commissionzen.com

Privacy Policy

Please identify yourself and specify the information you seek. Commission Zen (“Commission Zen”, “Us”, “We”, “Our”, “CZEN ltd”) specializes in performance marketing software that provides online retailers, agencies, and affiliates with real- time insights into the performance of their affiliate marketing campaigns. Our goal is to facilitate your access to the information that is most pertinent to you. To assist you, please refer to the relevant section in the table below or select the appropriate category: You are an Advertiser or Affiliate within the Commission Zen Network. You are a Website Visitor on the Commission Zen website. You are seeking employment with Commission Zen. You are an end user (or consumer) utilizing services from Affiliates or Advertisers on the Commission Zen Network. Do you have any questions? 

Questions? 

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us by using following details: 

U.S 

ADDRESS: 4821 Winchester Blvd, Ste 102 Frederick, MD 21703 

PHONE NUMBER: +13023022280 

U.K 

ADDRESS: OFFICE 5195 182-184 HIGH STREET NORTH LONDON E6 2JA 

PHONE NUMBER: +442035751430 

Advertisers and Affiliates 

Utilization of Data from Advertisers and Affiliates 

Delivery of Services 

We offer our Affiliates and Advertisers an account within our network interface to facilitate access to our services. Registration is required to gain entry to our technologies. We will gather all data submitted by you, whether through the interface or other means, which may include your name, (company) address, telephone number, or email address. Additionally, we may collect information regarding the device you utilize to access our interface, such as your IP address, operating system, and browser type. This information will be employed to deliver and/or enhance our services in accordance with the terms of use or to further our legitimate interest in the effective management of our business. 

Promoting Services to You or Your Organization 

We employ a variety of marketing strategies to deliver promotional content regarding our services, as well as those of our advertisers and affiliates within the network. We may utilize the contact information you provide (whether through our website, business cards, or your engagement with our services) for marketing purposes, in alignment with our legitimate interests to advance our business objectives. You have the option to opt out of our mailing lists at any time by unsubscribing via the link at the bottom of any marketing email or by reaching out to us directly. 

Enhancing Usability 

Our network interface utilizes cookies and other tools to gather analytical data that assists in understanding how the interface is utilized. We analyze this information to enhance our insights and generate statistical reports concerning user activity. 

This data is not employed to create a personal profile of you.  

Usage of data to administer our business 

We handle personal information to uphold our legitimate interests, ensuring that the use of our services remains lawful and free from fraud, does not interfere with the functionality of our services, does not cause harassment to our staff or other individuals, and allows us to assert our legal rights while fulfilling our legal responsibilities. In instances where we have reasonable grounds to believe that you may be violating applicable laws, we may utilize your personal information to notify relevant third parties, such as your email or internet service provider, or law enforcement authorities regarding the matter. 

Information Confidentiality 

We maintain the confidentiality of your information but may disclose it to our group members, employees, suppliers, or subcontractors as necessary for the purposes outlined in this Privacy Policy. This disclosure is contingent upon their agreement to protect the information and refrain from using it independently. 

Activities performed by third-party service providers include website hosting, analytics, customer relationship management, email marketing, and IT support. 

External/Third Parties: 

We may share your personal information with third parties and service providers located internationally for various purposes, including with overseas cloud computing providers. We take appropriate measures to ensure that these international recipients adhere to privacy obligations concerning your personal information. However, we cannot be held liable for the privacy or security practices of any third party, including those to whom we are authorized to disclose personal information in accordance with this Privacy Policy or relevant laws. The collection and utilization of an individual’s information by such third parties may be governed by their own privacy and security policies. These third parties include YouTube API Services; for more details regarding this tool, we recommend reviewing their Terms of Service and Privacy Policy, and you can visit the Google security settings page to revoke access to your data. 

Merger: 

In the event of a merger, acquisition, or sale of all or part of our assets… 

Legal Obligations: 

Furthermore, we are obligated to share your information as mandated by law, which may include disclosures to governmental authorities and law enforcement agencies. This also encompasses situations related to ongoing or anticipated legal actions, as well as efforts to establish, assert, or safeguard our legal rights, including sharing information with third parties for fraud prevention purposes. 

Compliance, Adherence and Safeguarding: 

We may share your personal information with third parties to uphold or implement the terms of our agreements, to examine possible violations, or to ensure the rights, property, or safety of Commission Zen, our clients, or other individuals are protected. 

Data Retention 

We will retain your personal information only for as long as necessary to achieve the purposes for which it was collected, including compliance with any legal, accounting, or reporting obligations. In determining the appropriate retention period for personal data, we take into account factors such as the volume, nature, and sensitivity of the data, the potential risks associated with unauthorized use or disclosure, the purposes for which we process the data, and whether those purposes can be fulfilled through alternative means, as well as relevant legal requirements. 

Data Accessibility Rights 

We are committed to upholding your rights as outlined by relevant data protection legislation. It is important to note that these rights are not absolute and may not be applicable in every situation. You have the following rights: – To request access to your personal information and details concerning our usage and processing of that information. – To request the correction or deletion of your personal data. – To request a limitation on our use of your personal information. – To request a machine-readable version of your data or to have your data transferred to other information technology systems. – To object to the processing of your personal information under certain circumstances. – To withdraw your consent for our use of your personal data at any time, particularly when our processing relies on your consent. Should you have any concerns regarding our handling of your personal data, we encourage you to reach out to us. If you are dissatisfied with our data processing practices or our response to your inquiries. 

Website Visitors 

Data Utilization 

To respond to your inquiries

When you reach out to us regarding our services, the forms you fill out or the emails you send may contain personal information, such as your name, email address, and the nature of your inquiry. In accordance with our legitimate interest in promoting and managing our business, we will process your inquiries to respond and provide you with relevant information about the services we offer. 

News and Updates 

If you request to be included on our mailing list, we will send you updates and information via email unless you choose to opt out (in which case, please inform us by clicking the unsubscribe link at the bottom of any marketing email you receive or by contacting us directly). 

Social Media Plugins 

Commission Zen engages with and promotes its services through social networks and has integrated various social media plugins on our websites. These plugins are utilized to further our legitimate interest in marketing our business and facilitating communication with our partners and the general public. When you access a page on our website that features a social media plugin, your browser or application will create a direct connection to the servers of the respective social network. Consequently, information indicating that your browser has accessed the Commission Zen page will be sent to the social network, regardless of whether you possess an account with that network or are logged in. If you are logged into your account simultaneously, a page view may be linked to your profile.

Data Utilization to manage operations 

We handle personal information to uphold our legitimate interests, ensuring that the use of our services remains lawful and free from fraud, does not interfere with the functionality of our services, and does not cause harassment to our staff or other individuals. Additionally, we aim to protect our legal rights and fulfill our legal responsibilities. If we have reasonable grounds to believe that you are, or may be, violating any applicable laws, we may use your personal information to notify relevant third parties, such as your email or internet service provider, or law enforcement authorities regarding the content. 

Disclosure of Information 

Group members, staff, and service providers: We maintain the confidentiality of your information; however, we may share it with our group members, employees, suppliers, or subcontractors as necessary to fulfill the purposes outlined in this Privacy Policy. This sharing is contingent upon their agreement to protect the information and refrain from using it independently. Third-party service providers may engage in activities such as website hosting, analytics, customer relationship management, email marketing, and IT support. 

What rights do you possess concerning your data? 

We are committed to upholding your rights as outlined by relevant data protection legislation. It is important to note that these rights are not absolute and may not apply in every situation. You have the right to: 

  • Request access to your personal information and details regarding our usage and processing of that information; 
  • request the correction or deletion of your personal information; 
  • request that we limit our use of your personal information; 
  • request a machine-readable version of your personal information or ask for it to be transferred to other IT systems; 
  • Object to the processing of your personal information for specific purposes; and 
  • withdraw your consent for our use of your personal information at any time, particularly when our processing relies on your consent. 

Should you have concerns about how we are handling your personal data, we encourage you to reach out to us. In the event of a dispute regarding an individual’s personal information, both parties must first seek to resolve the matter directly. If we become aware of any unauthorized access to an individual’s personal information, we will notify the individual and any relevant supervisory authority as required, as soon as we ascertain the nature of the breach and how it occurred. 

Job Applicants 

How is data from job applicants utilized? 

In the course of our recruitment process, we gather and handle personal data pertaining to job applicants. This information encompasses: 

  • Your name, address, and contact information, including email and phone number; 
  • Details regarding your qualifications, skills, experience, and employment history; 
  • Information about your current salary, including any benefits you are entitled to. 

We may acquire this information through various means. For instance, it may be included in application forms, CVs, or resumes, obtained from your passport or other identification documents, or gathered during interviews or other assessment methods, including online evaluations. 

The processing of this information is necessary to take steps at your request before entering into an employment contract with you. Additionally, we have a legitimate interest in processing personal data throughout the recruitment process and in maintaining records of that process. Handling data from job applicants enables us to oversee the recruitment process, evaluate and verify an applicant’s suitability for employment, and determine whom to extend a job offer to. 

Consumers 

How is end user data utilized? 

Commission Zen primarily leverages end user data to track the journey of an end user from an Affiliate to an Advertiser. This tracking process allows us to confirm that an end user has engaged with an Affiliate’s service, discovered a product, and subsequently clicked a link that directs them to the Advertiser’s service for product review or purchase. The primary objective of tracking is to attribute sales and marketing efforts made by an Affiliate to specific transactions, thereby enabling Advertisers to compensate Affiliates on a per-transaction basis. Additionally, tracking facilitates the generation of relevant reports for both Affiliates and Advertisers, the majority of which consist solely of aggregated statistical data. 

Commission Zen does not possess any identifying information about the end user; it only recognizes that the same end user initiated their experience with the Affiliate and concluded it with the Advertiser, indicating the success of the affiliate marketing campaign for that particular end user. 

By maintaining a limited user profile that does not disclose the end user’s name or identity, Commission Zen can analyze the end user’s journey across different devices. This capability allows us to determine if a referral began on one device and was completed on another. The profile is exclusively utilized to attribute sales and marketing efforts to an Affiliate, even if the end user switches devices prior to finalizing a transaction. Commission Zen allows Affiliates to inquire whether a user action should have resulted in a commission for that Affiliate. This process requires the exchange of information between Affiliates and Advertisers. 

Advertisers utilize the data provided by Affiliates to cross-verify with their own records. Commission Zen facilitates this data exchange and ensures the payment of any commissions owed to the Affiliate as a result. 

How is data collected from end users? 

The primary technologies employed by Commission Zen for tracking purposes include Tracking Domain Cookies, Journey Tags, and Device Fingerprinting. 

Tracking Domain Cookies: 

These cookies are generated by Commission Zen’s own domain when an end user interacts with an advertisement presented by an Affiliate. This data allows us to ascertain which end users are directed by specific Affiliates to particular Advertisers. Additional information regarding cookies can be found here. 

Advertiser Journey Tag: 

This refers to JavaScript code that is embedded within the Advertiser’s service, facilitating the transmission of transactional data to Commission Zen. This information is utilized by Commission Zen to document, verify, and report the successful completion of transactions, which is essential for distributing commissions to Affiliates. 

Fingerprinting: 

This technique enables Commission Zen to uniquely identify a device by analyzing various attributes of the browser or device, including screen size, resolution, and user settings. 

What information do we gather from end users? 

We ensure that we only collect data that is essential for our operations. The majority of the data utilized by Commission Zen is generated by machines. This allows us to identify an individual without disclosing their identity. We do not employ this data for making predictions or assessments regarding users’ interests or personalities. 

Commission Zen operates within the affiliate marketing ecosystem (refer to our Agreement with Advertisers and Affiliates below) and does not always possess complete control over the personal data obtained from users, Affiliates, or Advertisers. Commission Zen maintains a unique sequence of numbers related to transactions that does not disclose the identity of any specific end user. This data includes information about the Advertiser’s campaign, the Affiliate, the action taken by the end user (such as a click or a view and the corresponding country), and the device utilized. Additionally, Commission Zen acquires limited transactional data through the Journey Tag to verify that a transaction has taken place and to facilitate accurate commission allocation, billing, and reporting. This information encompasses the order value, whether a voucher was applied, the type of product, and the sales channel. 

The data processing activities of Commission Zen concerning end user information do not necessitate the direct identification of individuals. Consequently, Commission Zen primarily retains what is referred to as “pseudonymous” data in this context. Pseudonymisation enhances privacy by separating data from direct identifiers, ensuring that it cannot be linked to a specific individual without additional information. 

Pseudonymisation effectively mitigates the risks linked to data processing, all the while preserving the utility of the data. 

Does Commission Zen possess a legitimate interest in utilizing data? 

We have conducted a balancing exercise and determined that legitimate interests serve as a valid basis for processing user data as outlined in this section of the Privacy Policy. 

In evaluating Commission Zen’s legitimate interest, we took into account the interests of the entire affiliate ecosystem. A balancing test was performed, confirming that tracking poses no risk or only a minimal risk of causing undue negative effects on the interests or fundamental rights and freedoms of the end user. Legitimate interests extend beyond those of Commission Zen and may encompass the interests of third parties or society as a whole. In relation to our services, we recognize that: 

Advertisers are interested in executing online advertising campaigns funded on a performance basis, where third-party referrers of customers or potential customers receive compensation for referrals that generate revenue for the Advertiser or fulfill other desired actions. 

Affiliates seek to monetize their content, services, or other elements of their websites by generating advertising revenue based on performance. 

Both Advertisers and Affiliates are interested in acquiring reports pertinent to their respective revenue generation activities. 

Commission Zen aims to operate an affiliate marketing network and provide technology, services, and reporting in exchange for payment from Advertisers. 

Commission Zen, Advertisers, Affiliates, and society as a whole share an interest in combating fraud, service misuse, and money laundering. 

Agreement with Affiliates and Advertisers within our network 

Commission Zen’s affiliate marketing network facilitates collaboration between Advertisers and Affiliates, enabling them to execute affiliate marketing campaigns effectively. In the execution of these campaigns, each party contributes to shared objectives and retains the authority to make specific decisions regarding the utilization of data. 

Commission Zen mandates that all participants in its network adhere to data protection regulations and fulfill their responsibilities in addressing requests related to data subject rights. Individuals wishing to exercise their rights concerning the data managed by a specific party may contact that party directly. 

Commission Zen collaborates with these Advertisers. For instructions on how to submit a request to an Affiliate or Advertiser, please refer to their individual privacy notices. For further details on how to make a request to Commission Zen, please see the section titled “What rights do you have in respect of user data” below. 

Required by Law: 

Furthermore, we may disclose your information as mandated by law, such as to governmental entities and law enforcement agencies; in relation to any legal proceedings or anticipated legal actions; and to establish, exercise, or defend our legal rights, which may include sharing information for fraud prevention purposes. 

Enforcement: 

We may disclose your personal information to third parties to enforce or implement the terms of agreements, to investigate potential violations, or to safeguard the rights, property, or safety of Commission Zen, our clients, or others. 

Data Security 

We are committed to implementing all appropriate technical and organizational measures to safeguard your personal information from loss, misuse, or unauthorized alteration. It is important to understand that while we strive to ensure the security of the information we handle, no security system can guarantee complete protection against all possible security breaches. 

When modifications are made to this Privacy Policy?

This Privacy Policy is subject to periodic updates. We will inform you of any alterations by publishing the revised policy on this site and, when possible, by sending you an email notification.