Privacy Policy

## 1. Controller and Contact glowDOLLARS is operated by Glow Productions. If you have any privacy question or wish to exercise a right described below, contact us at info@glowdollars.com. This Privacy Policy should be read alongside our Terms of Service and Affiliate Agreement, which govern your participation in the affiliate program. ## 2. Information We Collect We collect the following categories of personal information: **Identity and account.** When you sign up as an affiliate, we collect your name, email address, and a hashed password (managed through our authentication provider, Better Auth). We also record sign-in events, IP address, device, and session metadata needed to operate and secure your account. **Affiliate and payout data.** Your affiliate record, referral links, click and conversion attribution, commissions, balance, payout method and details, and payout history are managed through our attribution and payout partner, Partnero. **Voluntary contact and support submissions.** When you contact us through our contact or support forms, we collect the name, email, topic or department, message, and any file attachments you choose to send. **Automatic data.** When you use the site we collect Cloudflare edge logs, pseudonymous usage events through Google Analytics 4 (property G-S2M7V66GBX), browser and device characteristics, and connection information. We set an affiliate referral attribution cookie (30 days, last-touch) and an authentication session cookie. ## 3. How We Use Information We use personal information to: operate the affiliate program; calculate, verify, and issue commissions and payouts through Partnero; prevent fraud, abuse, and unauthorized access; maintain security; produce aggregate analytics; send transactional email about your account; respond to contact and support requests; and meet legal, tax, and financial-record obligations. ## 4. Legal Bases for Processing (GDPR) For affiliates in the European Economic Area, we process personal information on the following legal bases: performance of the affiliate agreement with you (Art. 6(1)(b) GDPR); compliance with legal obligations such as financial, tax, and anti-money-laundering record-keeping (Art. 6(1)(c)); and our legitimate interests in operating, securing, and protecting the affiliate network, including fraud prevention (Art. 6(1)(f)). The affiliate program is a business-to-business service. ## 5. Sub-processors We use the following categories of sub-processors: Cloudflare (edge delivery, CDN, bot protection, Turnstile), Partnero (affiliate attribution and payouts), Resend (transactional email delivery), Google Analytics 4 (aggregate, pseudonymous analytics), and Vendo (the payment processor used for affiliate payouts). A current list with processing purposes and international-transfer mechanisms is available on request to info@glowdollars.com. ## 6. Cookies and Similar Technologies We use cookies and similar technologies for authentication (required to stay signed in), affiliate referral attribution (records the referring partner so commissions can be credited), analytics, and remembering your preferences such as cookie-banner consent. See our Cookie Policy at /legal/cookies/ for the full inventory and controls. ## 7. Data Sharing We share personal information with the sub-processors listed above for the purposes described, with banking and payment networks in order to issue payouts, and when required by law or to protect our rights, the rights of others, or public safety. We do not sell personal information. ## 8. International Transfers Glow Productions is a European business. Personal information may be processed within the European Economic Area and, through our sub-processors, in other jurisdictions under appropriate safeguards such as Standard Contractual Clauses or an applicable adequacy decision. ## 9. Retention We retain account data for the life of the affiliate relationship plus the period needed to meet financial, tax, and legal record-keeping obligations (typically seven to ten years under EU and Czech law). Analytics data is aggregated or anonymized within approximately 14 months. Contact and support submissions are retained for up to 24 months unless a dispute or legal hold requires longer retention. Server and edge logs are retained according to our infrastructure providers' standard policies. ## 10. Your Rights Subject to applicable law, you may have the right to access, correct or rectify, delete, restrict the processing of, object to, port, or receive a copy of your personal information, and to withdraw consent where processing relied on it. You also have the right to lodge a complaint with your local data-protection supervisory authority. To exercise any right, email info@glowdollars.com. We will respond within 30 days and may need to verify your identity before acting on a request. ## 11. CCPA and U.S. State Notice glowDOLLARS provides a business-to-business affiliate program. We do not "sell" or "share" personal information as those terms are defined under the California Consumer Privacy Act or analogous U.S. state laws. California and other qualifying U.S. state residents may request to know what personal information we hold, request deletion, or object to processing; contact info@glowdollars.com. ## 12. Security We apply reasonable administrative, technical, and physical safeguards, including hashed passwords, TLS encryption in transit, and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We have an incident-response process for suspected security incidents. ## 13. Children's Information The affiliate program is available only to individuals who are at least eighteen (18) years old. We do not knowingly collect personal information from anyone under 18. If you believe we have collected information from a person under 18, contact info@glowdollars.com and we will take steps to delete it. ## 14. Adult-Content Notice The paysites promoted through the glowDOLLARS affiliate network contain sexually explicit content intended for adults. All affiliates and end users must be at least eighteen (18) years of age. See our 18 U.S.C. §2257 Record-Keeping Compliance statement at /legal/2257/. ## 15. Changes to This Policy We may update this Privacy Policy. Material changes will be posted on this page with an updated effective date, and where a material change affects how we use an active affiliate's personal information, we will notify that affiliate through their account or by email. ## 16. Effective Date This Privacy Policy is effective as of July 2026.