# Skimlinks Privacy Policy

### Introduction

This Privacy Policy explains what personal and other information is collected by Skimbit Ltd (a company registered in England and Wales with number 06347796 and its registered office at Aldgate House, 2nd Floor, 33 Aldgate High Street, London EC3N 1DL, United Kingdom) (**“Skimlinks”** or **“we”**) as part of its activities, and how Skimlinks uses that information.

Skimlinks recognises that your privacy is very important to you and that it is your right to control your Personal Data, whether you are a Publisher, a Merchant or a User. We recommend that you read this Privacy Policy in full to ensure that you are fully informed. To make it easier for you to review those parts of the Privacy Policy which apply to you, we have divided up this Privacy Policy into the following sections – please take the time to read Section 1 (General) and, if you are a Publisher, Merchant or User, the Section which applies to you.

Section 1 – General (applicable to everyone)

Section 2 – Publishers

Section 3 – Merchants

Section 4 – Users

Section 5 – U.S. State Privacy Notice

In this Privacy Policy, the following expressions have the following meanings:

“Advertiser” |
an entity purchasing advertising or marketing services from Skimlinks directly or through an agent. |

“Agreement” |
an agreement between (i) a Publisher or a Merchant and (ii) Skimlinks. |

“Computer” |
a device used for accessing digital information including but not limited to desktops, laptops, tablets, mobile phones and other connected devices. |

“Merchant” |
a supplier of goods and/or services to Users, or individuals representing such a supplier, which may also be authorised by Skimlinks to access and use the Service under the terms of an Agreement. |

“Merchant Core Tools” |
means Skimlinks Code as used by a Merchant to enable tracking, analytics and marketing functionality. |

“Optional Tools” |
means (i) SkimWords (ii) Network Overwrite (iii) URL Shortener (iv) Link Generator (v) Skim RSS BETA (vi) Skimlinks APIs (URL Shortener API, Merchant API and Reporting API BETA), and (vii) such additional or alternative proprietary or third party software tools that Skimlinks may launch from time to time. |

“Personal Data" |
information we collect about you or your device when you visit our websites or Skimlinks Enabled Sites or interact with our Service that is considered personal information or personal data as those terms are defined by applicable privacy laws. |

“Publisher” |
a person or other entity who is entitled to access and use the Service under the terms of an Agreement, or individuals representing such a person or entity. |

“Publisher Core Tools” |
means (i) Skimlinks Code and (ii) Link API, either of which Publishers can use to affiliate Merchant links with the purpose of earning Publisher Commissions and obtaining insights via the Publisher Hub. |

“Publisher Hub” |
Skimlinks’ proprietary, login-protected web portal that may be accessed by Publishers at www.skimlinks.com to access and configure Tools, view performance and billing reports, and search for participating Merchants. |

“Service” |
access to and use of (i) the Publisher Hub and (ii) the Tools. |

“Skimlinks Code” |
is computer code which, when added to a web page or a global footer, enables the Service on a Skimlinks Enabled Site. |

“Skimlinks Enabled Site” |
a Publisher’s or a Merchant’s website running one or more Tools. |

“Tools” |
means Publisher Core Tools, Optional Tools and Merchant Core Tools or, as the context requires, any of them. |

“Usage Data” |
data collected or created by the use of the Service, including but not limited to device type, browser-type, operating system, internet provider, your ip address, domain name, the web pages that you visit or have visited, the actions that you take on those websites, the date and time of your visits, broad geographic location (e.g. country or city-level location) and other technical information. |

“User” |
an end-user experiencing one or more of the Tools on a Skimlinks Enabled Site. |

“You” |
anyone who interacts with our website, including Publishers and Users. |


### Section 1: General

This section applies to everyone who visits, or otherwise interacts, with our website or Skimlinks Enabled Sites.

**How we keep your Personal Data secure**

We use appropriate technical and organisational measures to protect the Personal Data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Specific measures we use include storing your Personal Data on secure, firewall-protected servers that are located in secure facilities. These technology and security features, as well as strict internal guidelines, are designed to safeguard the privacy of your Personal Data from unauthorised access or improper use. We will continue to enhance security as new technology becomes available. Access to your Personal Data is only granted to Skimlinks staff who require such access. Backups are run to reduce the risk of loss of information, and our Internet servers are housed in secure facilities. We have security measures in place to protect our customer database and access to this database is restricted internally. While we take the steps described above to ensure that your information is secure on our system, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

**International data transfers**

Your Personal Data may be transferred using Skimlinks’ content distribution network to, and processed in, countries other than the country in which it has been collected or in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our website servers, our Service servers and third party service providers and partners operate in the EMEA, Asia and the USA. This means that when we collect your Personal Data we may process it in any part of these regions or countries.

However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Policy.

All our data transfers are safeguarded by applicable transfer mechanisms, such as Standard Contractual Clauses and Data Processing Agreements, where this is required by applicable data protection laws.

**Your data protection rights**

Depending on where you reside, you may have the following data protection rights under applicable data protect laws:

- If you wish to
**access, correct, update or request deletion**of your Personal Data, you can do so at any time by contacting us using the contact details provided under the “Contacting Skimlinks” heading below. - In certain circumstances, you can
**object to processing**of your Personal Data, ask us to**restrict processing**of your Personal Data or request portability of your Personal Data. Again, you can exercise these rights by contacting us using the contact details provided under the “Contacting Skimlinks” heading below. - You have the right to
**opt-out of marketing communications**we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “Contacting Skimlinks” heading below. - Similarly, if we have collected and process your Personal Data with your consent, then you can
**withdraw your consent**at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent. - You have the
**right to complain to a data protection****authority**about our collection and use of your Personal Data. For more information, please contact the UK Information Commissioner’s Office.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

**How we use cookies on our website**

A cookie is a small text file that is stored on a user’s Computer for tracking and record-keeping purposes. We use both session ID cookies and persistent cookies, further details of which can be obtained here. We use session cookies to make it easier for you to navigate our website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies via your browser’s ‘clear cookie’ function. Please see allaboutcookies.org for more information about blocking cookies on your particular web browser.

Before dropping cookies onto your Computer for which consent is needed we will display a banner and give you the option to proceed or not and let you know what constitutes consent. This consent request will vary by the country you access the website from.

Persistent cookies enable us to track and target your interests to enhance your experience on our website and, if applicable, the Publisher Hub. For example, we use this data to understand how you interact with our website so we can make improvements to the information and design of our website.

**What Personal Data does Skimlinks collect and why?**

The Personal Data that we may collect about Publishers broadly falls into the following categories:

**Information that you provide voluntarily**

Certain parts of the Service may ask you to provide Personal Data voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data.

**Information that we collect automatically**

When you use the Service and/ or our website, we may collect certain information automatically from your Computer. In some countries, including countries in the European Economic Area, this information may be considered Personal Data under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, unique device identification numbers and Usage Data. We may also collect information about how your device has interacted with the Service and/ or our website. Collecting this information enables us to better understand how the Services are used. We use this information for our internal analytics purposes and to improve the quality and relevance of the Service and/ or our website to Publishers, Merchants and Users.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “How we use cookies on our website” above.

In general, we will use the Personal Data we collect from you only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your Personal Data. However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

**What we share with third parties**

We use third parties’ analytics technologies which involve cookies being dropped via our website and the collection of Usage Data, so we can understand how you use our website. We do not have access to or control over these cookies, but please see here for more information on these cookies.

**Who do we share your Personal Data with?**

We may disclose your Personal Data to the following categories of recipients:

- to our
**third party services providers and partners**who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or process Personal Data for content customization, personalization, ad selection and ad delivery and reporting, measurement purposes or who otherwise process Personal Data for purposes that are described in this Privacy Policy or notified to you when we collect your Personal Data; - to any
**competent law enforcement body, regulatory, government agency, court or other third party**where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person; - to an
**actual or potential buyer**(and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Data only for the purposes disclosed in this Privacy Policy; - in order to enforce or apply Skimlinks’ Terms of Service, or to protect the rights, property, or safety of Skimlinks, our customers, or others. This includes exchanging information with other companies and organisations for the purpose of fraud protection and credit risk reduction.
- to any other person with your consent to the disclosure.

**Legal basis for processing Personal Data**

Our legal basis for collecting and using the Personal Data described in this Privacy Policy will depend on the Personal Data concerned and the specific context in which we collect it.

However, we will normally collect Personal Data from you only where (i) we have your consent to do so, (ii) we need the Personal Data to perform a contract with you, or (iii) the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you. If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our Services and for our commercial interests, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please let us know.

**Privacy Self-Regulation
**Skimlinks is dedicated to providing Internet users the highest level of transparency and control over the use of their data in online advertising. We adhere to the and follow the guidelines provided by the EDAA's European Industry Self-Regulatory framework on Data-Driven Advertising. More information about the EDAA's European Principles is available here. Skimlinks also participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies as vendor number 46. For more information on the privacy self-regulation commitments of our affiliate, Taboola, please visit their Privacy Policy (accessible here)

**Changes to this Privacy Policy**

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments, so please review it frequently. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If we make material changes to this policy, we will notify Publishers and Merchants by means of a notice on the Publisher Hub.

**Contacting Skimlinks**

If you have any questions about this Privacy Policy, our practices, or your dealings with Skimlinks, you can contact us or contact our data protection officer at dpo@skimlinks.com or at the following address;

Skimbit Ltd t/a Skimlinks

Aldgate House, 2nd Floor

33 Aldgate High Street

London EC3N 1DL, United Kingdom

**Data Protection Service**

You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s web site at: https://ico.org.uk/for-the-public/.

### Section 2: Publishers

This section describes what information is collected by Skimlinks from Publishers, and how that information is used by Skimlinks.

**What information we collect from Publishers**

When a Publisher signs up to use the Service, we collect and store various pieces of Personal Data, including:

- Full name of the Publisher and, if different, the name of the Publisher contact
- Email address
- Telephone number
- Website information
- Bank/PayPal details
- Payment & VAT Information
- Address

We also collect and store information about when and how a Publisher uses the Publisher Hub, including reports and other tools and interfaces provided by us.

**How we use Publisher information**

We use this Publisher information to perform our obligations under the Agreement, including:

- To assess the suitability of Skimlinks Enabled Sites for the Service
- To contact Publishers to help them with registration, use and optimisation of the Service
- To pay Publishers their share of the commissions earned through the Service
- To communicate with Publishers on Skimlinks-related matters
- To provide Publishers with performance and billing information
- To improve the service we provide to Publishers based on how Publishers use our service and the tools which we provide to them.
- To introduce Merchants and Advertisers who may wish to purchase services from or partner with the Publisher.

**Updating Publisher information**

Publishers can edit any of their Personal Data within the Publisher Hub. It is the Publisher’s responsibility:

- To protect against unauthorised access to their details and the Publisher Hub
- To log-off from the Publisher Hub when not using it
- To keep its password secret.

**What does Skimlinks do on Skimlinks Enabled Sites?**

Once a Publisher’s application to use the Service is accepted, and the Publisher has added the Skimlinks Code to its Skimlinks Enabled Site template, a JavaScript file will be downloaded to Users’ Computers when they view Skimlinks Enabled Sites. Depending on which of the Tools has been enabled via the Publisher Hub, this JavaScript file will do the following:

- Collect and store information about Users behaviours on a site (including impressions and links clicked), so we can monetise such behaviours from participating Merchants, and report on them for Publisher and Merchant reports.
- Collect and store information about Skimlinks Enabled Sites, to provide the Service.
- Outside of the UK and EMEA, and solely in respect to Users of Skimlinks Enabled Sites of certain Publishers (as indicated in the Terms of Service, Skimlinks and its affiliates (the "Skimlinks Group") stores or reads a cookie when the User visits such Skimlinks Enabled Sites or clicks on content on such Skimlinks Enabled Sites, in order to optimize, personalize, analyze and recommend content to these Users. More information about how this automated means of data collection works and how this data is handled, including how to opt-out, can be found at the Privacy Policy of Skimlinks' affiliate company, Taboola (accessible here)

**What information relating to Users does Skimlinks collect?**

Skimlinks will not knowingly collect or store any information which enables us to determine the actual identity of Users visiting a Skimlinks Enabled Site.

The Skimlinks Group uses cookies, other automated means or data collection and web beacons to collect Usage Data relating to Users. This Usage Data is used by Skimlinks to optimize the performance and yield of the Service, to provide comprehensive reporting to Publishers, and to provide reporting to Merchants, Advertisers and other third parties. Usage Data cannot generally be used to identify a specific person.

Outside of the UK and EMEA, and solely in respect to Users of Skimlinks Enabled Sites of certain Publishers (as indicated in the Terms of Service), Skimlinks' affiliate, Taboola, stores or reads a cookie when a User visits a web page or clicks on content on a publisher's properties, in order to optimize, personalize, analyze and recommend content to Users. More information about how the data collected, including how to opt-out, can be found at the Privacy Policy of Skimlinks' affiliate company, Taboola (accessible here)

For more information regarding cookies, please see Section 1 of this Privacy Policy.

The Skimlinks Group provides an opt-out mechanism for Users who do not wish for their Usage Data to be used for advertising targeting purposes, to the extent such Users are targeted through the use of a Skimlinks Group cookie.

This opt-out is accessible here, which includes a link to the Privacy Policy of Skimlinks' affiliate, Taboola (accessible here), where more information can be found about Taboola and how it handles Users' data, including how to opt out of Taboola's cookie used for advertising targeting purposes. It is the Publisher’s responsibility to provide their Users with this option.

**Do Publishers need to update their own privacy policies if they use Skimlinks?**

It is the responsibility of the Publisher to ensure that its privacy policy, ‘About Us’ or other relevant website section includes the following information, and that the Publisher gives notice to each User (whether in a privacy policy or otherwise) containing these provisions:

- A statement regarding use of the Service on the Skimlinks Enabled Site(s). For example:

*“Our website contains some affiliate marketing links, which means we get paid commission on sales of those products or services we write about. Our editorial content is not influenced by advertisers or affiliate partnerships. We use Skimlinks and more information about their data collection is set out in their privacy policy at https://skimlinks.com/privacy-policy”*

*To the extent the Skimlinks Group processes your personal data when provide affiliate marketing links, we act as controllers in respect of this data. Details regarding our controller arrangement can be requested using the contact details set out in section [x].*

- Full details about cookies, or automated means of data collection, used by the Skimlinks Group onto Users’ Computers when Users view a web page or click on an affiliate link on Skimlinks Enabled Sites. Publishers must at a minimum include the information that can be found in Section 4 below under the heading of
*‘What information does Skimlinks collect about Users through its technology and how does it use this information?’*. Publishers should also provide a link for Users with information regarding how they can disable any use of Skimlinks Group cookies used for targeted advertising, as set out in Section 4 below under the heading of*‘How can I disable Skimlinks cookies?’*.

If the Publisher is based in the European Union, or offers goods and services to customers in the European Union, the Publisher must also seek the consent of Users before Skimlinks cookies are dropped via their Skimlinks Enabled Site and to certain uses of their personal data (including audience tracking and some affiliate marketing activities). We will from time to time notify Publishers of the use which will require consent. Publishers can decide how to obtain consent but Skimlinks suggests that:

- In relation to cookies or other automated means of data collection, users are requested to consent to the terms of the Publisher’s Privacy Policy, either the first time a user’s device arrives on a Skimlinks Enabled Site. After initial provision of consent by a User, it need not be provided again, unless the purpose of cookies dropped, or other automated means of data collection used, via Skimlinks Enabled Sites is changed, or the consent expires as per the period that was declared. If Skimlinks makes relevant changes to its cookies, or other automated means of data collection, we will notify you accordingly.
- In relation to processing for those uses notified to Publishers as requiring consent, Publishers should consider using a consent management platform.

For U.S. properties, the Publisher must insert a link to the DAA opt-out program (currently available at https://www.aboutads.info/choices) and the NAI opt-out program (currently available at https://www.networkadvertising.org/choices/).

For EU/EEA properties, the Publisher must insert a link to the EDAA opt-out program (currently available at https://www.youronlinechoices.eu/).

For properties in other regions, if the above rules are not sufficient for compliance with local legislation or regulation, please provide a link to this Privacy Policy.

**What we share with third parties**

We may share with certain key partners and advertisers some anonymous Publisher information in order to optimise our Advertiser and Merchant relationships and increase revenue yields for Publishers.

We may disclose your personal data to third parties:

- In the event that Skimlinks identifies a Merchant with which a Publisher could have a commercial relationship, to make introductions.

**Data retention**

We retain Personal Data we collect from the Publisher indefinitely for fraud prevention and regulatory compliance.

### Section 3: Merchants

This section describes what information is collected by Skimlinks from Merchants, and how that information is used by Skimlinks.

**What information we collect from Merchants**

When a Merchant signs up to use the Service, we collect and store various pieces of Personal Data, including:

- Full name of the Merchant and, if different, the name of the Merchant contact
- Email address
- Telephone number
- Website information
- VAT Information
- Address

**How we use Merchant information**

We use this Merchant information to perform our obligations under the Agreement, including:

- To assess the suitability of the Merchant for the Service
- To contact Merchant to help them with registration, use and optimisation of the Service
- To communicate with Merchants on Skimlinks-related matters
- To provide Merchants with order and billing history information
- To improve the service we provide to Merchants based on how Merchants use our service and the tools which we provide to them.
- To introduce Publishers who may wish to enter into agreements with the Merchant.

**What we share with third parties**

We may disclose your personal data to third parties:

- In the event that Skimlinks identifies a Publisher with which a Merchant could have a commercial relationship, to make introductions.

**Data retention**

We retain Personal Data we collect from the Merchant indefinitely for fraud prevention and regulatory compliance.

### Section 4: Users

This section explains how Skimlinks operates through Skimlinks Enabled Sites, and how information about Users is obtained and used by Skimlinks.

**What is Skimlinks?
**Skimlinks offers a service to Publishers to help them earn an income and gain insights from their commerce-related content. The service works by creating/tagging links within content that a User is reading which, if clicked, takes the User to a Merchant website where the products and/or services can be purchased. If the User then buys something as a result of clicking on these links, the Publisher is paid a referral fee by the Merchant through Skimlinks. This referral fee does not come out of Users’ pockets, nor does it affect the price Users pay or the experience Users have on the Merchant’s site.

**What information does Skimlinks collect about Users through its technology and how does it use this information?**

- We store anonymized Users’ IP addresses, from which we can determine a User’s approximate geographical location (e.g. country or region) prior to anonymizing. We need this information to optimize the links that are created/monetized to suit the geography of the User, and to provide aggregate reporting to Publishers, Merchants and Advertisers on the location of users visiting Skimlinks Enabled Sites. We also use IP addresses as part of our efforts to reduce fraud and identify non-human browsing patterns.
- We store information about the device that a User uses to access sites within our Publisher network, such as the browser type, browser version, and type of device. This helps us ensure we can diagnose and fix browser compatibility issues more swiftly, optimize our service to suit the preferred browsing environments, and provide aggregate reporting to Publishers, Merchants and Advertisers.
- Information regarding the cookies we utilise on Skimlinks Enabled Sites can be found here
- As part of the information available in standard web serving logs, we also store information about the referrer, i.e. the website page from which the User linked to the Skimlinks Enabled Site.
- To provide Publishers and Merchants with the Service, we collect information on visits and sales on Skimlinks Enabled Sites, including but not limited to order value, products bought, and order identifiers. These are used to help Publishers, Merchants and Advertisers make better marketing and content creation decisions.
- At no time do we know who a User is, nor do we make any attempt to try and identify a User.

The Skimlinks Group uses cookies or other automated means of data collection to collect the information we need to optimise the product/Merchant links we monetize/create, and improve the service we provide to Publishers, Merchants, Advertisers and Users.

Outside of the UK and EMEA, and solely in respect to the Users of Skimlinks Enabled Sites of certain Publishers (as indicated in the Terms of Service), Skimlinks' affiliate, Taboola, stores or reads a cookie when a User visits a web page or clicks on content on such Skimlinks Enabled Sites, in order to optimize, personalize, analyze and recommend content to Users. More information about this automated means of data collection works and how this data is handled, including how to to opt-out, can be found at the Privacy Policy of Skimlinks' affiliate company, Taboola (accessible here).

**How can I disable Skimlinks cookies?**

If you no longer want the Skimlinks Group to use a cookie to target advertising to you, you can opt-out here (which includes a link to the Privacy Policy of Skimlinks' affiliate company, Taboola (accessible here), from where you can opt-out of Taboola's cookie used for optimization, personalization and analysis and recommending content) or by e-mailing at dpo@skimlinks.com. This will mean the Skimlinks Group will not drop Skimlinks Group cookies when you browse websites in our Publisher or Merchant network.

U.S. visitors can understand more about cookies and their choices at these websites:

EU/EEA visitors can understand more about cookies and their choices at https://www.youronlinechoices.eu/

If you opt-out of Skimlinks cookies, Skimlinks will still operate on pages that you visit, and still create monetizable links in content if the Publisher has chosen to install Skimlinks on its website. We just won’t optimise these links based on your preferences and behaviours, nor will we associate the websites you visit and shop from to a specific cookie.

In order for referral fees and commissions to be paid by Merchants to Publishers, Skimlinks works with Affiliate Networks and other ad networks that manage the relationships between Skimlinks and the Merchants. As set out above, Users who receive Skimlinks cookies are also assigned a unique identifier number.

When a User clicks on a link created by a Tool, Skimlinks attaches the User’s unique identifier number so it passes to the appropriate affiliate network for the purpose of tracking whether that User makes a purchase on the Merchant website they visit. Note that at no time during this process do we pass any Personal Data, nor make any attempt to determine the actual identity of an individual User; all information is completely anonymous and used only for the purposes of optimizing the service provided to the User. The affiliate and ad networks that work with Skimlinks also use their own cookies in order to track if a sale has occurred, as most of these parties will only pay Publishers when a referral has been successful, i.e. a sale was completed. We do not have control over or access to these cookies and they are dropped by the affiliate and ad networks via our Skimlinks Enabled Sites.

**Data retention**

We retain Personal Data (in anonymized form) that we collect from you for up to three years. After that we will either delete it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

### Section 5: U.S State Privacy Notice

**Your rights under U.S. State Privacy Laws
**If you are a resident of a U.S. State covered by U.S. State Privacy Laws granting you privacy rights in relation to Personal Data (“Consumer” or “you”), this U.S. State Privacy Notice explains how to exercise rights you may have. “U.S. State Privacy Laws” include the California Consumer Privacy Act, the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Marketing, the Nevada Senate Bill 220, the Virginia Consumer Data Protection Act, and any similar U.S. state law when and if such law(s) have taken effect. This Privacy Notice is intended solely for, and is applicable as to Consumers. If you are not a Consumer, this does not apply to you and you should not rely on it.

**Personal Data we collect about Consumers
**We may collect the following categories of information summarized in the table below:

Our Personal Data Collection Practices

Category |
Examples |

“Identifiers” |
unique personal identifier, Internet Protocol address |

“Commercial Information” |
records of purchase order value |

“Internet of other similar network activity” |
information about categories of consumer interests derived from online usage, and information on a consumer's interaction with a website, application, or advertisement |

“Geolocation Data” |
Internet Protocol address |


Please note that, when you interact with our Publishers’ Skimlinks Enabled Sites, the information we collect above is anonymized prior to storage in our systems so that it cannot be linked to you.

Furthermore, when you interact with our Publishers’ Skimlinks Enabled Sites, our affiliate, Taboola, may collect the above information, as mentioned above. Please see the state-specific notice of Regional Privacy Rights section in Taboola’s Privacy Policy at https://www.taboola.com/policies/privacy-policy#regional-privacy-rights for more information about how Taboola collects, uses, and discloses your personal information and how you may exercise rights that may be applicable to you.

In addition, we may collect Personal Data from job applicants, current or former employees, owners, directors, officers, and contractors (and emergency contacts for the foregoing), from CRM tools, and from business to business communications or transactions. The categories of Personal Data may include those listed above as well as those listed in Cal. Civ. Code § 1798.80(e) and professional or employment-related information.

**Our Disclosure and/or Sale or Share of Personal Data
**Skimlinks has not disclosed, sold or shared Personal Data in the categories of information identified above to third parties (based on U.S. State Privacy Laws’ definition of “sell” and “share”) in the prior 12 months.

**Our Purposes for Collecting and Disclosing Personal Data
**Generally speaking, we collect and disclose the Personal Data that we collect for the following purposes:

-
-
- Developing new products and improving our services.
- Providing analytics regarding the effectiveness of online ad campaigns, including by reporting on the number of ads viewed and actually clicked (or swiped) on, and if the consumer purchased any items from the advertisers.
- Auditing.
- Detecting security incidents and protecting against malicious or fraudulent activity (and, if necessary, prosecuting those responsible).
- Quality control and debugging.
- Short-term and transient use.
- Internal research.
- Supporting employment, infrastructure and human resource management (e.g., processing employment applications, providing benefits to employees and dependents, managing compensation, operating facilities and infrastructure).
- Conducting business to business relationships.
- Fulfilling or meeting the reason you provided the information.
- Complying with our legal obligations.


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For information about what Personal Data our parent company, Taboola, collects when you interact with Skimlinks, and discloses, please see the state-specific notice of Regional Privacy Rights section in Taboola’s Privacy Policy at https://www.taboola.com/policies/privacy-policy#regional-privacy-rights, including how you may exercise rights that may be applicable to you.

**Your Rights and Choices
**The U.S. State Privacy Laws provide Consumers with specific rights regarding their Personal Data. This section describes your U.S. State Privacy Laws rights and explains how to exercise those rights. You have the right not to receive discriminatory treatment by us for the exercise of such rights.

Right to Opt-out of the sale or sharing of your Personal Data: Consumers may opt out of the “sale” or “sharing” of their Personal Data. If you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales or sharing. You may “opt out” of our “sale” or “sharing” of your Personal Data (as those terms are defined by the U.S. State Privacy Laws) by clicking here (which includes a link to the Privacy Policy of Skimlinks’ affiliate company, Taboola (accessible here), from where you can opt-out of Taboola’s cookie used for optimization, personalization, analysis, and recommending content) or by e-mailing us at dpo@skimlinks.com.

Access to Specific Information and Data Portability Rights: You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your Personal Data over the past 12 months.

Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), we will disclose to you the specific pieces of Personal Data that we have collected from you. However, we may withold some Personal Data where the risk to you or our business is too great to disclose the Personal Data, or where we cannot verify your identity in relation to such Personal Data. Thus, for security purposes (and as required under U.S. State Privacy Laws), we will verify your identity – in part by requesting certain information from you – when you request to exercise your U.S. State Privacy Laws privacy rights.

Deletion Request Rights: You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), and provided we have Personal Data about you, we will delete (and direct our service providers to delete) your Personal Data from our records unless an exception applies.

Right to Correct Inaccurate Personal Data: You have the right to request that we correct Personal Data that we maintain about you, taking into account the nature of the Personal Data and the purpose of the processing of the Personal Data. Once we receive your verifiable consumer request (see “Exercising Access, Data Portability, Deletion, and Correction Rights” below), we will use commercially reasonable efforts to correct the inaccurate Personal Data, if any, as directed by you.

Exercising Access, Data Portability, Deletion, and Correction Rights:

**How to submit requests:**

To exercise the access, data portability, deletion and correction rights described above, please submit a verifiable consumer request to us by visiting skimlinks.com or via e-mail at dpo@skimlinks.com.**Who may submit requests:**

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may designate an authorized agent to make a request on your behalf by verifying your own identity with us and providing a copy of written authorization from the agent to act on your behalf or other validation method used by us to confirm that an agent has been authorized to act on behalf of a consumer**How often can you submit requests:**

You may only make a verifiable consumer request for access or data portability twice within a 12-month period**How we verify and respond to requests:**

Your request must be verifiable. This means that you, or your authorized agent, must provide sufficient information that allows us to reasonably verify that you are the person about whom we collect personal information or an authorized representative of that personal. We may verify your request:- If you have a password protect account with us, we may verify your request using our existing authentication practices for that ccount
- For request to know or have Personal Data deleted, by requiring you to provide us at least two data points, depending on the type of Personal Data in question.


Your verifiable consumer request must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

**Reponse Timing and Format:**

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reason why we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindranace.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

**Non-Discrimination
**We will not discriminate against you for exercising any of your U.S. State Privacy Laws rights. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.

**Other California Privacy Rights
**California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information set forth below in Section “

*Who to contact for more information*”.

**Who to contact for more information
**For questions or concerns about our privacy practices, you can contact us or contact our data protection officer at dpo@skimlinks.com or at the following address:

Skimbit Ltd t/a Skimlinks

Aldgate House, 2nd Floor

33 Aldgate High Street

London EC3N 1DL, United Kingdom


*This Privacy Policy was last updated on 11.01.2024*

If you have a question or any concerns about our Privacy Policy, please let us know.