Privacy Policy

How we use data from Advertisers and Publishers?

Providing our services

We provide our Publishers and Advertisers with an account in our network interface to access our services. You will need to register there in order to obtain access to our technologies. We will collect all data which has been provided by you (both via the interface or otherwise), this will likely include your name, (company) address, telephone number or email address.

We may collect information on the device you are using to enter our interface pages such as your IP address, operating system and browser of your device.

We will use such information for providing and/or making our services available under the terms of use of our services or in the pursuit of our legitimate interest of the proper administration of our business.

Marketing to you or your company

We use various forms of marketing to provide you with promotional materials about our services or those of advertisers and publishers operating on the network. We may process contact information that you provide to us (either via our website, through business cards, or through use of our services) for the purposes of marketing in accordance with our legitimate interests to promote our business. You can always request to be removed from the mailing lists by unsubscribing at the bottom of any marketing email.

The newsletter will be sent by means of "MailChimp", a newsletter platform. The e-mail addresses of our newsletter recipients, as well as further data described in the context of this information, are being stored on the servers of MailChimp in the USA. MailChimp uses this information to send out and evaluate the newsletters on our behalf. In addition, MailChimp can use this data to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and the presentation of the newsletter. However, MailChimp does not use the data of our email recipients to contact them independently or transfer data to other third parties.

Mailchimp's privacy policy can be found here.

Some advertisers may also use Get Response to contact publishers regarding offers and promotions. The Get Response privacy policy can be found here.

Improving and optimising usability for you and others

Our network interface uses cookies and other mechanisms, to collect analytical information to help analyse how the interface is used. We process this information to improve our understanding and to compile statistical reports regarding that activity. This information is not used by us to develop a personal profile of you.

Google will receive hashed email addresses as part of their tracking which we have implemented on awin.com. We use Google Analytics on our website for reporting of website usage. Pseudonymised data, such as your hashed email addresses, may be forwarded to Google Analytics. Please note that Awin is not responsible for the processing of your personal data by Google. If you wish to read more about how Google may process your personal data, please visit their Privacy Policy. If you wish to opt-out of Google Analytics monitoring your behaviour on our website please use this link: https://tools.google.com/dlpage/gaoptout/.

Please find some general information on cookies here. Cookies on our interface are listed here.

How do we use data to administer our business?

We process personal information for the legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

With whom do we share your information?

How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide security for information we process and maintain, no security system can prevent all potential security breaches.

For how long do we keep your data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

What rights do you have in respect of your data?

We will honour your rights under applicable data protection laws. These rights are not absolute and they do not always apply in all cases. You may:

request access to your information and information related to our use and processing of your information;
request the correction or deletion of your information;
request that we restrict our use of your information;
request a machine-readable copy of your information or that your information be transferred to other IT systems;
object to the processing of your information for certain; and
withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

Please send your requests to global-privacy@awin.com.

If you are unhappy with the way we are processing your personal data, please let us know by contacting us. If you do not agree with the way we have processed your data or responded to your concerns, you can submit a complaint to a Data Protection Supervisory Authority.

Do we transfer data outside of the EEA?

We are established in the following countries and in the course of business we may transfer personal information to other entities in our group in those countries. We also transmit your data to our subcontracted service providers, both in and out of the EU.

Where we transfer your personal information to entities in our group or service providers in countries which have not been deemed to have an adequate level of protection under an adequacy decision of the EU Commission, we have put in place specific contracts containing the EU Commission’s standard contractual clauses (the “Model Clauses”) to ensure that your personal information is treated by all parties in a way that is consistent with and which respects laws on data protection, in particular the GDPR.

If you require further information about these protective measures, please contact global-privacy@awin.com.

What happens when we make changes to this Privacy Policy?

This Privacy Policy may be updated from time to time. We will notify you of any changes by posting the new policy here and, where feasible, by letting you know by email.

How we use data from visitors of our website?

To address your enquiries

If you contact us about our services, the forms you complete or the emails you send may include information about you, such as your name, your email address and your enquiry.

In line with the legitimate interest we have in promoting and operating our business, we will process your enquiries to reply and provide you with information about the services we offer.

To send you news and updates

If you ask to be added to our mailing list, we will keep you updated with information on news by email unless you would like to be removed from that list (in which case please let us know by clicking unsubscribe at the bottom of any marketing email that you receive). The newsletter will be sent by means of "MailChimp".

MailChimp's privacy policy can be found here.

The newsletter will be sent by means of "MailChimp", a newsletter platform. The e-mail addresses of our newsletter recipients, as well as further data described in the context of this information, are being stored on the servers of MailChimp in the USA. MailChimp uses this information to send out and evaluate the newsletters on our behalf. In addition, MailChimp can use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter. However, MailChimp does not use the data of our email recipients to contact them independently or transfer data to third parties.

Social plugins

Awin participates in and markets via social networks and has implemented certain social plugins on our websites. All social media plugins are used in the pursuit of our legitimate interest of marketing our business and communicating with our business partners and the public.

Visitors wishing to avoid connecting to plugins used on our websites can install privacy-enhancing browser plugins, such as Ghostery (https://www.ghostery.com/), NoScript (https://noscript.net/) or DoNotTrackMe (https://www.abine.com/index.html).

When you enter a page on our website that contains a social network plugin, your browser or app will establish a direct connection to the social network’s servers. The information that your browser has visited the Awin page will be transmitted to the social network, even if you do not have an account with that social network or are not logged into your account. If you are logged in to your account at the same time, a page impression may be assigned to your profile there.

Our website connects to the following social networks:

Facebook, see Facebook’s Data Privacy Policy
Twitter, see Twitter’s Privacy Policy
LinkedIn, see LinkedIn's Privacy Policy
Disqus, see Disqus Privacy Policy
YouTube, see Youtube’s Privacy policy

Website Analytics

We use Google Analytics on our website for anonymous reporting of website usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our website please use this link: https://tools.google.com/dlpage/gaoptout/.

Website chat functionality

We have a live chat functionality in order to provide you with further information on Awin’s services following-up your enquiry and upon your consent. The personal data collected in the course of this chat function are the following: name, email address, website URL. We use Salesforce for this chat functionality including Sneak Peak. You may find Salesforce’s Privacy Policy here. The consent you provide for this service can be withdrawn at any time via global-livechat@awin.com.

How do we use data to administer our business?

We process personal information for the legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

With whom do we share your information?

How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide security for information we process and maintain, no security system can prevent all potential security breaches.

For how long do we keep your data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

What rights do you have in respect of your data?

We will honour your rights under applicable data protection laws. These rights are not absolute and they do not always apply in all cases. You may:

request access to your information and information related to our use and processing of your information;
request the correction or deletion of your information;
request that we restrict our use of your information;
request a machine-readable copy of your information or that your information be transferred to other IT systems;
object to the processing of your information for certain; and
withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

Please send your requests to global-privacy@awin.com.

If you are unhappy with the way we are processing your personal data, please let us know by contacting us. If you do not agree with the way we have processed your data or responded to your concerns, you can submit a complaint to a Data Protection Supervisory Authority.

Do we transfer data outside of the EEA?

We are established in the following countries and in the course of business we may transfer personal information to other entities in our group in those countries. We also transmit your data to our subcontracted service providers, both in and out of the EU.

Where we transfer your personal information to entities in our group or service providers in countries which have not been deemed to have an adequate level of protection under an adequacy decision of the EU Commission, we have put in place specific contracts containing the EU Commission’s standard contractual clauses (the “Model Clauses”) to ensure that your personal information is treated by all parties in a way that is consistent with and which respects laws on data protection, in particular the GDPR.

If you require further information about these protective measures, please contact global-privacy@awin.com.

What happens when we make changes to this Privacy Policy?

This Privacy Policy may be updated from time to time. We will notify you of any changes by posting the new policy here.

How do we use data from job applicants?

As part of any recruitment process, we collect and process personal data relating to job applicants. Such information includes:

your name, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history;
information about your current level of remuneration, including benefit entitlements

We may collect this information in a variety of ways. For example, it might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

We need to process this information to take steps at your request prior to entering into an employment contract with you. We also have a legitimate interest in processing personal information during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm an applicant’s suitability for employment and decide to whom to offer a job.

Greenhouse

On our website, we have integrated iFrames from Greenhouse, which allow website users to apply to vacancies within the Awin group. You can find further information on how our partner processes your data on their privacy policy: https://www.greenhouse.io/de/privacy-policy.

How do we use data to administer our business?

We process personal information for the legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

With whom do we share your data?

How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide security for information we process and maintain, no security system can prevent all potential security breaches.

For how long do we keep your data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As a general rule, your personal information collected as part of your recruitment process will be retained for 6 months following the notification on an unsuccessful application. In case of a successful application, your personal information will be retained as part of your personnel records and subsequent employee data retention periods will apply.

What rights do you have in respect of your data?

We will honour your rights under applicable data protection laws. These rights are not absolute and they do not always apply in all cases. You may:

request access to your information and information related to our use and processing of your information;
request the correction or deletion of your information;
request that we restrict our use of your information;
request a machine-readable copy of your information or that your information be transferred to other IT systems;
object to the processing of your information for certain; and
withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

Please send your requests to global-privacy@awin.com.

If you are unhappy with the way we are processing your personal data, please let us know by contacting us. If you do not agree with the way we have processed your data or responded to your concerns, you can submit a complaint to a Data Protection Supervisory Authority.

Do we transfer data outside of the EEA?

We are established in the following countries and in the course of business we may transfer personal information to other entities in our group in those countries. We also transmit your data to our subcontracted service providers, both in and out of the EU.

Where we transfer your personal information to entities in our group or service providers in countries which have not been deemed to have an adequate level of protection under an adequacy decision of the EU Commission, we have put in place specific contracts containing the EU Commission’s standard contractual clauses (the “Model Clauses”) to ensure that your personal information is treated by all parties in a way that is consistent with and which respects laws on data protection, in particular the GDPR.

If you require further information about these protective measures, please contact global-privacy@awin.com.

What happens when we make changes to this Privacy Policy?

This Privacy Policy may be updated from time to time. We will notify you of any changes by posting the new policy here and, where feasible, by letting you know by email.

How do we use data from end users?

Awin primarily uses end user data for the purpose of tracking an end user from a Publisher to an Advertiser. Tracking enables Awin to see that an end user has visited a Publisher's service, found a product, and clicked the link to be taken to the Advertiser's service to review or purchase the product.

The purpose of tracking is to attribute sales and marketing effort by a Publisher to a particular transaction, to enable Advertisers to reward Publishers on a per transaction basis. Tracking also allows Awin to provide Publishers and Advertisers with related reports. The majority of these reports contain only aggregated statistical data.

Awin doesn’t know who the end user is, simply that the same end user started their journey with the Publisher and completed it with the Advertiser and that the affiliate marketing campaign was therefore successful in respect of that end user.

By maintaining a limited user profile which does not reveal an end user’s name or identity, Awin can also understand an end user journey when it starts on one device, and ends on a different device. Through this functionality, Awin can understand whether a referral is commenced on one device and completed on another device. The profile is only used to attribute sales and marketing effort to a Publisher, even if the end user has changed devices before completing a transaction.

Awin permits Publishers to enquire as to whether an action by a user ought to have generated a commission for that Publisher. This necessitates the sharing of information, between Publishers and Advertisers. Advertisers use the information provided by Publishers to verify against their own records. Awin enables this data sharing and the payment of any commission due to the Publisher as a result.

How do we collect data from end users?

The main technologies used for Awin’s tracking are Tracking Domain Cookies, Journey Tags and Device Fingerprinting.

Awin Tracking Domain Cookies: These are cookies served by Awin’s own domain when an end user clicks on an advertisement displayed by a Publisher. We use this information to understand which end users are referred by which Publishers to which Advertiser. Please find some general information on cookies here. Our tracking cookies are listed here.

Advertiser Journey Tag: This is JavaScript code integrated into the Advertiser’s service to enable Awin to receive transactional information from Advertisers. Awin uses this information to record, validate and report the completion of transactions, for the purposes of apportioning commissions to Publishers.

Fingerprinting: This is a method by which Awin can uniquely identify a device by considering certain attributes of the browser or the device (incl. screen size/resolution and user configurations).

What data do we collect from end users?

We take care not to collect data that we don’t need. The majority of the data Awin uses is machine generated. It lets us single out a person but it does not reveal who that person is. We do not use this data to make predictions or evaluations of users’ interest or personalities.

Awin is one part of the affiliate marketing ecosystem (see our Agreement with Advertisers and Publishers below) and does not always have absolute control over the personal data that it receives from users, Publishers or Advertisers.

Awin stores an individual sequence of figures in respect of a transaction that does not reveal the name of a particular end user and contains information on the Advertiser’s campaign, the Publisher, the end user action (i.e. a click or a view and in which country it occurred), and the device that is used.

Awin also receives limited transactional information via the Journey Tag, to confirm that a transaction has occurred and carry out accurate commission allocating, billing and reporting. Such information includes the order value, whether a voucher has been used, product type, and sales channel.

Awin's data processing activities relating to end user data, do not require the direct identification of an individual and therefore Awin mostly holds what is known as “pseudonymous” data in this respect. Pseudonymisation is privacy-enhancing. It is the separation of data from direct identifiers so that data can no longer be attributed to a specific individual without the use of additional information. Pseudonymisation, therefore, reduces the risks associated with data processing, while also maintaining the data’s utility.

Does Awin have legitimate interest in using data?

We have carried out a balancing exercise and have identified legitimate interests as a basis for processing user data for the purposes set out in this section of the Privacy Policy.

When assessing Awin’s legitimate interest, the interests of the full affiliate ecosystem were considered. A balancing test was carried out and it was confirmed that tracking carries no risk or a very low risk of undue negative impact on the end user’s interests or fundamental rights and freedoms. Legitimate interests are not limited to the interests of Awin, but can be legitimate interests of a third party or to society as a whole. In the context of our service, we consider that:

Advertisers have an interest in carrying on an online advertising campaign, paid for on a performance basis, whereby third party referrers of customers or potential customers of the Advertiser are compensated for referrals which generate revenue for the Advertiser or which undertake another act desired by the Advertiser.
Publishers have an interest in monetising their content, services or other aspects of the Publisher website by generating advertising revenue which is paid on a performance basis.
Advertisers and publishers have an interest in obtaining reports relevant to their respective business revenue generation.
Awin has an interest in operating an affiliate marketing network, and to provide technology, services and reporting, in return for payment from Advertisers.
Awin, Advertisers, Publishers and society at large have an interest in preventing fraud, misuse of services, or money laundering.

What is our arrangement with Publishers and Advertisers on our network?

Awin's affiliate marketing network connects Advertisers and Publishers, so that they can work together to run affiliate marketing campaigns.

In running the campaign each party plays their part in pursuing the common purposes and each party can make certain decisions about the way data is used.

Awin contractually requires that its whole network is compliant with data protection law and that they each fulfil their obligations to respond to requests to exercise data subject rights. You can approach each party, if you intend to exercise your rights in respect of the data which that party controls.

Awin works with these Advertisers. For guidance on how to make a request to a Publisher or an Advertiser, please check their respective privacy notices. For more information of how to make a request to Awin, “What rights do you have in respect of user data” below.

For how long do we keep end user data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As a general rule, Awin retains tracking data for 36 months after collection.

What rights do you have in respect of user data?

We will honour your rights under applicable data protection laws. These rights are not absolute and they do not always apply in all cases. If you wish to make a request in respect of your user data, as described in this section of the Privacy Policy, please contact global-privacy@awin.com

You may:

request access to your information and information related to our use and processing of your information;
request the correction or deletion of your information;
request that we restrict our use of your information;
request a machine-readable copy of your information or that your information be transferred to other IT systems;
object to the processing of your information for certain; and
withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

Please note that, as described under “What data do we collect from users?”, Awin mostly holds what is known as “pseudonymous” data in respect of users. Pseudonymisation means that we may not be in a position to identify the individual behind the data we hold and that we therefore cannot provide them with access, rectification, erasure or data portability without the provision of additional information (for example your IP address, or Device ID).

How do we use data to administer our business?

We process personal information for the legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

With whom do we share your information?

How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide security for information we process and maintain, no security system can prevent all potential security breaches.

Do we transfer data outside of the EEA?

We are established in the following countries and in the course of business we may transfer personal information to other entities in our group in those countries. We also transmit your data to our subcontracted service providers, both in and out of the EU.

Where we transfer your personal information to entities in our group or service providers in countries which have not been deemed to have an adequate level of protection under an adequacy decision of the EU Commission, we have put in place specific contracts containing the EU Commission’s standard contractual clauses (the “Model Clauses”) to ensure that your personal information is treated by all parties in a way that is consistent with and which respects laws on data protection, in particular the GDPR.

If you require further information about these protective measures, please contact global-privacy@awin.com.

What happens when we make changes to this Privacy Policy?

This Privacy Policy may be updated from time to time. We will notify you of any changes by posting the new policy here.

What does this Privacy Policy do?

Who are we and what do we do?

Who are you and what do you want to know?

Questions?