PARTNERLOOM PRIVACY POLICY

This Privacy Policy explains what personal and other information is collected by Dia Partners OÜ, a company registered in Estonia with number 16665931 and its registered office at Pikk 47, EE-10133 Tallinn, Estonia, doing business as Partnerloom (“Partnerloom” or “we”) as part of its activities, and how Partnerloom uses that information.

Partnerloom recognises that your privacy is very important to you and that it is your right to control your Personal Data, whether you are a Partner, a Vendor or a User. We recommend that you read this Privacy Policy in full to ensure that you are fully informed. 

To make it easier for you to review those parts of the Privacy Policy which apply to you, we have divided up this Privacy Policy into the following sections – please take the time to read Section 2 (General) and, if you are a Partner, Vendor or User, the Section which applies to you.

Section 2 – General (applicable to everyone)
Section 3 – Partners
Section 4 – Vendors
Section 5 – Users
Section 6 – US State Privacy Notice

1. Definitions used in this Agreement

In this Privacy Policy, the following expressions have the following meanings:

“Agreement” An agreement between a Partner or a Vendor and Partnerloom.

“Computer” A device used for accessing digital information including but not limited to desktops, laptops, tablets, mobile phones and other connected devices.

“Vendor” A supplier of goods and/or services to Users, or entities or individuals representing such a supplier, which may also be authorised by Partnerloom to access and use the Service under the terms of an Agreement.

“Vendor Core Tools” Partnerloom Code as used by a Vendor to enable tracking, analytics and marketing functionality.

“Optional Tools” URL Shortener, Link Generator, Analytics, Partnerloom APIs (URL Shortener API, Vendor API and Reporting AP), and such additional or alternative proprietary or third party software tools that Partnerloom may launch from time to time.

“Personal Data» Information we collect about you or your device when you visit our websites or interact with our Service, that is considered personal information or personal data as those terms are defined by applicable privacy laws.

“Partner” A person or other entity who is entitled to access and use the Service under the terms of an Agreement, or individuals representing such a person or entity.

“Partner Core Tools” Partnerloom Code, the service website, and the Link generator, either of which Partners can use to affiliate Vendor links with the purpose of earning Partner Commissions and obtaining insights via the Platform.

“Platform” Partnerloom’s proprietary, login-protected web portal that may be accessed by Partners at www.partnerloom.com to access and configure Tools, view performance and billing reports, and search for participating Vendors.

“Service” Access to and use of the Platform and the Tools.

“Partnerloom Code” Computer code which, when added to a web page or a global footer, enables the Service.

“Tools” Partner Core Tools, Optional Tools and Vendor Core Tools or, as the context requires, any of them.

“Usage Data” Data collected or created by the use of the Service, including but not limited to device type, browser-type, operating system, internet provider, your IP address, domain name, the web pages that you visit or have visited, the actions that you take on those websites, the date and time of your visits, broad geographic location (e.g. country or city-level location) and other technical information.

“User” An end-user experiencing one or more of the Tools.

“You” Anyone who interacts with our website.

2. General

This section applies to everyone who visits, or otherwise interacts, with our website.

2.1 How we keep your Personal Data secure

We implement appropriate technical and organisational measures, proportionate to the risks of processing your Personal Data. We store data on firewall-protected servers located in secure facilities, apply internal policies and controls to prevent unauthorised access or improper use, limit access to Partnerloom personnel with a business need, and run regular backups to reduce the risk of loss. We continually improve these safeguards as technology evolves. Despite these measures, no method of transmission or storage is completely secure, and we cannot guarantee absolute security; any information you transmit to us is sent at your own risk.

2.2 International data transfers

Your Personal Data may be transferred using Partnerloom’s content distribution network to, and processed in, countries other than the country in which it has been collected or in which you are resident. These countries may have data protection laws that are different to the laws of your country and, in some cases, may not be as protective.

Specifically, our website servers, our Service servers and third party service providers and partners operate in the EU and the USA. This means that when we collect your Personal Data we may process it in any part of these regions or countries. However, we have taken appropriate safeguards in all regions to require that your Personal Data will remain protected in accordance with this Privacy Policy. All our data transfers are safeguarded by applicable transfer mechanisms, such as Standard Contractual Clauses and Data Processing Agreements, where this is required by applicable data protection laws.

2.3 Your data protection rights

Depending on where you reside, you may have the following data protection rights under applicable data protect laws:

1. If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us using the contact details provided under the “Contacting Partnerloom” heading;
2. In certain circumstances, you can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Partnerloom” heading;
3. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you;
4. Similarly, if we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent,
5. You have the right to complain to a data protection authority about our collection and use of your Personal Data. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

2.4 How we use cookies on our website

A cookie is a small text file that is stored on a user’s Computer for tracking and record-keeping purposes. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies via your browser’s ‘clear cookie’ function. Please see allaboutcookies.org for more information about blocking cookies on your particular web browser.

Persistent cookies enable us to track and target your interests to enhance your experience on our website and, if applicable, the Platform. For example, we use this data to understand how you interact with our website so we can make improvements to the information and design of our website.

2.5 What Personal Data does Partnerloom collect and why?

The Personal Data that we may collect broadly falls into the following categories:

2.5.1 Information that you provide voluntarily

Certain parts of the Service may ask you to provide Personal Data voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data.

2.5.2 Information that we collect automatically

When you use the Service and/ or our website, we may collect certain information automatically from your Computer. In some countries this information may be considered Personal Data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, unique device identification numbers and Usage Data. We may also collect information about how your device has interacted with the Service and/or our website. Collecting this information enables us to better understand how the Services are used. We use this information for our internal analytics purposes and to improve the quality and relevance of the Service and/or our website for Partners, Vendors and Users. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “How we use cookies on our website” above.

In general, we will use the Personal Data we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

2.6 What we share with third parties

We may use third parties’ analytics technologies which involve cookies being dropped via our website and the collection of Usage Data, so we can understand how you use our website. We do not have access to or control over these cookies.

2.7 Who do we share your Personal Data with?

We may disclose your Personal Data to the following categories of recipients:

1. to our third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or process Personal Data for content customization, personalization, ad selection and ad delivery and reporting, measurement purposes or who otherwise process Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your Personal Data;
2. to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person;
3. to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Policy;
4. in order to enforce or apply Partnerloom’ Terms of Service, or to protect the rights, property, or safety of Partnerloom, our customers, or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction;
5. to any other person with your consent to the disclosure.

2.8 Legal basis for processing Personal Data

Our legal basis for collecting and using the Personal Data described in this Privacy Policy will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, we need the Personal Data to perform a contract with you, or the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you. If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our Services and for our commercial interests, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please let us know via privacy@partnerloom.com.

2.9 When We Act as a Data Processor for Our Partners

Our Services are designed so that we do not process Personal Data on behalf of our Partners. In some cases, however, we may incidentally receive limited Personal Data from a Partner or otherwise (for example, an email address or contact name) as part of providing the Service. When this happens, we only use that data to deliver the Service requested, protect its security, and meet any legal obligations. We also require our staff and service providers to keep that data confidential, apply appropriate security measures, and delete it when it is no longer needed unless the law requires us to keep it. Where we act as a processor for our Partners, such processing is limited to incidental Personal Data and is governed by the data processing terms set out in our Terms of Service. 

2.10 Cambios a esta Política de Privacidad

Podemos actualizar esta Política de Privacidad ocasionalmente en respuesta a cambios en las condiciones legales, técnicas o comerciales, por lo que le recomendamos que la revise con frecuencia. Cuando actualicemos nuestra Política de Privacidad, tomaremos las medidas necesarias para informarle, según la importancia de los cambios. Si realizamos cambios sustanciales en esta política, notificaremos a nuestros Socios y Proveedores mediante un aviso en la Plataforma.

2.11 Cómo contactar con Partnerloom

If you have any questions about this Privacy Policy, our practices, or your dealings with Partnerloom, you can contact us or contact our data protection officer at privacy@partnerloom.com or at the following address;

Dia Partners OÜ t/a Partnerloom
Pikk 47-9
EE-10133 Tallinn
Estonia

3. Partners

This section describes what information is collected by Partnerloom from Partners, and how that information is used by Partnerloom.

3.1 What information we collect from Partners

When a Partner signs up to use the Service, we collect and store various pieces of Personal Data, including:

1. full name of the Partner and, if different, the name of the Partner contact;
2. email address;
3. telephone number;
4. website information;
5. bank/PayPal details;
6. payment & VAT Information;
7. address.

We also collect and store information about when and how a Partner uses the Platform, including reports and other tools and interfaces provided by us. 

3.2 How we use Partner information

We use this Partner information to perform our obligations under the Agreement, including:

1. to assess the suitability of Partner’s digital presence for the Service;
2. to contact Partners to help them with registration, use and optimisation of the Service;
3. to pay Partners their share of the commissions earned through the Service;
4. to communicate with Partners on Partnerloom-related matters;
5. to provide Partners with performance and billing information;
6. to improve the service we provide to Partners based on how Partners use our service and the Tools which we provide to them;
7. to introduce Vendors who may wish to purchase services from or partner with a Partner.

Any processing of personal data is carried out in our capacity as a data controller.

3.3 Updating Partner information

Partners can edit any of their Personal Data within the Platform. It is the Partner’s responsibility:

1. to protect against unauthorised access to their details and the Platform;
2. to log-off from the Platform when not using it;
3. to keep its password secret.

3.4 What information relating to Users does Partnerloom collect?

Partnerloom will not knowingly collect or store any information which enables us to determine the actual identity of Users. The Partnerloom Group uses cookies, other automated means for data collection and web beacons to collect Usage Data relating to Users. This Usage Data is used by Partnerloom to optimize the performance and yield of the Service, to provide comprehensive reporting to Partners, and to provide reporting to Vendors and other third parties. Usage Data cannot generally be used to identify a specific person. For more information regarding cookies, please see Section 2.4 of this Privacy Policy.

The Partnerloom Group provides an opt-out mechanism for Users who do not wish for their Usage Data to be used for advertising targeting purposes, to the extent such Users are targeted through the use of a Partnerloom Group cookie.

3.5 Do Partners need to update their own privacy policies if they use Partnerloom?

It is the responsibility of the Partner to communicate to each User (whether in its privacy policy or otherwise)

1. that some links are affiliate links and commissions may be earned;
2. that Partner uses Partnerloom to manage and attribute affiliate links;
3. that Partnerloom may process device/interaction data for attribution and fraud prevention;
4. the legal basis used; and
5. a link to Partnerloom’s Privacy Policy 

3.6 What we share with third parties

We may share with certain key partners some anonymous Partner information in order to optimize our Vendor relationships and increase revenue yields for Partners. We may disclose your personal data to third parties in the event that Partnerloom identifies a Vendor with which a Partner could have a commercial relationship, to make introductions.

3.7 Data retention

We retain Personal Data we collect from the Partner for fraud prevention and regulatory compliance for as long as legally required.

4. Vendors

This section describes what information is collected by Partnerloom from Vendors, and how that information is used by Partnerloom.

4.1 What information we collect from Vendors

When a Vendor signs up to use the Service, we collect and store various pieces of Personal Data, including:

1. full name of the Vendor and, if different, the name of the Vendor contact;
2. email address;
3. telephone number;
4. website information;
5. tax ID Information;
6. address.

4.2 How we use Vendor information

We use this Vendor information to perform our obligations under the Agreement, including:

1. to assess the suitability of the Vendor for the Service;
2. to contact Vendor to help them with registration, use and optimisation of the Service;
3. to communicate with Vendors on Partnerloom-related matters;
4. to provide Vendors with order and billing history information;
5. to improve the service we provide to Vendors based on how Vendors use our service and the Tools which we provide to them;
6. to introduce Partners who may wish to enter into agreements with the Vendor.

Any processing of personal data is carried out in our capacity as a data controller.

4.3 What we share with third parties

We may disclose your personal data to third parties in the event that Partnerloom identifies a Partner with which a Vendor could have a commercial relationship, to make introductions.

4.4. Data retention

We retain Personal Data we collect from the Vendor indefinitely for fraud prevention and regulatory compliance.

5. Users

This section explains how information about Users is obtained and used by Partnerloom.

5.1 What is Partnerloom?

Partnerloom offers a service to Partners to help them potentially earn an income and gain insights from their commerce-related content. The service works by creating/tagging links within content that a User is reading which, if clicked, takes the User to a Vendor website where the products and/or services can be purchased. If the User then buys something as a result of clicking on these links, the Partner is paid a referral fee by the Vendor through Partnerloom.

5.2. What information does Partnerloom collect about Users through its technology and how does it use this information?

5.2.1 Use of Anonymized IP Address Data

We store anonymized Users’ IP addresses, from which we can determine a User’s approximate geographical location (e.g. country or region) prior to anonymizing. We need this information to optimize the links that are created/monetized to suit the geography of the User, and to provide aggregate reporting to Partners and Vendors. We also use IP addresses as part of our efforts to reduce fraud and identify non-human browsing patterns.

5.2.2 Collection and Use of User Agent Data

We store information about the User Agent that a User uses to access sites within our Partner network, such as the browser type, browser version, and type of device. This helps us ensure we can diagnose and fix browser compatibility issues more swiftly, optimize our service to suit the preferred browsing environments, provide aggregate reporting to Partners, Vendors and Advertisers, and ensure security, prevent and detect fraud, and fix errors.

5.2.3 Collection of Referrer Data

As part of the information available in standard web serving logs, we also store information about the referrer, i.e. the website page from which the User linked to Partnerloom.

5.2.4 Collection of Transaction Data

To provide Partners and Vendors with the Service, we collect information on Partnerloom visits and sales, including but not limited to order value, products bought, and order identifiers. These are used to help Partners and Vendors make better marketing and content creation decisions.

5.2.5 User Anonymity and Automated Data Collection

At no time do we know who a User is, nor do we make any attempt to try and identify a User. The Partnerloom Group uses cookies or other automated means of data collection to collect the information we need to optimize the product/Vendor links we monetize/create, and improve the service we provide to Partners, Vendors and Users.

5.3 How can I disable Partnerloom cookies?

If you no longer want the Partnerloom Group to use a cookie to target advertising to you, you can opt-out. This will mean the Partnerloom Group will not drop Partnerloom Group cookies when you browse websites in our Partner or Vendor network.

If you opt-out of Partnerloom cookies, Partnerloom will still operate on pages that you visit, and still create monetizable links in content if the Partner has chosen to install Partnerloom on its website. We just won’t optimise these links based on your preferences and behaviours, nor will we associate the websites you visit and shop from to a specific cookie.

In order for referral fees and commissions to be paid by Vendors to Partners, Partnerloom works with Affiliate Networks and other ad networks that manage the relationships between Partnerloom and the Vendors. As set out above, Users who receive Partnerloom cookies are also assigned a unique identifier number.

The affiliate and ad networks that work with Partnerloom also use their own cookies in order to track if a sale has occurred, as most of these parties will only pay Partners when a referral has been successful, i.e. a sale was completed. We do not have control over or access to these cookies.

5.4 Data retention
We retain Personal Data (in anonymized form) that we collect from you for up to three years. After that we will either delete it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

6. US State Privacy Notice

6.1 Your rights under U. State Privacy Laws

If you are a resident of a US State covered by US State Privacy Laws granting you privacy rights in relation to Personal Data (“Consumer” or “you”), this US State Privacy Notice explains how to exercise rights you may have. “US State Privacy Laws” include the California Consumer Privacy Act, the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Marketing, the Nevada Senate Bill 220, the Virginia Consumer Data Protection Act, and any similar US state law when and if such law(s) have taken effect. This Privacy Notice is intended solely for, and is applicable as to Consumers. If you are not a Consumer, this does not apply to you and you should not rely on it.

6.2 Personal Data we collect about Consumers

We may collect the following categories of information, with examples, summarized in the table below:

“Identifiers” Unique personal identifier, Internet Protocol address.

“Commercial Information” Records of purchase order value.

“Internet of other similar network activity” Information about categories of consumer interests derived from online usage, and information on a consumer’s interaction with a website, application, or advertisement.

“Geolocation Data” Internet Protocol address.

Please note that, when you interact with our Partnerloom., the information we collect above is anonymized prior to storage in our systems so that it cannot be linked to you.

In addition, we may collect Personal Data from job applicants, current or former employees, owners, directors, officers, and contractors (and emergency contacts for the foregoing), from CRM tools, and from business to business communications or transactions. The categories of Personal Data may include those listed above as well as those listed in Cal. Civ. Code § 1798.80(e) and professional or employment-related information.

6.3 Sale or Sharing of Personal Data 

We do not sell or share Personal Data (including for cross-context behavioral advertising) and have not sold or shared Personal Data in the preceding twelve (12) months, as “sell” and “share” are defined by applicable U.S. State Privacy Laws. We also do not sell or share the Personal Data of consumers under 16 years of age.

6.4 Our Purposes for Collecting and Disclosing Personal Data

Generally speaking, we collect and disclose the Personal Data that we collect for the following purposes:

1. developing new products and improving our services;
2. providing analytics regarding the effectiveness of online ad campaigns, including by reporting on the number of ads viewed and actually clicked (or swiped) on, and if the consumer purchased any items from the advertisers;
3. auditing;
4. detecting security incidents and protecting against malicious or fraudulent activity (and, if necessary, prosecuting those responsible);
5. quality control and debugging;
6. short-term and transient use;
7. internal research;
8. supporting employment, infrastructure and human resource management (e.g., processing employment applications, providing benefits to employees and dependents, managing compensation, operating facilities and infrastructure);
9. conducting business to business relationships;
10. fulfilling or meeting the reason you provided the information;
11. complying with  our legal obligations.

6.5 Your Rights and Choices

The US State Privacy Laws provide Consumers with specific rights regarding their Personal Data. This section describes your US State Privacy Laws rights and explains how to exercise those rights. You have the right not to receive discriminatory treatment by us for the exercise of such rights.

6.5.1 Right to Opt-out of the sale or sharing of your Personal Data

Consumers may opt out of the “sale” or “sharing” of their Personal Data. If you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales or sharing. You may “opt out” of our “sale” or “sharing” of your Personal Data (as those terms are defined by the US State Privacy Laws). 

6.5.2 Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), we will disclose to you the specific pieces of Personal Data that we have collected from you. However, we may withhold some Personal Data where the risk to you or our business is too great to disclose the Personal Data, or where we cannot verify your identity in relation to such Personal Data. Thus, for security purposes (and as required under US State Privacy Laws), we will verify your identity – in part by requesting certain information from you – when you request to exercise your US State Privacy Laws privacy rights.

6.5.3 Deletion Request Rights

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), and provided we have Personal Data about you, we will delete (and direct our service providers to delete) your Personal Data from our records unless an exception applies.

6.5.4 Right to Correct Inaccurate Personal Data

You have the right to request that we correct Personal Data that we maintain about you, taking into account the nature of the Personal Data and the purpose of the processing of the Personal Data. Once we receive your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), we will use commercially reasonable efforts to correct the inaccurate Personal Data, if any, as directed by you.

6.5.5 Exercising Access, Data Portability, Deletion, and Correction Rights

6.5.5.1 How to submit requests

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us by visiting partnerloom.com or via e-mail at privacy@partnerloom.com.

6.5.5.2 Who may submit requests

Solo usted, o alguien legalmente autorizado para actuar en su nombre, puede realizar una solicitud verificable de consumidor relacionada con sus Datos Personales. Puede designar a un agente autorizado para que realice una solicitud en su nombre verificando su identidad con nosotros y proporcionando una copia de la autorización escrita del agente para actuar en su nombre u otro método de validación que utilicemos para confirmar que un agente ha sido autorizado para actuar en nombre de un consumidor.

6.5.5.3 ¿Con qué frecuencia puedes enviar solicitudes?

Solo puede realizar una solicitud de consumidor verificable de acceso o portabilidad de datos dos veces dentro de un período de 12 meses

6.5.5.4 Cómo verificamos y respondemos a las solicitudes

Su solicitud debe ser verificable. Esto significa que usted o su agente autorizado deben proporcionar información suficiente que nos permita verificar razonablemente que usted es la persona sobre la que recopilamos información personal o un representante autorizado de dicha persona. Podemos verificar su solicitud:

1. Si tiene una cuenta protegida con contraseña con nosotros, podemos verificar su solicitud utilizando nuestras prácticas de autenticación existentes para esa cuenta; o
2. para solicitar conocer o eliminar Datos Personales, requiriendo que nos proporcione al menos dos puntos de datos, dependiendo del tipo de Datos Personales en cuestión.

Su solicitud verificable de consumidor también debe describirla con suficiente detalle para que podamos comprenderla, evaluarla y responderla adecuadamente. No podremos responder a su solicitud ni proporcionarle Datos Personales si no podemos verificar su identidad o autoridad para realizar la solicitud y confirmar que los Datos Personales le corresponden. Solo utilizaremos los Datos Personales proporcionados en una solicitud verificable de consumidor para verificar la identidad o autoridad del solicitante para realizar la solicitud.

6.5.5.5 Tiempo y formato de respuesta

Nos esforzamos por responder a las solicitudes verificables de los consumidores dentro de los cuarenta y cinco (45) días siguientes a su recepción. Si necesitamos más tiempo, le informaremos por escrito del motivo y del plazo de prórroga. Si tiene una cuenta con nosotros, le enviaremos nuestra respuesta por escrito a dicha cuenta. Si no tiene una cuenta con nosotros, le enviaremos nuestra respuesta por correo postal o electrónico, a su elección.

Cualquier divulgación que proporcionemos solo cubrirá el período de 12 meses anterior a la recepción de la solicitud verificable del consumidor. La respuesta que proporcionemos también explicará el motivo por el cual no podemos atender la solicitud, si corresponde. Para las solicitudes de portabilidad de datos, seleccionaremos un formato para proporcionar sus Datos Personales que sea fácilmente utilizable y le permita transmitir la información de una entidad a otra sin problemas.

No cobramos ninguna tarifa por procesar o responder a su solicitud verificable de consumidor, a menos que sea excesiva, repetitiva o manifiestamente infundada. Si determinamos que la solicitud amerita un cargo, le informaremos por qué tomamos esa decisión y le proporcionaremos un presupuesto antes de procesarla.

6.6 No discriminación

No lo discriminaremos por ejercer cualquiera de sus derechos bajo las Leyes de Privacidad de los Estados Unidos. Tiene derecho a no recibir un trato discriminatorio por nuestra parte por ejercer sus derechos de privacidad.

6.7 Otros derechos de privacidad de California

La ley «Shine the Light» de California (Código Civil, Sección § 1798.83) permite a los usuarios de nuestro sitio web residentes en California solicitar información sobre la divulgación de datos personales a terceros para fines de marketing directo. Para realizar dicha solicitud, contáctenos utilizando la información de contacto que se detalla a continuación en la sección » Contacto para obtener más información «.

6.8 Con quién contactar para obtener más información Si tiene preguntas o inquietudes sobre nuestras prácticas de privacidad, puede contactarnos o comunicarse a privacidad@partnerloom.com o a la siguiente dirección:

Dia Partners OÜ t/a Partnerloom Pikk 47 EE-10133 Tallin Estonia

Esta Política de privacidad se actualizó por última vez el  10 de agosto de 2025