ULUD (hereinafter - “the ULUD Platform”, “the Platform”) is a partner marketing platform providing services on the design and management of an affiliate network introduced by ULUD LTD (hereinafter – “we”, “our”, “us”, “the Company”). The Company is registered in the United Kingdom with the location of 91 Battersea Park Road, London, England, SW8 4DU, registration number: 13309068. The submitted document makes an integral part of the entire set of documents regulating the operation of the Platform.
Signing up to the Platform presupposes that the user agrees to provide reliable data about him/her.
Information is our main instrument of work. Its proper collection, processing, use, and exchange have always been our highest priority. All the actions committed by us, as by a “data processor”, with regard to the end-user data have been a result of requests from the “data controllers”. With the help of the ULUD partner marketing platform, the interested parties can evaluate their partnerships and develop successful strategies basing on the results they get.
In line with the commitment by ULUD LTD, the clients indicate those types of data that they supply and collect by means of the ULUD Platform. Data use, collection, export, or any other activity in frames of the data management is conducted under their own policies and in accordance with the applicable rules and regulations.
On the instructions of our clients, who are “data controllers”, we collect a wealth of data left by end-users to provide our clients with a better understanding of how they could increase the efficiency of their partner relations. The information we collect includes Ad ID (unique ID implemented by the advertising industry that makes it possible to track users’ activity in frames of their interaction with ads and applications such as Apple’s IDFA and Google Ad ID), GEO from IP address and/or Wi-Fi networks use (not precise), IP address, Pixel tags, Cookies.
ULUD also provides the clients with an option to share their account information both with their clients and third parties. Here, we speak about the information needed to deliver services and to provide relevant information, including name, postal and/or legal address, email, the official name of a business, website URL, User name, password, and phone number. Clients who use payment services offered by ULUD LTD have also an option to share their banking details needed to conduct the relevant financial operations.
In frames of the interaction with the ULUD Platform, clients also have an option to get access to the data provided by other third parties. They may be advertising networks and analytical partners, including publishers, advertisers, and marketing partners. Using the ULUD Platform or their own customers’ website, marketing partners may sign up with advertisers. As a result of the receipt of marketing partner information, ULUD LTD experts would have more potential to prevent fraud and to better meet the contractual requirements.
Clients possess the data that they supply and gather by means of the ULUD Platform. If data is deleted or exported from ULUD by clients, its management shall be regulated by the clients’ own practices and applicable regulations and rules. ULUD LTD is a data processor acting on behalf of their clients who are data controllers. The ULUD clients may obfuscate such data as an IP address or device ID.
The data from end-users collected by ULUD LTD on the Websites
Our platform gathers the data about your visits to the Websites. We are primarily interested in the type of device you use and the way you actually use the Websites – when you surf them to get some more information about us and our products, when you sign up for our services or when you respond to our vacancies. The purpose is to better understand how we could improve your stay with us. We mention one more time that we collect only the information that you supply by your own choice. The details we collect may be the following: the device you use, its hardware model, operating system, and browser, the IP address from where you go to the Websites, the pages you visit exactly on the Websites, the pages you go before or after the Websites.
Purposes for the collection of the stated above types of data on behalf of the ULUD Platform:
to develop and implement updates in line with the end-users’ requirements;
to conduct an analysis of the Websites use;
to perform security reviews for the further modifications in the security systems;
to deliver official, technical, warning and other communications;
to deliver marketing and promotional materials.
Pixel & Postback Tracking
The ULUD Platform provides its clients with the opportunity to customize pixel or postback tracking to gather performance marketing analytics about end-users. Pixel tracking works with the help of cookies. A cookie-file keeps the information about the session of a user on the ULUD website. When a targeted action is made, the pixel gathers this information from the browser. Postback is a mechanism that allows ULUD transferring data about a transaction from the affiliate network to the advertiser. Some clients request a server-to-server assessment, and ULUD is eager to provide them with such an option as well.
Purposes for the processing of the data from end-users on behalf of the ULUD Platform’s clients:
to assess the effectiveness of advertising campaigns by a number of parameters and further reporting on the basis of this assessment;
to assess certain marketing partners with regard to their efficiency;
to display advertising by means of the ULUD services with no personal identification;
to govern cooperation with partners;
to make payouts basing on the results of the conversions.
The Platform does not disclose personally-identifying information not published in the account, except if it is needed to follow your instructions (for example, to process payments), when the Platform has your special consent for that, when the Platform in the good faith believes that the disclosure of the information is allowed under the applicable law, or when there is a justified need, notably in the following situations:
provision of services by third parties who need the data to perform their obligations on behalf of the Platform (provided that they will protect the confidentiality of the received information);
implementation of requirements of judicial proceedings, court decisions or other cases of mandatory disclosure of information;
handling of complaints connected with the violation of rights of the third parties;
handling of requests to the support services;
protection of rights and property of the Platform and its users;
transfer of the assets of ULUD LTD
Retention & Deletion of Data
Personal data of the subject shall be deleted or blocked as soon as the purpose for their retention ceases to exist. The data retention may continue if it is provided for by the European or national law in frames of the orders, laws or other regulations on the personal data operator’s activity. Block and deletion of the data are carried out when the period of data retention stipulated by the specified regulations expires except for the cases when there is a need for further data retention with the purpose to conclude the agreement or to perform the obligations under it.
Rights of the Subjects of the Personal Data
In case of processing of your personal data you become the subject of the personal data in the meaning provided for by GDPR and obtain the following rights in relation to the data processor:
Right to access the data. You may demand from the data processor a confirmation of the fact that we do process your personal data. You can submit to us such a request in no particular format at [email protected]. If such processing takes place, you may demand from the processor to provide you with the report on the following types of information: purposes, types of the data, data receivers, data retention period, data origin, the existence of automated process on the decision making, including profiling.
Right to submit corrections. You have the right to demand from the processor to make corrections and/or additions if the personal data related to you are incorrect or incomplete. The data processor shall make the relevant amendments immediately.
Right to limit the processing. You may demand to limit the processing of the personal data if the processing of such data is unauthorized and you reject to delete the data demanding limitation of its use instead of deletion; if the data processor no longer needs the data but you need it to address legal claims or if you have submitted objection to the processing of the personal data in accordance with Clause 1 Article 21 of GDPR.
Right to remove the data. You may demand from the data processor to immediately remove your personal data and the data processor shall immediately do so if there are the following grounds: the data is no longer needed for the purposes it has been collected, you withdraw your consent for the processing, you express your objection to processing your data, the processing has been unauthorized.
Right to data portability. You have the right to transfer your personal data from one data processor to another.
Right to submit an objection. At the presence of certain conditions, you have the right to submit an objection to the processing of your personal data at any time that is processed on the basis of Clause 1(e) and Clause 1 (f) of Article 6 of GDPR. The same is for the profiling carried out on the basis of these provisions.
Right to withdraw your consent for the processing of your personal data. You have the right at any time to withdraw your consent for the processing of the personal data. The withdrawal of the consent shall not influence the legitimacy of the processing made on the basis of such consent before the withdrawal.
Legal Basis for the Procession of the Personal Data
In case we receive the consent from the subject of the personal data to carry out procedures on the processing of such data, Clause 1(a) of Article 6 of GDPR shall be the legal basis for that.
If the processing of the personal data is needed to perform the obligations under the agreement, the party to which the subject of the personal data is, Clause 1(b) of Article 6 of GDPR shall be the legal basis for that. The same provision applies to the procedures occurring before the conclusion of the agreement.
If the processing of the personal data is needed to perform the legal obligation the Platform bears, Clause 1(c) of Article 6 of GDPR shall be the legal basis for that.
If the need to process the personal data is caused by vital interests of the subject of the personal data or another physical person, Clause 1(d) of Article 6 of GDPR shall be the legal basis for that.
If the processing of the personal data is needed with the view to respecting the legal interests of the Platform or of the third party and if the interests, fundamental rights and freedoms of the subject of the personal data have no higher legal rank over the interest stated above, Clause 1(f) of Article 6 of GDPR shall be the legal basis for the processing.
For further information on how ULUD LTD complies with GDPR.
End-User Personal Settings
You can block cookies at any time, by deleting the cookie-files that were installed by the Website. This can be done via browser settings, deletion of cash, history file and cookie-files. An end-user can block Ad Identifiers collection by changing settings on their devices. It can be also reset using privacy settings.
Our Platform gathers personal data on behalf of clients and plays the role of an intermediary between the businesses and the end-users. We kindly ask you to review the relevant privacy policies of our third-party partners: Google Analytics, SalesForce, Marketo, Pendo, NetSuite by Oracle, Intercom, Zendesk, LiveChat, TransferWise, and Inspectlet.
Flash Cookies and HTML5 Opt-Out
The Platform and its third-party partners use HTML5. Moreover, the partners to the Platform may use flash cookies. The purpose is to serve advertising based on your activity in the browser as well as to store the content information and your preferences. Each browser offers its own instructions for blocking HTML5. You will find them in your browser settings.ULUD participates in the Google Third-Party Serving Compatibility Program. Clients wishing to advertise with Google must comply with Google’s Third-Party Ad Serving Policy.