly utilizes IP hashing or truncation techniques to minimize personal data retention while maintaining regional attribution accuracy and security monitoring.
05 Account & Profile Management
Information collected during account creation is utilized to administer workspace accounts, enable multi-user role permissions, maintain security authentication, and issue automated platform notifications (such as commission approval updates, billing receipts, or system status alerts).
06 Payment & Financial Information
To manage Merchant subscription fees and facilitate Partner commission payouts:
- SaaS Subscription Payments: Swakly relies on external, PCI-DSS compliant third-party payment gateways. Swakly does not store complete credit card numbers, CVVs, or full payment credentials directly on its servers.
- Partner Payout Distribution: When payouts are generated, Swakly processes bank transfer metadata, PayPal payment handles, or integrated payout routing information required to execute valid transfers to Partners.
07 APIs & E-commerce Integrations
Swakly integrates with third-party e-commerce platforms, payment processors, billing systems, and custom webhooks. When a Merchant connects an integration (e.g., via OAuth or API Key):
- We process API access tokens, Webhook secret keys, store domain parameters, and order sync events necessary to maintain automated attribution pipelines.
- Data retrieved via integration APIs is strictly limited to parameters required for program tracking, commission calculation, and reporting.
08 Purpose & Legal Bases for Processing
If you reside in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, our legal bases for collecting and using your personal data depend on the specific context and purpose:
- Performance of Contract: Provisioning accounts, generating tracking links, calculating commissions, issuing payouts, and fulfilling platform functionality.
- Legitimate Interests: Monitoring platform security, detecting affiliate fraud, optimizing UI/UX performance, preventing abuse, and issuing product updates.
- Legal Obligation: Maintaining accounting, tax compliance, and anti-money laundering records.
- Consent: Placing non-essential analytical cookies or delivering direct marketing communications (where explicitly requested).
09 Cookies & Tracking Technologies
Swakly uses cookies, local storage objects, and web beacons to maintain platform security, preserve session states, analyze performance trends, and track affiliate referrals.
| Cookie Type | Necessity | Function |
|---|---|---|
| Strictly Necessary | Mandatory | Authentication sessions, security CSRF protection, and load balancer routing. |
| Attribution & Referral | Functional / Essential for Tracking | Remembers referral IDs and Click IDs across merchant store sessions to ensure proper partner credit. |
| Analytics & Performance | Optional | Aggregated user usage pattern analysis to help us improve site navigation and interface design. |
10 Information Sharing & Subprocessors
Swakly does not sell, rent, or trade personal data to third parties for monetary gain or targeted third-party advertising. Information is shared strictly under the following operational circumstances:
- Vetted Subprocessors: Cloud hosting infrastructure providers, database operators, error monitoring platforms, email delivery gateways, and payment service providers bound by strict Data Processing Agreements (DPAs).
- Merchant/Partner Relationship: Performance and identification data associated with an affiliate program is visible to the respective Merchant operating that specific program.
- Legal Requirements: Disclosures enforced by law, court orders, subpoenas, or governmental investigations.
- Corporate Restructuring: Transfers occurring as part of a merger, acquisition, asset sale, or corporate reorganization, subject to standard confidentiality protections.
11 International Data Transfers
Information processed by Swakly may be stored and processed in primary data centers located in the United States, European Union, or other global locations where our service providers operate.
When transferring data outside the EEA or UK, Swakly relies on approved data transfer mechanisms, including the European Commission’s Standard Contractual Clauses (SCCs) and UK International Data Transfer Addendums, ensuring equal data protection standards globally.
12 Security Controls & Safeguards
Swakly implements reasonable technical, administrative, and physical measures designed to protect information from loss, unauthorized access, alteration, or disclosure.
- Encryption: TLS 1.3 encryption in transit for web traffic and APIs; AES-256 encryption for data at rest.
- Access Safeguards: Multi-factor authentication (MFA) requirements, role-based access controls (RBAC), and least-privilege administrative access policies.
- Continuous Monitoring: Real-time event logging, automated threat detection, and regular vulnerability scans.
Disclaimer: While we implement rigorous safeguards, no electronic transmission over the Internet or storage environment can be guaranteed to be 100% secure.
13 Data Retention
We retain personal information for as long as necessary to fulfill the operational purposes described in this policy, maintain active user accounts, comply with legal obligations (e.g., statutory tax and reporting requirements), resolve disputes, and enforce contracts.
When personal data is no longer required, it is either securely deleted, anonymized, or isolated from further processing.
14 Your Privacy Rights (GDPR & Global Standards)
Depending on your jurisdiction, you may hold specific legal rights regarding your personal data:
- Right to Access / Portability: Request copies of the personal data held about you in a structured, standard electronic format.
- Right to Rectification: Request correction of inaccurate or incomplete personal information.
- Right to Erasure ("Right to be Forgotten"): Request deletion of your data when processing is no longer required or lacks a valid legal basis.
- Right to Restrict or Object: Restrict processing or object to processing based on legitimate interest grounds.
- Right to Withdraw Consent: Revoke consent at any time where processing relies on explicit consent.
- Supervisory Complaint: Lodge a complaint with a Data Protection Authority in your local country or state.
Account holders may manage or correct their data directly inside app.swakly.com. To submit a privacy rights request, contact us at [PRIVACY EMAIL]. Requests will be reviewed and addressed within statutory timelines.
15 California Privacy Rights (CCPA / CPRA)
Under the California Consumer Privacy Act (as amended by the California Privacy Rights Act):
- Non-Sale Declaration: Swakly does not sell personal information or share personal information for cross-context behavioral advertising within the meaning of the CCPA.
- Right to Know & Delete: California residents have the right to request specific disclosures regarding categories collected, sources, purposes, and deletion rights.
- Non-Discrimination: We will not discriminate against any user for exercising rights under California privacy legislation.
16 Children's Privacy
Swakly is an enterprise B2B SaaS platform designed exclusively for businesses and commercial partners. Our services are not directed to or intended for individuals under 18 years of age. We do not knowingly collect personal data from children.
17 Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect technological adjustments, functional platform updates, or revised legal obligations. When changes occur, the "Last Updated" date at the top of this page will be revised. Material updates will be communicated via direct email or prominent platform banners within app.swakly.com.
18 Contact & Legal Entity Details
For privacy inquiries, Data Processing Agreement requests, or regulatory questions, please reach out through the contact points below: