Surfshark Privacy Policy for Affiliates
Effective Date: August 24, 2022
Thank you for visiting the Surfshark performance marketing partner network website (the "Site"). Surfshark B.V.("we", "us", “Surfshark”) is committed to protecting the privacy of your personally identifiable information (or “personal data”). We provide this privacy policy ("Privacy Policy") in order to explain our online information practices and the choices you can make about the way your personal data is used by us. You should read this Privacy Policy thoroughly. It explains how we process your personal data, for what purposes the personal data is processed and provides other information about our privacy practices. For example, the Privacy Policy provides details on data processing when you, register an account ("Account") with the Surfshark performance marketing partner network ("Performance Marketing Partner Network") and log in to your Account as a member of the Performance Marketing Partner Network.
Privacy Policies Used in Connection with Your Subscription. When you register for an Account on the Performance Marketing Partner Network, we use a password-protected third-party portal to store your personal information, and we share your personal information with such third party ("Third Party Agent") as is necessary for the performance of your Account and the Performance Marketing Partner Network.
Personally Identifiable Information. We collect personally identifiable information when you register for an Account or otherwise choose to provide personally identifiable information to us. This may include but is not limited to: your full name, business entity name and/or your title with the applicable business entity, as well as your personal and/or business entity related e-mail address, address, ZIP code, country, state, city, telephone number, account information (or other information that we require in order to pay any amounts due to you under the Performance Marketing Partner Network), IP address, type of browser you are using (e.g., Chrome, Internet Explorer), the type of operating system you are using, (e.g., Windows or Mac OS) and the domain name of your Internet service provider (ISP)and/or any other information requested on the applicable Subscriber registration form.
Cookies and Web Beacons and Ad Identifiers. To enhance your experience with the Site, we use cookies. Cookies are small packets of data stored on your computer used to store your preferences. You may set your browser to warn you that cookies are in use, or to block the use of cookies. We use strictly necessary cookies to allow you to move around the Site and log in to your Account, and functional cookies to improve the services and support available to you. You can control whether or not functional cookies are used, though preventing them may mean some services and support will be unavailable.
We may additionally collect information using Web beacons, which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs. Web beacons are electronic images that may be used on the Site, in your Account, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon.
When you use the Performance Marketing Partner Network, cookies are set as described in the table below. In addition, we work with TUNE Inc. (“HasOffers”). This service uses cookies and pixel tags to determine when affiliates/ partner websites refer new customers to Surfshark. You can find more information about their use of cookies at :https://www.tune.com/resources/data-and-privacy/privacy-policies/.
Cookie name
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Cookie expiry
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Provenance
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Purpose
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Cookie category
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PHPSESSID
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Session
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Surfshark
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This is a general purpose identifier used to maintain user session variables. It is normally a random generated number, it is used, for example, to maintain a logged-in status for a user between pages.
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Strictly necessary
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[abcdef0123456789]{32}
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10 years
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Surfshark
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Tracks your visit to and usage on the site
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Strictly necessary
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__zlcmid
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1 year
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Third party (Zendesk)
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This Cookie is used to store the visitor’s identity across visits and the visitor’s preference to disable our live chat feature.
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Functional
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_ga
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2 years
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Third party (Google)
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It is used to distinguish users
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Analytic
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_gid
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1 day
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Third party (Google)
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It is used to distinguish users
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Analytic
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_dd_s
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1 day
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Third party (Datadog)
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Cookie from Datadog o provide web performance analytics
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Analytic
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Use of Information. We use your personally identifiable information: (a) to send you information regarding your Account and the Performance Marketing Partner Network; (b) to track your compliance with the Terms and Conditions ("Terms and Conditions"); (c) for validation, suppression, content improvement and feedback purposes; and/or (d) to perform a contract with you and manage your account. In addition, we may use your IP address for the purposes identified above, as well as to analyze trends, administer the Site, track users’ movements, gather broad demographic information for aggregate use, and to confirm that a particular individual affirmed his/her consent to specific legal terms (e.g. a clickwrap license agreement). We, or our Third Party Agent, may contact you at any time regarding your Account or the Performance Marketing Partner Network and/or any other information that we may deem appropriate for you to receive in connection with your Account on the Performance Marketing Partner Network. You may update your contact preferences as set forth below.
Information Sharing. We share your personal data with third parties only for the purposes described in this Privacy Policy. We do not sell or trade your personal data with anyone. For example, we share your information with certain third-party administrative vendors, including HasOffers, for efficiency purposes in providing administrative or program management services in connection with your Account. Further, we reserve the right to share your personally identifiable information: (a) where required by law, or requested by a court of competent jurisdiction; (b) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; (c) where you are in violation of the Terms and Conditions and/or Services Agreement; (d) in the case of a dispute; or (e) where we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.
International Transfer of Data. We may transfer information that we collect about you and your end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your end users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
Legal basis for data processing. Where we act as a controller under European data protection law, our lawful basis for collecting and using the information described in this Privacy Notice will depend on the information concerned and the specific context in which we collect or use that information. We normally collect or use information from you only where we have collected your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, when we:
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use information to create or manage an account, we need it to perform a contract with you;
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use contact information for marketing purposes, we do so with your consent (which you can revoke at any time) or we have a legitimate interest to engage in marketing activities; and
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gather usage data and analyze it to improve the Site, we do so based on our legitimate interest in safeguarding and improving the Site.
Data Retention. Subject to any mandatory obligations to delete data, your information may be retained by us and in our Third-Party Agent portal, server logs, databases and records. We will keep your information for no longer than necessary for the purposes for which it is processed, as described by our Performance Marketing Partner Network here.
Minors. We will never knowingly collect any personal information about individuals under eighteen (18) years of age. If we obtain actual knowledge that we have collected personal information about an individual under eighteen (18) years of age, that information will be immediately deleted from our database.
Security. We endeavor to safeguard and protect our Account holders' information. When Account holders submit personally identifiable information to the Performance Marketing Partner Network, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit information such as bank account information and/or credit card information (“Payment Information”), and when we transmit such Payment Information, that Payment Information is encrypted and protected. The Third-Party Agent servers that we utilize to store personally identifiable information are kept in a secure physical environment. The Third-Party Agent has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach.
Deleting and Updating Your Information. If you would like to delete or update the personally identifiable information that we have collected from you, simply email us. We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
European Economic Area (the EEA). If you are from the EEA, you have some additional rights: to receive a copy of your data, request data portability, request data erasure or data rectification, restrict/object to the processing of your data and withdraw your consent when processing is based solely on it. If you would like to exercise your rights or make any comments or suggestions, please contact us at affiliates@surfshark.com. We strongly believe that together we could solve any issues, but please note that you could also get in touch with your local data protection authority.
California. If you are from California, then you have a right to receive a copy of your data.
Opting Out of Receiving E-mail. You may at any time choose to stop receiving emails containing general information regarding Surfshark by following the instructions at the end of each such email or by contacting us. Should you be contacted by our Third-Party Agent through email, you can follow the instructions at the end of each such email to stop receiving such emails. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Account, as well as to respond to any inquiry or request made by you.
Notification of Changes. We reserve the right to change or update this Privacy Policy at any time. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes.
Contact Us. If you have any questions regarding this Privacy Policy, if you would like to exercise your rights or would like to receive more information on our privacy practices, please contact us at affiliates@surfshark.com.