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Privacy Policy

How Bucksbooth collects, uses, shares and protects personal data - written for a global audience and aligned with the EU GDPR, UK GDPR, and other applicable data protection laws.

LAST UPDATED: 18 JULY 2026 · VERSION 1.0 · APPLIES WORLDWIDE

Contents

  1. Who we are & scope
  2. Our roles: controller vs. processor
  3. Personal data we collect
  4. Purposes & legal bases (GDPR Art. 6)
  5. Cookies & tracking technologies
  6. How we share personal data
  7. International data transfers
  8. Data retention
  9. Your rights (GDPR & worldwide)
  10. How to exercise your rights
  11. Automated decision-making
  12. Security
  13. Children's privacy
  14. US state privacy rights (CCPA/CPRA)
  15. Other jurisdictions
  16. Changes to this policy
  17. Contact & complaints

1. Who we are & scope

Bucksbooth ("Bucksbooth", "we", "us", "our") operates a performance marketing network that connects data owners and affiliates ("Affiliates") with advertisers ("Advertisers"), together with the associated technology platforms: Trackbooth (performance tracking), Subsbooth (list and consent management) and Sendbooth (email and SMS delivery) (together, the "Services").

This Privacy Policy applies to personal data we process when you:

  • visit our websites (including bucksbooth.com, trackbooth.com, subsbooth.com and sendbooth.net);
  • register for, apply to, or use the Services as an Affiliate, Advertiser, or their personnel;
  • interact with marketing campaigns delivered through our network as a consumer; or
  • communicate with us by email, phone, forms or otherwise.

We operate globally. Where the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"), the UK GDPR, or similar laws apply, this policy is intended to satisfy the transparency requirements of those laws (including GDPR Articles 13 and 14).

2. Our roles: controller vs. processor

Data protection law distinguishes between a "controller" (who determines the purposes and means of processing) and a "processor" (who processes on a controller's instructions). Bucksbooth acts in both capacities:

  • As a controller - for personal data of Affiliates, Advertisers and their personnel (account, billing, compliance and communications data), for visitors to our own websites, and for network-level compliance data such as suppression and opt-out lists.
  • As a processor - for subscriber and consumer data that Affiliates upload to or manage through Subsbooth and Sendbooth. In those cases the Affiliate (and/or the relevant Advertiser) is the controller, and our processing is governed by our platform terms and data processing agreement ("DPA"). A GDPR Article 28-compliant DPA is available to all platform customers on request from [email protected].
If you are a consumer who received a marketing email or SMS through our network: the sender identified in the message (an Affiliate) and the promoted brand (an Advertiser) are typically the controllers of your data. You can contact us at [email protected] and we will help route your request, and we will action opt-outs across our network directly.

3. Personal data we collect

3.1 Affiliates, Advertisers and their personnel

  • Identity & contact data: name, company/trading name, physical and billing address, telephone number, email address, website address, messaging handles.
  • Verification & tax data: taxpayer ID or national tax number, W-9/W-8 or local equivalents, company registration details, and identity documents where required for anti-fraud or legal compliance.
  • Financial data: payout method details (bank, ACH, PayPal), invoices and payment history.
  • Account & usage data: login credentials, platform activity, campaign selections, API usage, IP addresses, device and browser information, and support communications.
  • Compliance data: consent evidence for lists, traffic-quality signals, complaint records and audit trails.

3.2 Consumers (as processor, and for network compliance)

  • Subscriber records managed by Affiliates in Subsbooth: email address, phone number (for SMS), name, postal address, opt-in date, registration source URL, consent IP, and segmentation attributes.
  • Engagement data generated by Sendbooth and Trackbooth: delivery, open, click, conversion and unsubscribe events, with associated timestamps, IP addresses and device/browser metadata.
  • Suppression data (as controller): email addresses, phone numbers and domains on unsubscribe and suppression lists, retained specifically so that they are not contacted again.

3.3 Website visitors

  • IP address, approximate location, device and browser data, pages viewed, referral source, and cookie identifiers (see Section 5).
  • Anything you submit through our forms (applications, contact requests).

We do not intentionally collect special categories of personal data (e.g. health, religion, political opinions) and ask that you do not submit them to us.

4. Purposes & legal bases (GDPR Article 6)

Where GDPR or UK GDPR applies, we rely on the following legal bases:

PurposeExamplesLegal basis
Providing the ServicesAccount creation, campaign management, event tracking, payout calculation and paymentPerformance of a contract (Art. 6(1)(b))
Vetting & approvalReviewing applications, verifying identity, assessing traffic qualityContract (pre-contractual steps) and legitimate interests (Art. 6(1)(f)) in maintaining a trustworthy network
Compliance & anti-fraudSuppression-list scrubbing, consent audits, fraud detection, complaint handlingLegal obligation (Art. 6(1)(c)) and legitimate interests in preventing abuse
Legal & tax obligationsTax reporting, accounting records, responding to lawful requests from authoritiesLegal obligation (Art. 6(1)(c))
Our own marketingNewsletters and product updates to business contactsConsent (Art. 6(1)(a)) or legitimate interests, with opt-out always available
Security & service improvementMonitoring, debugging, analytics, infrastructure protectionLegitimate interests (Art. 6(1)(f))
Establishing or defending legal claimsDisputes, enforcement of our termsLegitimate interests (Art. 6(1)(f))

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms; you may object as described in Section 9. Consumer marketing consent (for the campaigns themselves) is obtained and evidenced by the relevant Affiliate/controller, in accordance with our platform terms.

5. Cookies & tracking technologies

Our websites and Services use cookies, pixels and similar technologies to:

  • Strictly necessary: authentication, security, load balancing (no consent required);
  • Performance tracking: attributing clicks and conversions to campaigns via Trackbooth (first-party where possible, with server-side postbacks preferred);
  • Analytics: understanding how our sites are used, in aggregate.

Where required by law (including the ePrivacy rules in the EU/UK), non-essential cookies are set only with your consent, which you can withdraw at any time through our cookie banner or browser settings. Blocking cookies may limit some features.

6. How we share personal data

We share personal data only as described below, and never sell consumer personal data for money:

  • Within the network: with Advertisers and Affiliates as necessary to run campaigns, verify events, resolve disputes, and investigate compliance issues (including, as stated in our Terms, disclosing an Affiliate's details to an affected Advertiser or authority in the event of a violation).
  • Service providers (processors): hosting and cloud infrastructure, email/SMS delivery infrastructure, payment providers, analytics, customer support tooling, and outside accounting firms - under contracts imposing confidentiality and data protection obligations.
  • Professional advisers: legal counsel, auditors, insurers.
  • Authorities: tax authorities, courts, regulators and law enforcement where required by law or where necessary to protect our rights, our users, or the public.
  • Corporate transactions: in connection with a merger, acquisition, financing or sale of assets, subject to appropriate safeguards.

7. International data transfers

Because we operate a global network, personal data may be transferred to and processed in countries other than your own, including the United States. Where we transfer personal data originating in the European Economic Area, the United Kingdom or Switzerland to countries not deemed to provide an adequate level of protection, we rely on appropriate safeguards, including:

  • the European Commission's Standard Contractual Clauses (SCCs) (2021/914), supplemented where necessary;
  • the UK International Data Transfer Addendum to the SCCs;
  • adequacy decisions where applicable; and
  • supplementary technical and organizational measures (encryption in transit and at rest, access controls, transfer impact assessments).

You may request a copy of the relevant safeguards by contacting [email protected].

8. Data retention

We keep personal data only as long as necessary for the purposes described in this policy, then delete or irreversibly anonymize it. Indicative periods:

  • Account & contract data: for the life of the relationship plus the limitation period for legal claims (typically up to 6 years, or as local law requires).
  • Financial & tax records: as required by applicable tax and accounting law (commonly 6–10 years).
  • Campaign event data: retained in identifiable form as long as needed for billing, dispute resolution and fraud prevention, then aggregated or deleted.
  • Consent records: for as long as the underlying consent is relied upon, plus the limitation period, so consent can be evidenced.
  • Suppression/opt-out lists: retained indefinitely in minimized form, because the law requires us to keep honoring your opt-out.
  • Unsuccessful applications: up to 24 months, unless you ask us to delete them sooner.

9. Your rights (GDPR & worldwide)

If you are in the EEA, UK, Switzerland, or another jurisdiction granting similar rights, you may, subject to legal conditions and exemptions:

  • Access - obtain confirmation of whether we process your personal data and receive a copy (GDPR Art. 15);
  • Rectification - have inaccurate data corrected and incomplete data completed (Art. 16);
  • Erasure - have your data deleted in certain circumstances ("right to be forgotten", Art. 17);
  • Restriction - restrict processing while a dispute or verification is resolved (Art. 18);
  • Portability - receive data you provided to us in a structured, commonly used, machine-readable format (Art. 20);
  • Objection - object to processing based on legitimate interests, and to direct marketing at any time, in which case we will stop (Art. 21);
  • Withdraw consent - where processing is based on consent, withdraw it at any time without affecting prior processing (Art. 7(3));
  • Complain - lodge a complaint with your local supervisory authority (Art. 77). We would appreciate the chance to address your concerns first, but you may contact your authority at any time.

Marketing opt-out: every email delivered through Sendbooth contains a working unsubscribe link, and SMS recipients can reply STOP. Opt-outs are honored well within legal deadlines and propagated across our network suppression lists so you are not contacted again through us.

10. How to exercise your rights

Email [email protected] with the subject "Data Rights Request", telling us which right you wish to exercise and the email address/phone number concerned. We may need to verify your identity before acting. We respond within one month (extendable by two further months for complex requests, with notice), free of charge except where requests are manifestly unfounded or excessive.

Where we act as a processor for an Affiliate or Advertiser, we will forward your request to the relevant controller without undue delay and assist them in responding.

11. Automated decision-making

We use automated systems (including fraud-scoring in Trackbooth) to flag suspicious traffic and events. These flags trigger human review before any decision producing legal or similarly significant effects - such as account termination or payment forfeiture - is made. We do not carry out automated decision-making within the meaning of GDPR Article 22 without appropriate safeguards, and you may request human intervention regarding any such decision.

12. Security

We apply technical and organizational measures appropriate to the risk, including encryption in transit and at rest, role-based access controls, network segregation, logging and monitoring, vendor due diligence, staff confidentiality obligations, and incident response procedures. Suppression lists are technologically fingerprinted and access-restricted. No system is perfectly secure; if a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority and, where required, affected individuals, in line with GDPR Articles 33–34 and other applicable laws.

13. Children's privacy

Our Services are strictly for business users aged 18+ and our network prohibits campaigns directed at children. We do not knowingly collect personal data from anyone under 16 (or the higher age applicable in your jurisdiction). If you believe a child's data has reached us, contact [email protected] and we will delete it.

14. US state privacy rights (CCPA/CPRA and similar)

If you are a resident of California or another US state with a comprehensive privacy law, you may have rights to know, access, correct, delete, and obtain a portable copy of your personal information, to opt out of "sale" or "sharing" of personal information and of targeted advertising, and to non-discrimination for exercising your rights. We do not sell personal information for money. To the extent network attribution activity constitutes "sharing" under the CPRA, you may opt out via [email protected] with the subject "Do Not Sell or Share". Authorized agents may submit requests with proof of authority.

15. Other jurisdictions

We honor applicable rights under other regimes, including Canada's PIPEDA and CASL (express/implied consent and unsubscribe rules for commercial electronic messages), Brazil's LGPD, Australia's Privacy Act and Spam Act, and similar laws. Where local law grants you rights beyond those listed here, we will honor them as required.

16. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date at the top shows the current version. For material changes, we will provide prominent notice (for example, on the platform login page or by email) before the changes take effect. Continued use of the Services after the effective date constitutes acknowledgment of the updated policy.

17. Contact & complaints

Privacy team / Data Protection contact: [email protected]
Compliance: [email protected]
Postal: Bucksbooth - Privacy Office, [registered company address].

EEA/UK individuals: where required by GDPR Article 27 / UK GDPR, details of our EU and UK representatives are available on request. You always retain the right to complain to the supervisory authority in your country of residence, place of work, or where the alleged infringement occurred.

Note for Bucksbooth: before publishing, insert your registered legal entity name, registered address, and (if appointed) your DPO and EU/UK representative details in Section 17. This document is a strong starting framework but should be reviewed by qualified counsel for your specific corporate structure and markets.
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