Privacy Policy

Last updated: January 1, 2026

1. Introduction

Partner Commerce, Inc. (“Partner Commerce,” “we,” “us,” or “our”) is committed to protecting the privacy of visitors to partnercommerce.com and the clients and partners we serve. This Privacy and Cookies Policy explains how we collect, use, store, and share personal data in connection with our website and our affiliate marketing management services.

This policy applies in two contexts:

As a data controller – when we determine the purposes and means of processing personal data collected through our website, marketing activities, and business operations.
As a data processor – when we process personal data on behalf of our clients as part of delivering affiliate marketing management services. See Section 8 for details on our processor role.

By using our website or engaging our services, you acknowledge the practices described in this policy. If you have questions, contact us using the details in Section 13.

2. How We Use Your Personal Data

We collect and process the following categories of personal data:

Website Usage Data

We collect data about how you use our website, including IP address, browser type and version, operating system, referral source, pages visited, and session duration. This data is processed to monitor and improve our website and services. The legal basis is our legitimate interests in maintaining a functional and secure website.

Account and Inquiry Data

When you contact us, complete a form, or request information about our services, we collect your name, email address, phone number, company name, job title, and the content of your inquiry. This data is processed to respond to your inquiry, provide our services, and manage our business relationship. The legal basis is our legitimate interests in operating our business and, where applicable, the performance of a contract.

Marketing and Newsletter Data

If you subscribe to our newsletter or opt in to marketing communications, we collect your email address and communication preferences. The legal basis for this processing is your consent. You may withdraw consent at any time by clicking “unsubscribe” in any marketing email or contacting us directly.

Correspondence Data

We retain records of communications we exchange with you, including emails and form submissions, along with associated metadata. The legal basis is our legitimate interests in maintaining accurate business records and managing ongoing relationships.

Recruitment Data

If you apply for a position at Partner Commerce, we collect the personal data contained in your application, including resume, contact details, work history, and references. This data is processed solely for recruitment purposes and retained in accordance with applicable law. The legal basis is our legitimate interests in evaluating candidates and, where applicable, compliance with legal obligations.

Data Categories We Collect

Category	Examples	Legal Basis
Identity data	First name, last name, job title	Legitimate interests / Contract
Contact data	Email address, phone number, company	Legitimate interests / Contract
Technical data	IP address, browser type, inferred location	Legitimate interests
Usage data	Page views, content downloads, session data	Legitimate interests
Marketing data	Email preferences, subscription status	Consent
Recruitment data	Resume, references, work history	Legitimate interests / Legal obligation

Third-Party Tools We Use to Store Data

Personal data collected through our website and business operations may be stored and processed in the following systems: Google Workspace, HubSpot, Slack, Notion, and Impact.com. A full list of our sub-processors is available upon request by contacting [email protected].

3. Automated Decision-Making

We may use automated tools to send relevant email communications based on actions you take on our website, such as downloading content or registering for a webinar. This automation determines the timing and relevance of outreach but does not make decisions that produce legal or similarly significant effects on you.

No fully automated decision-making that significantly affects your rights or interests is carried out without human review.

4. Providing Your Data to Others

We do not sell personal data to third parties. We may share your personal data in the following circumstances:

Service providers and sub-processors – we share data with vendors who help us operate our business, such as CRM platforms, email marketing tools, and project management software. These parties are contractually required to protect your data and may only use it for the purposes we specify. A list of our current sub-processors is available upon request by contacting [email protected].
Group companies – we may share data with affiliates and subsidiaries of Partner Commerce, Inc. to the extent necessary for our legitimate business purposes.
Professional advisors – we may share data with legal counsel, insurers, auditors, and other advisors where necessary to protect our legal rights or comply with regulatory requirements.
Legal obligations – we may disclose data where required by law, court order, or governmental authority, or where we believe disclosure is necessary to protect the safety or rights of any person.
Business transfers – in the event of a merger, acquisition, or sale of all or part of our business, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

5. International Transfers of Your Personal Data

Partner Commerce, Inc. is headquartered in the United States. Personal data we collect is primarily stored and processed in the United States. To deliver our services globally, we may transfer personal data to, or access it from, countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Transfers from the EEA, United Kingdom, and Switzerland

Where we transfer personal data from the European Economic Area (EEA), the United Kingdom, or Switzerland to countries that have not been deemed to provide adequate protection, we rely on appropriate safeguards, including:

Standard Contractual Clauses (SCCs) as adopted by the European Commission
The UK International Data Transfer Agreement (IDTA) for transfers from the United Kingdom
Equivalent mechanisms as required by Swiss law

Our key sub-processors, including Google Workspace, HubSpot, Slack, and Notion, maintain their own transfer mechanisms and data processing agreements in compliance with applicable data protection law.

To request a copy of our data transfer mechanism documents, please contact our privacy team at the address in Section 13.

6. California Residents

Partner Commerce, Inc. complies with the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). California residents have the following rights with respect to their personal information:

Right to know – the categories and specific pieces of personal information we have collected about you, the sources, our purposes, and the categories of third parties with whom we share it.
Right to delete – request deletion of personal information we hold about you, subject to certain exceptions.
Right to correct – request correction of inaccurate personal information.
Right to opt out – opt out of the sale or sharing of personal information. We do not sell personal information to third parties.
Right to limit – limit the use and disclosure of sensitive personal information.
Right to non-discrimination – we will not discriminate against you for exercising any of these rights.

To exercise these rights, submit a request by emailing [email protected] with the subject line “California Privacy Request” or by mailing:

Partner Commerce, Inc.
Attn: Privacy – California Request
1771 Post Rd E, Suite 126
Westport, CT 06880
United States

We will confirm receipt of your request within 10 business days and respond within 45 days. Where additional time is required, we will notify you. We may ask you to verify your identity before processing your request.

7. Other State Privacy Rights

Residents of other US states, including Virginia, Colorado, Connecticut, Texas, and others with enacted privacy legislation, may have similar rights to access, correct, delete, or opt out of processing of their personal data. To inquire about exercising these rights, contact us at [email protected].

8. Retaining and Deleting Personal Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting obligations.

General retention guidelines:

Website usage and analytics data – up to 26 months from collection
Contact and inquiry data – for the duration of our business relationship and up to 3 years thereafter
Marketing data – until you withdraw consent or opt out
Recruitment data – up to 12 months following the conclusion of a recruitment process unless otherwise required by law
Contract and financial records – as required by applicable law, typically 7 years

When personal data is no longer required, we securely delete or anonymize it in accordance with our Data Retention and Disposal Policy.

9. Our Role as a Data Processor

Important: When Partner Commerce processes data on behalf of clients as part of delivering affiliate marketing management services, we act as a data processor, not a data controller. In this capacity, we process data only on the documented instructions of our clients.

This Privacy Policy does not govern our processing of personal data in our capacity as a data processor. Our legal obligations in that context are set out in the data processing agreement (DPA) or equivalent contractual arrangement between Partner Commerce and the relevant client.

If you are an individual whose data has been processed by Partner Commerce on behalf of one of our clients and you wish to exercise your privacy rights, please contact the relevant client directly, as they are the data controller responsible for your data.

In certain circumstances, Partner Commerce may act as a data controller with respect to personal data we collect independently – for example, affiliate partner contact data we collect in the course of recruiting partners for client programs. Where this is the case, we will process that data in accordance with this Privacy Policy and applicable law.

10. About Cookies

A cookie is a small file stored on your browser by a web server. Cookies allow websites to recognize your browser across visits and store preferences or session information.

Cookies We Use

Type	Purpose	Examples
Essential	Required for the website to function. Cannot be disabled.	Session cookies, CSRF tokens
Analytics	Help us understand how visitors use the site to improve performance.	Google Analytics
Marketing	Track visits across sites to deliver relevant advertising.	LinkedIn Insight, Google Ads
Preferences	Remember your settings and choices.	Language, cookie consent

Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our website. For guidance, visit your browser’s help documentation:

Do Not Track

Our website does not currently respond to Do Not Track (DNT) browser signals. We will update this section if our practices change.

11. Amendments

We may update this policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date at the top of this page and, where appropriate, notify you by email or through a prominent notice on our website.

We encourage you to review this policy periodically to stay informed about how we protect your information.

12. Your Rights

Depending on your location, you may have the following rights with respect to your personal data:

Right of access – request a copy of the personal data we hold about you
Right to rectification – request correction of inaccurate or incomplete data
Right to erasure – request deletion of your personal data, subject to legal retention obligations
Right to restrict processing – request that we limit how we use your data in certain circumstances
Right to data portability – request a copy of your data in a structured, machine-readable format
Right to object – object to processing based on our legitimate interests
Right to withdraw consent – where processing is based on consent, withdraw it at any time without affecting prior processing

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days, or within the timeframe required by applicable law. We may ask you to verify your identity before processing your request.

If you are located in the EEA or UK and are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

13. Contact & Legal and Privacy Contact

For questions about this Privacy Policy, to exercise your rights, or for any privacy-related concern, please contact us:

Partner Commerce, Inc.
1771 Post Rd E, Suite 126
Westport, CT 06880
United States
Email: [email protected]
Phone: (800) 214-2907

Legal and Privacy Contact

Partner Commerce has designated a Legal and Privacy Contact for data protection inquiries. If you have a concern relating to the processing of your personal data, or wish to exercise your rights under GDPR or other applicable law, please contact:

Legal and Privacy Contact
Partner Commerce, Inc.
1771 Post Rd E, Suite 126
Westport, CT 06880
United States
Email: [email protected]