Terms of Use and Privacy Policy

Effective date: 15.08.2023

1. Who are we, a field of our activity and legitimate interests?

1.1 Limited Liability Company “SalesDoubler” (hereinafter also referred to as the Company, SalesDoubler, we) – the Company that was created, registered, and carries out its activities by the national legislation of Ukraine, registration number in Ukraine (National State Registry of Ukrainian Enterprises and Organizations code): 38981229, location: Ukraine, Kyiv, Stepan Bandera Avenue, 13, contacts: info@salesdoubler.pro.

1.2 The company manages the website https://salesdoubler.pro/, which is the platform that ensures the interaction of advertisers and affiliates for marketing and advertising activities according to the СPA (Cost Per Action) model that provides the opportunity for advertisers to promote their products (goods, services, etc.) using the services of affiliates, and affiliates – to receive a reward for the targeted actions of consumers on the advertisers’ websites. The company can carry out other types of activities that are not prohibited by law.

1.3 Since 2012, SalesDoubler has been working in the field of advertising and marketing activities using the CPA model, and our legitimate interests are to continue to carry out our business, to increase the number of our customers and partners (affiliates, advertisers, etc.), to increase the number of users of the Website, to expand the list of services that can be provided using the Website, to maintain the appropriate level and develop the services provided on the Website, their quality and safety, continue to build a positive image and a well-recognized brand of the Company, as well as perform other actions that will contribute to the development of the Company and the services provided on the Website.

2. What is regulated by this Privacy policy?

2.1 SalesDoubler respects the privacy, inviolability of private life, and personal data protection of all persons, without exception, who visit the Website and those who use the services available on the Website. In this regard, the Company strives to carry out its activities in compliance with the requirements for the protection of personal data, thereby creating and ensuring the most comfortable and safe conditions for using the services and services of the Website.

2.2 For this, we have implemented rules and procedures, which are fixed in this Privacy Policy, where you will find answers to questions about for what purpose, on what basis, and what your personal data can be processed by the Company, in what way and for how long your personal data may be processed, how the protection of your personal data is ensured, to whom your personal data may be transferred, about your rights, as a subject of personal data and other issues related to the processing of personal data.

3. Terms used in this Privacy Policy

3.1  Personal data subject – individual, whose personal data is processed. As a rule, it is a user of the Website, the affiliate (his authorized person and/or representative), advertiser (his authorized person and/or representative), and the consumer.

3.2 Personal data – information or a set of information about an individual who is identified or can be specifically identified based on such information or a set of information.

3.3 Personal data owner – Limited Liability Company “Salesdoubler”, which determines the purpose of personal data processing, establishes the composition of this data, and the procedures for its processing.

3.4 Website – graphic and informational materials set, ЕCМ (electronic computing machine) programs, and databases, which ensure their availability on the Internet at the network address: https://salesdoubler.pro.

3.5 User – any Website visitor who accesses the Website from any device.

3.6 Affiliate –a person who provides services for placing advertising materials on the Internet to promote the sale of products (goods, services) of advertisers and receives a reward for this from the advertiser on the terms specified in the advertiser’s affiliate program on the Website.

 3.7 Advertiser –a person who places on the Website affiliate programs for affiliates to place advertising materials on the Internet to promote the sale of their products (goods, services) and pays affiliates a reward on the terms specified in the relevant affiliate program on the Website. 

3.8 Consumer – a client of the advertiser who is interested in purchasing or buying advertiser products (goods, services) as a result of the activities of affiliates cooperating with advertisers using the services of the Website.

 3.9 Agreement to personal data processing –the voluntary expression of the will of the subject of personal data regarding the granting of permission for the processing of his personal data per the formulated purpose of their processing, expressed in a written form or electronic form. 

3.10 Legitimate interest – the basis for personal data processing, which is based on the legally established permission for the owner of personal data to carry out the collection and processing of personal data to protect the legitimate interests of the owner of personal data or a third to whom personal data is transferred, except for cases, when the needs to protect the fundamental rights and freedoms of the subject of personal data in connection with the processing of his data prevail over such interests. The Company’s legal interests are specified in paragraph 1.3. of this Privacy Policy. When determining the company’s legal interests, we consider the need to maintain a balance between the rights and freedoms of the subjects of personal data and the company’s legal interests.

3.11 Personal data processing –any action or set of actions, such as collection, registration, accumulation, storage, adaptation, change, renewal, use and distribution (distribution, implementation, transfer), depersonalization, destruction of personal data, including using information (automated) systems or without the use of such systems.    

3.12 Personal data processing using automated systems – operations carried out in whole or in part using automated tools: storage of data, execution of logical and (or) arithmetic operations with these data, their change, destruction, selection or distribution.

3.13 Third persones (recipients of personal data) – any person, except the subject of personal data, the owner or manager of personal data, and the Commissioner for Human Rights of the Verkhovna Rada of Ukraine, to whom the owner or manager of personal data transfers personal data.

3.14 Tracking functional – functionality that provides the ability to establish the fact of the consumer’s transition from the affiliate’s advertising material to the advertiser’s website and the consumer’s performance of a specific action on the advertiser’s website (registration, purchase of goods, etc.)-

3.15 Redirect domain – a component of the tracking functionality, which is a URL on the Internet to which consumers are automatically redirected from the affiliare’s link URL and then redirected to the advertiser’s website.

3.16 Transfer of information using the API method (application programming interface) –  a method of interaction between software components that provides the technical possibility of data transfer between several systems that store relevant information.

4. What is your personal data, and for what purpose can we process it? Method of obtaining personal data.

4.1 We can collect and process several types of personal information related to the use (visit) of the Website by users, as well as information related to the provision of services on the Website:

• information about users (visitors) of the Website;
• information about affiliates;
• information about advertisers; 
• information about consumers;
• information about potential users, affiliates, advertisers, consumers.

4.2 During your interaction with the website as a user, we may collect and process the following information: the IP address of the user’s device from which the website is accessed, the date and time the user visited the website, the technical characteristics of the web browser and operating system the user’s device from which the Website is accessed, the Website from which the user was redirected to the Website, other similar information.

The information indicated in this paragraph can be collected and processed for analytics, optimization, and improvement of the Website, to create safe conditions for using the Website, for historical and statistical purposes (including for the formation of registers of users of the Website and their data, specified in this paragraph).    

4.2.1. When you contact the Company using the feedback forms on the Website, we may collect and process the following personal information: first name, last name and (if available) patronymic, email address, country, phone number, messenger contact details, any what other data the user provides in an email through a feedback form or online chat.

The information indicated here may be collected and processed to establish contact and provide the requested information, for communication and interaction between the Company and the user, for analytics, optimization, and improvement of the Website, for creating safe conditions for using the Website, for historical and statistical purposes (including for the formation of user registers and their data specified in this paragraph), for marketing and advertising of services, offers of the Company, including new offers and services (messages and offers of services and products of the Company, other types of marketing and advertising activities of the Company)   

4.3 When you interact with the Company to receive services as an affiliate and/or advertiser, we may collect and process the following information:

4.3.1 Contact and general information: name, surname and (if available) patronymic, e-mail address, country, phone number, website of the affiliate and/or advertiser, contact details of the messenger, any other data that the affiliate or the advertiser provides in an e-mail through the feedback form or online chat, information about the legal entity on whose behalf the affiliate and/or the advertiser acts: organizational and legal form, name, location, surname, first name and (if available) patronymic of the manager or authorized representative of the affiliate and/or advertiser company.

The information indicated here may be collected and processed to create and function the affiliate and/or advertiser account on the Website, for communication and interaction of the Company (company representative) with the affiliate and/or advertiser, for the provision of services to the affiliate and/or the advertiser, for analytics, optimization, and improvement of the Website, to create safe conditions for using the Website, for historical and statistical purposes (including for the formation of registers of affiliate and/or advertisers and their data specified in this clause), for marketing and advertising of the Company’s services, offers, including new offers and services (messages and offers of the Company’s services and products, other types of marketing and advertising activities of the Company)

4.3.2. Payment information: during the Company’s interaction with the affiliate and/or advertiser, we may collect and process payment information, which may include the bank card number, bank account, name and details of the issuing bank, last name, first name and (if available) patronymic of the bank account holder (bank card), name and legal form of the company of the affiliate and/or advertiser, surname, first name and (if available) patronymic of the manager or an authorized representative of the company of the affiliate and/or advertiser and other payment information.

The information specified here is necessary for making settlements with affiliates and/or advertisers and for analytics, optimization, and improvement of the Website to create safe conditions for using the Website.

 4.4 When you interact with advertising materials (by going to an advertiser’s website) placed on the Internet by affiliates interacting with the Website:

4.4.1 We may collect and process the following information: the IP address of the user’s device, the date and time of the user’s visit to the advertiser’s website, the technical characteristics of the user’s browser and operating system, the website from which the user was redirected to the advertiser’s website, a unique identifier transition.

 The data indicated here is collected using the tracking functionality, and the processing of such data is carried out to provide services to affiliates and advertisers for the opportunity advertisers and affiliates to establish how the consumer interacted with the information of the affiliate, whether the result of this interaction was the transition of the consumer to the website of the advertiser, whether the result of such interaction was the purchase by the consumer of goods (product, service) from the advertiser or the another specific consumer’s targeted action on the advertiser’s website.

Because affiliates are interested in consumers finding information about advertisers’ products and services and going to advertisers’ websites to purchase their goods and services from advertisers, and because advertisers are interested in selling their goods and services to consumers, the collection and processing of the information specified in this paragraph information are also carried out to exchange this information between affiliates and advertisers so that they have the opportunity to make appropriate calculations.

4.4.2 The affiliate may collect personal data about you, which may then be transferred to us and the advertiser, namely: first name, last name, and (if available) patronymic, e-mail address, country, telephone number, the website from which the transfer was made to advertiser’s website, any other data you may provide to the affiliate.

 The data specified here is collected to provide services to advertisers in attracting consumers to their goods and/or services.     

4.5 The Company may use your personal data to provide services and information about new services, products, and services offered by the Company or companies that are part of the Treeum group of companies and our partners. You have the right to refuse to receive such communications at any time.

4.6 We may use the personal data we collect to provide and improve our services, respond to your inquiries, and communicate with you about our products, services, and promotional offers.    

4.7 The Company may process your personal data for historical and statistical purposes.

4.8 Your personal data can be collected by the Company in the following ways:

• by voluntary provision of personal data by the user, affiliate, advertiser, and other persons when filling out the relevant contact and other forms on the Website (including by using @sdcat_bot) and/or when concluding contracts for the provision of services; 
• by collecting data when visiting the site (IP address of the user’s device from which the Website is accessed, date and time of the user’s visit to the Website, technical characteristics of the web browser, and operating system of the user’s device from which the Website is accessed, the Website from which the user was redirected to Website, other similar information);
• by obtaining personal data using tracking functionality and redirect domains (The company uses the following redirect domains: rdr.salesdoubler.com.ua, rdr.myintsd.com, rdr.fmcgsd.net, rdr.pdlsd.net, go.salesdoubler.net, rdr.gointsd.com, rdr.sdpdl.com.ua, rdr.pdlsd.kz, sdprl.com).
• by receiving personal data from affiliates, which are transmitted by the API method;
• by storing cookies on Website visitors’ devices [hyperlink to Privacy Policy].

4.9 Providing personal data is voluntary but necessary for the website’s operation and for providing services to affiliates and advertisers. We do not guarantee that you can fully use the Website without providing personal data. Without providing personal data that is necessary for the provision of services (including, but not limited to, affiliates and advertisers), we will not be able to provide such services, enter into service contracts and fulfill our obligations under service contracts.

4.10 The Company may collect and otherwise process your personal data with and without using automated systems. 

5. On what basis and for what purpose can we process your personal data?

5.1. The Company processes personal data by the national legislation of Ukraine and international legislation, in particular, under the Convention on the Protection of Individuals in Connection with Automated Processing of Personal Data dated January 28, 1981, the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679), the Law of Ukraine “On the Protection of Personal Data” and other legislative acts. 

5.2. The grounds for processing your personal data may be legal grounds provided for by the national legislation of Ukraine and the GDPR, in particular:

• agreement to the processing of personal data;
• the need to perform a contract with you or to take actions at your request before concluding a contract;
• protection of vital interests;
• the need for us to fulfill the duty stipulated by law;
• our legitimate interests or the legitimate interests of a third party.

6. How long can your personal data be processed?

6.1. We may store and process your personal data for as long as necessary to achieve the purpose for which the personal data was collected and processed. We try not to process personal data longer than is necessary to achieve the purpose for which the data was collected and processed.

6.2. Sometimes the Company may keep your personal data longer than necessary to achieve the purpose of its processing, in particular, if it is necessary to comply with our legal obligations, to protect your rights and legitimate interests, for statistical and historical purposes, to interact with government authorities, etc.

7. How do we protect your personal data?

 7.1 The company uses generally accepted standards of technological and operational protection of information and personal data from loss, unauthorized disclosure, or other forms of improper use. However, despite its best efforts, the Company cannot guarantee absolute security against any threats arising outside of the Company’s control.

 7.2 The Company ensures the application of necessary confidentiality obligations and technical and organizational security measures to prevent unauthorized or illegal disclosure or processing of such information and data, and their accidental loss, destruction, or damage.

8. Who can your personal data be transferred to?

 8.1 We may disclose your personal data to our employees, companies that are part of the Treeum group of companies, partner companies, third parties, including affiliates, advertisers, service providers, government authorities (including regulatory, law enforcement, and judicial), and other third parties, if it is necessary for the execution of the Company’s business processes, provision of services, the fulfillment of the Company’s legal obligations and for other reasons established by national law and the GDPR.

8.2 Our employees adhere to the requirements of confidentiality and responsible handling of personal data to which they have access. At the same time, access to personal data is provided only if it is necessary to perform tasks or functions related to personal data and in accordance with the purpose for which personal data can be processed. For example, your personal data may be disclosed to our employees who are responsible for the processing of personal data and their preservation, employees who are responsible for advertising and marketing, employees who are responsible for providing services to affiliates and advertisers, employees who are responsible for communication with by users of the Website, etc.

8.3 The Company may transfer personal data to companies that are part of the Treeum group of companies and partner companies when such data transfer is necessary for the Company’s business processes, provision of services and is consistent with the purpose of personal data processing. Companies that receive personal data strictly comply with the conditions and obligations regarding the processing of personal data, including the conditions regarding the protection of personal data and the conditions regarding the purpose of the payment of such personal data.

8.4 Your personal data may be transferred to third parties with whom we cooperate to perform business-related processes (functions): Traffic logging (accounting), Email mailing service, Triggered email mailing service, Service for communicating with affiliates, Analytics service, Advertising service in social networks, SMS mailing service, Advertising in Google services, Proxy service, Traffic attribution platform, Service for electronic exchange of documents, data storage, hosting of websites, payment processing Such third parties can access only those personal data that necessary for their provision of services to the Company, provided that this is consistent to process personal data, and provided that they undertake to comply with the requirements for the protection of personal data.

8.5 We may engage external consultants (auditors, economists, accountants, lawyers, business analysts, etc.), as well as contractors (development and implementation of software, management systems, website, maintenance of such systems and provision of advertising services, lead generation services, translation and writing services, etc.), if necessary. Such consultants and contractors may access only those personal data necessary for them to provide services to the Company, provided that this is consistent to process the personal data and that they undertake to comply with the requirements for the protection of personal data.

8.6 Affiliates and advertisers cooperating with the Company may also process personal data. 

8.7 We may pass personal data to government authorities (including supervisory, law enforcement, and judicial authorities) if required by law or to fulfill legal obligations.

8.8 You have the right to receive information about your personal data which were passed, on what basis, and to whom. To do this, you need to send a request to the email address info@salesdoubler.pro. If necessary, we may ask you to confirm your identity to avoid possible attempts of illegal access to personal data.

9. Your rights as a personal data subject.

9.1. As a personal data subject, you have the rights guaranteed by law:

1) know about the sources of collection, the location of your personal data, the purpose of their processing, and the location of the owner of personal data;

2) receive information about the conditions for providing access to personal data, in particular, information about third parties to whom personal data is passed;

3) the right to access your personal data;

4) to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, an answer about whether your personal data is being processed, as well as to receive the content of such personal data;

5) make a reasoned demand to the owner of personal data with an objection to the processing of your personal data;

6) make a reasoned demand to change or destruct of your personal data by any owner and manager of personal data, if these data are processed illegally or are unreliable;

7) the right to protect your personal data from illegal processing and accidental loss, destruction, or damage due to deliberate concealment, non-provision, or untimely provision of them, as well as to protect against providing information that is unreliable or disgraces the honor, dignity, and business reputation of an individual;

8) make complaints about the processing of your personal data to the Commissioner or the court;

9) apply legal remedies in case of violation of the legislation on the protection of personal data;

10) enter a caveat regarding the limitation of the right to process your personal data when giving consent;

11) withdraw consent to the processing of personal data;

12) know the mechanism of automatic processing of personal data;

13) to protect against an automated decision that has legal consequences for you;

14) “to be forgotten”, which guarantees the deletion of all personal data from our databases at your request.

9.2. To exercise your rights, as well as in case of questions related to your personal data, you can contact us by emailing info@salesdoubler.pro. If necessary, we may ask you to confirm your identity to avoid possible attempts of illegal access to personal data.

10. Sensitive personal data.

10.1 As a general rule, the Company does not process personal data on racial or ethnic origin, political, religious, or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as data related to health, sexual life, biometric or genetic data.

11. Third party sites.

11.1. For the convenience of users, affiliates, advertisers and consumers, the Website may contain links to other sites, such as our partners or suppliers, subject to different privacy policies. This Policy will not apply to your use of other websites. We are not responsible for the content, products, or services offered, privacy and security practices, or practices of third party sites. We recommend you to review the respective privacy policies of such websites to understand how your information may be collected and used by those websites.

12. Social networks

12.1. Our website includes and/or may contain links to social networks such as Facebook, Twitter, YouTube, Telegram, Instagram or Linkedin («Social networks»). These Social Networks may collect information about your IP address and the page you visit on our Website and may set cookies. Your interactions with these Social Networks are governed by their own privacy policies.

13. Data transmission to third countries.

13.1. The transfer of personal data to foreign subjects of relations related to personal data is carried out only under the condition that the relevant state ensures adequate protection of personal data in cases established by law or an international treaty of Ukraine.

13.2. The Company may transfer personal data to foreign entities, provided that such persons undertake the processing of personal data by the requirements of the legislation on the protection of personal data, and provided that such transfer is consistent with the purpose of processing personal data. 

13.3. To receive information about whether your personal data has been transferred to third countries, you can contact us by emailing the e-mail address info@salesdoubler.pro. If necessary, we may ask you to confirm your identity to avoid possible attempts of illegal access to personal data.

14. Updates to this Privacy Policy 

14.1. We may update this Privacy Policy occasionally to reflect changes in our practices or legal obligations. We encourage you to periodically review this Policy for updates. The “Effective Date” at the top of this Policy indicates its last updated date.

15. Contact us

15.1. If you have any questions about this Privacy Policy or the processing of personal data, please contact us at info@salesdoubler.pro.

Cookies policy

Effective date: 15.08.2023 

1. General information 

1.1 We use cookies to improve and optimize the usability of our Website. This Cookie Policy details the information that cookies collect, how we use it, and why we need to save cookies.

2. What are cookies?

2.1 Cookies are small text files that are stored on your device (computer, tablet, mobile phone) when you visit the Website. They contain information about your web browser activity on this Website, allowing the Website to remember your actions and your settings.

2.2 Cookies are used to maintain the site user’s session (after authorization), and the user does not need to re-enter the login and password on each Site page.

3. Third party cookie files

3.1 We may allow certain third party cookies on our website. These cookies are provided by trusted third parties to analyze website traffic, display targeted advertising, and provide social networking features. We do not control these cookies and their use is governed by the privacy policies of the relevant third parties.

4. Types of cookies we use 

4.1. The technologies used on the Internet are constantly changing and improving, which has the effect of changing the specific cookies that we use on the Website. Therefore, we cannot guarantee that the specific cookies specified in this Policy as of the date of its update will be relevant for a long time.

Therefore, this Cookie Policy sets out the general types of cookies we use on our Website and the main examples of such files.

4.2. We use the following types of cookies:

4.2.1. Advertising cookies: used to track users (visitors) of the Website, tracking how the visitor uses the Website, and user activity on the Website. Examples of advertising cookies: _fbp – These cookies are used by Facebook for advertising and traffic tracking, for example, fb.1.1690818789429.2134237695. FPAU – Collects data about users and their activity on the website through embedded elements to generate Google analytics and reports, for example, 1.2.172845453.1690818790.

4.2.2. Analytical Cookies: We use analytical cookies to collect information about how visitors interact with our Website. This helps us understand and improve the performance and usability of our Website. Examples of analytical cookies: _ga – records the unique identifier of a website visitor. This identifier makes it possible to track how the visitor uses the website. This data is used for statistics in Google Analytics, for example, GA1.1.413885605.1690818789. __utmc – records the time of the website visit and stores this data in Google Analytics, for example, 134756461.

4.2.3. Functionality cookies: allow our website to remember information that changes its behavior or appearance, such as the website language you prefer, the theme of the website, and the date it was saved (light or dark). These cookies may also be used to provide you with personalized content and improve the user experience. Examples of functional cookies: pll_language – to save the language of the user’s browser, for example, uk. themeState – to save the theme of the user’s site (light or dark), for example, night.

4.2.4. Technical cookies: These cookies are necessary for the operation of our website and allow you to use the services of the Website, and are also necessary to establish a unique identifier of the consumer, advertiser, and affiliate, the offer of the advertiser. Certain services or features on our Website may not be available without these cookies. Examples of technical cookies: sd_session is a unique user identifier, for example, bGtxdG50MmdRa6sWKv06UYZZ. sd_token – for user authorization on the site, for example IVQ5OEhod1c2NWdZdlYzWkFocUJxR21DU2dWajRadXBNSjk%3D.

5. What data is collected?

5.1. When you visit our Website, we automatically collect certain personal data from your device, such as:

a) Your IP address.

b) Date and time of visiting our website.

c) Duration of your session.

d) How many times have you visited our site during the month?

e) The operating system your computer is using.

f) We use Google Analytics to track traffic to our website.

6. Data protection and storage

6.1. Information collected through cookies may contain personal data. We process your personal data through our Privacy Policy [hyperlink to Privacy Policy]. We retain cookie data for the period necessary to achieve the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

7. Updates to this Policy

7.1. We may update this Cookie Policy from time to time. We encourage you to periodically review this Policy for updates. The “Effective date” at the top of this Policy indicates its last updated date.

8. Contact us

8.1. If you have any questions about this Cookie Policy or the use of cookies, please contact us at info@salesdoubler.pro.