Draft — needs legal review before launch.

Privacy policy

Last updated: [DATE]

Who we are

This site is run by [COMPANY NAME], [COMPANY ADDRESS] ("we", "us"). We are the controller of the personal data described here. You can reach us at [CONTACT EMAIL].

What we collect

We do not ask you to create an account or fill in forms. We collect:

• Server logs. Our hosting provider (Cloudflare) records technical data when you load a page: IP address, date and time, page requested, browser type and referring page.
• Advertising pixels, only if you accept. If you click "Accept" on our cookie banner, we load the Meta Pixel and the TikTok Pixel. They record which page you visited, that you clicked through to an offer, your IP address, browser details and identifiers stored in cookies. Meta and TikTok may link this to your account on their platforms.
• Your cookie choice. We store "accepted" or "declined" in your browser's local storage so we don't ask on every page.
• Campaign codes. If you arrived from one of our ads, the link may contain a campaign name and a click ID from Meta or TikTok. When you click through to an offer, we pass the campaign name, ad name and click ID to the advertiser's tracking link so the sale can be credited to us.

Cookies

No advertising cookies are set until you accept. If you accept, Meta and TikTok set cookies such as _fbp and _ttp. If you decline, we set none of them. You can change your mind at any time with the "Cookie choices" button at the bottom of every page.

Why we use it, and our legal basis

• Running and protecting the site (server logs): our legitimate interest in keeping the site working and secure (GDPR Art. 6(1)(f)).
• Measuring our ads (Meta and TikTok pixels): your consent (GDPR Art. 6(1)(a)). You can withdraw it at any time; this does not affect what happened before.
• Remembering your cookie choice: our legitimate interest in respecting that choice (GDPR Art. 6(1)(f)).
• Getting paid for referrals (campaign codes on outbound links): our legitimate interest in being credited for the visitors we send (GDPR Art. 6(1)(f)). [Legal review: confirm the basis for passing click IDs.]

Who we share it with

• Cloudflare, which hosts the site.
• Meta Platforms and TikTok, if you accept advertising cookies. For data collected through their pixels, they may act as joint controllers with us. Their own privacy policies apply to what they do with it.
• The advertiser or affiliate network behind an offer, when you click through to it.

We do not sell lists of visitors. Some of these companies are based in the United States, so your data may be transferred outside the EU/EEA. [Legal review: name the transfer safeguards, e.g. EU–US Data Privacy Framework or standard contractual clauses.]

How long we keep it

• Server logs: [X days].
• Pixel data: kept by Meta and TikTok under their own retention rules.
• Your cookie choice: until you clear your browser storage or change it.

Your rights

You can ask to access, correct or delete your personal data, to restrict or object to how we use it, and to receive it in a portable format. You can withdraw consent at any time. You also have the right to complain to your local data protection authority.

[Legal review: this site targets US visitors. Add any disclosures US state privacy laws require, for example a California "Do Not Sell or Share" notice, since advertising pixels may count as "sharing".]

Contact

Questions or requests: [CONTACT EMAIL], or write to [COMPANY NAME], [COMPANY ADDRESS].