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Last Revised: September 11, 2023

Related: ClickBank Privacy Notice for California Residents

Click Sales Inc. (“ClickBank,” “we,” or “us”) respects your privacy. This Privacy Policy describes the types of information we may collect from you when you visit all ClickBank-owned websites and domains and the websites and domains of our parents, and affiliates, including without limitation clickbank.com, clkbank.com, and clickbank.net; or use our mobile applications, or use our other products and services that include an authorized link to this Privacy Policy (collectively, the “Services”). This Privacy Policy describes (i) how we use the information we collect, (ii) with whom we share it, (iii) how we protect it, and (iv) the choices we offer you regarding our collection and use of such information. We are constantly working to improve our administrative, technical, and physical safeguards to protect your personal information. If you do not agree with this Privacy Policy, please do not access or use any part of the Services.

1. Information We Collect

Where We Collect It From. We may collect information about you from various sources, such as:

• Directly from you when you use the Services, such as when you register for an account, access certain features or content, or order products; and

• Our parents, affiliates, service providers, business partners, and other third parties.

What We Collect. The information we collect about you may include, without limitation:

• information that may be used, alone or in connection with other information, to identify you (collectively “personal information”);

• demographic information about you but does not specifically identify you;

• information about the devices you use to access the Services;

• dates, times, and duration of use of the Services (including whether you are a repeat or first time visitor); and

• information on actions you have taken when using the Services.

Automatic Collection. When you use the Services, we may also collect certain information by automated means, such as cookies and web beacons. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, is used to transmit information about actions of the user opening the page or email containing the beacon back to a web server. We may also use third-party analytics tools (such as Google Analytics) that collect information about use of the Services and user traffic.

Statistical Information. The information we collect automatically is statistical data and may include personal information. It helps us to improve and personalize our Services, including by enabling us to identify and authenticate users.

2. How We Respond to “Do Not Track” Signals. A "Do Not Track" signal (DNT) prevents web applications from tracking you. You can learn more about DNT at https://allaboutdnt.com.

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Services do not respond to the preferences you may have set in your web browser regarding such collection of your information, and the Services may continue to collect information in the manner described in this Privacy Policy.

3. Cookies and Other Tracking Technologies. We may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Services, such as your IP address, pages you visit, and when you view a page or open an email in which a tag is embedded. Some tracking technologies are served by third parties. These third parties may use this information to provide you with interest-based (behavioral) advertising or other targeted content and for other purposes. We do not control these third parties’ tracking technologies or how they may be used. The information practices of these third parties are governed by their own privacy policies and are not covered by this Privacy Policy. If you have any questions about an advertisement or other targeted content, you should contact the third party directly.

4. How We Use the Information We Collect. We may use information we obtain about you to:

• Process orders you place and complete other transactions you have requested using the Services, and provide you with products and services you request;

• Send you information or materials you request;

• Maintain a record of your purchases and other transactions using the Services;

• Respond to your questions and comments and provide customer support;

• Communicate with you about products, services, offers, and promotions;

• Operate, evaluate, and improve our business and the products and services we offer;

• Analyze and enhance our marketing communications and strategies;

• Analyze trends and statistics regarding use of the Services and transactions conducted using the Services;

• Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;

• Enforce our Terms of Sale and other agreements; and

• Comply with relevant legal requirements and industry standards.

Combined Information. We may combine the information we collect with publicly available information and information we receive from our parent or affiliate companies, business partners, and other third parties. We may use that combined information to enhance and personalize your experience with us, to communicate with you about products, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this Privacy Policy.

Other Uses. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

5. Disclosure of Information.
Who We Disclose To. We may disclose aggregated information about our users, and information that does not identify any individual user, without restriction.

We may disclose personal information about you:

• To contractors, service providers, and other third parties we use to support our business;

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• To enforce or apply our Terms of Sale and other agreements;

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ClickBank, users of the Services, or others;

• To third parties to market their products or services to you if you have not opted out of these promotions; and

• With your consent.

We also reserve the right to transfer your personal information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets, equity or similar transaction. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your personal information in a manner that is consistent with our Privacy Policy.

6. Data Security.We have implemented measures intended to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. Please note that the electronic transmission of information is not completely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that such measures will always be sufficient or effective. Any transmission of personal information is at your own risk.

7. Your Choices. We offer you the following choices about the information we collect from you and how we communicate with you:

CookiesMost browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the features of the Services.

Promotional CommunicationsIf you do not want us to use your contact information to promote our products or services, you can opt out by logging into your account and adjusting your user preferences in your account profile. If you have received a promotional email from us, you can also opt out of receiving future promotional emails from us by following the unsubscribe instructions contained in such email.

Web AnalyticsYou may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.

Third-Party AdvertisingIf you do not want your personal information shared with third parties for their own promotional purposes, you can opt out by:

• If you are a ClickBank client, logging into your account and adjusting your user preferences in your account profile.

• If you are a ClickBank customer, by opting out through your "frequent customer" account. If you do not have a “frequent customer” account, you can opt out by viewing your specific order number through the Site.

Your opt-out will not apply to personal information already shared with third parties prior to the date you opt out.

Third-Party TrackingAlthough we do not control third parties’ collection or use of your information to serve interest-based advertising or other targeted content, a number of these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted advertisements from members of the Network Advertising Initiative by visiting http://www.networkadvertising.org/choices.

8. Accessing and Changing Your Information. You can review and change the personal information associated with your account by:

• If you are a ClickBank client, by logging into your account and managing your personal information through your account or by sending an email request to privacy@clickbank.com.

• If you are a ClickBank customer, by sending an email request to privacy@clickbank.com.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

9. Your California Privacy Rights. California Civil Code Section § 1798.83 permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by mailing your request to 1444 S. Entertainment Ave. Suite 410, Boise, ID 83709, Attn: Privacy. For additional information regarding your privacy rights, please see our Privacy Notice for California Residents, which includes information regarding the sale and sharing of your personal information. We do not “sell” or “share” personal information as such terms are defined by any applicable privacy law.

10. Children Under the Age of 13. The Services are not directed to, and we do not knowingly collect or solicit personal information from, children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us using the email address provided below.

11. Changes to Our Privacy Policy. We reserve the right to update or change this Privacy Policy at any time. If we make a material change to our Privacy Policy, we will provide notice to you (for example, by posting on our website) that our privacy practices have changed and will provide a link to the new policy. In the event we make a material change to how we use your personal information, we will provide you with an opportunity to opt out of such new or different use. The date this Privacy Policy was last revised is at the top of this document. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

12. Data Transfers. We are based in the United States. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including in the United States, pursuant to our Data Transfer Addendum. By using the Services, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

13. Notice to EEA and UK Residents. Privacy and security are crucial in our approach to product and business development. We continuously evaluate all our practices in an effort to safeguard your personal information as effectively as possible. We comply with the General Data Protection Regulation (GDPR) and to help our users comply with GDPR to the extent GDPR so requires.

13.1. Legal Basis. Our legal basis for processing and collecting personal information varies based on the context in which it is collected. However, we will normally collect personal information only as necessary to perform a contract with you (such as when we provide the Services you request), as noted in this Privacy Policy, and otherwise with your explicit consent.

13.2. Transfers of Data. We are based in the United States and thus transfer your personal information across borders to conduct our business. We have taken appropriate safeguards to ensure your personal information is protected in accordance with this Privacy Policy through implementing additional safeguards, such as the Standard Contractual Clauses (“SCCs”). Standard Contractual Clauses (SCCs) are guidelines that govern the exchange of personal information between EU and non-EU countries. The European Commission determines whether SCCs are acceptable for data transferred internationally.

13.3. Retention of Data. We will only retain personal information for as long as it is required to provide you the Services you have requested, or as otherwise required by applicable law.

13.4. Your Rights. You may exercise the rights afforded to you under the GDPR, including the right to access, correct, update, and/or delete your personal information. You may also object to the further processing of your personal information and request portability of your personal information at any time by contacting us using the email provided below.

13.5. Consent. You may withdraw your consent that allows us to collect, store, and otherwise process your personal information, at any time. Please contact us using the email address provided below to do so.

13.6. Data Protection Authority. You have the right to complain to an applicable data protection authority. For more information, please contact your local data protection authority, contact information may be found here.

13.7. Data Privacy Framework. ClickBank complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF") and the UK Extension to the EU-U.S. DPF ("UK Extension") and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") in each case as set forth by the U.S. Department of Commerce. For the avoidance of doubt, ClickBank alone complies with the EU-U.S. DPF, UK Extension and Swiss-U.S. DPR, and not any of ClickBank's legal affiliates. ClickBank has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF, UK Estension, and Swiss-U.S. DPF with regard to the processing of personal data received from the European Union, Switzerland, and the United Kingdom in reliance on the EU-U.S. DPF, the UK Extension and Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF, UK Extension, and/or the Swiss-U.S. DPF, the Principles shall govern in each case. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If we received your information pursuant to the DPF, you have the right to opt-out of (a) disclosures of your personal information to third parties not identified at the time of collection or subsequently authorized, and (b) uses of your personal information for purposes materially different from those disclosed at the time of collection or subsequently authorized. ClickBank is responsible for the processing of personal information it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. ClickBank complies with the Principles for all onward transfers of personal data from the European Union, the United Kingdom, and Switzerland, including the onward transfer liability provisions. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. With respect to personal information received or transferred pursuant to the DPF, ClickBank is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC), or any other U.S. authorized statutory body. In compliance with the Principles, ClickBank commits to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us at privacy@clickbank.com. We will investigate and attempt to resolve complaints and disputes regarding collection, use, and disclosure of personal information in accordance with this Privacy Policy.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ClickBank commits to refer unresolved DPF complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS are provided at no cost to you.

You may initiate binding arbitration by providing us with notice pursuant to Section 14 below. The notice must contain a summary of steps taken to resolve the claim, a description of the alleged violation, and, at your choice, any supporting documents and materials and/or a discussion of law relating to the alleged claim. No representative of the U.S., EU, or any EU Member State or any other governmental authority, public authority, or enforcement authority may participate in these arbitrations. The location of the arbitration will be the United States, and the individual may choose video or telephone participation, which will be provided at no cost to the individual. In-person participation will not be required. The language of the arbitration will be English unless otherwise agreed by the parties. Upon a reasoned request, and taking into account whether the individual is represented by an attorney, interpretation at the arbitral hearing, as well as translation of arbitral materials will be provided at no cost to the individual, unless the EU-U.S. Data Privacy Framework Panel finds that, under the circumstances of the specific arbitration, this would lead to unjustified or disproportionate costs.

14. Contact Us. If you have any questions about this Privacy Policy or our information practices, please contact us by email at privacy@clickbank.com.