Privacy Policy

Last updated: August 9, 2024

1. Introduction

Off Label Technology ("we," "our," or "us") is committed to protecting your privacy and ensuring compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This Privacy Policy explains how we collect, use, and protect personal data in connection with our affiliate marketing tracking technology and services.

2. Data Controller

Off Label Technology
Av. Conselheiro Nébias, 754/756 - sala 1422
Santos - SP, 11045-002 - Brazil
Email: dpo@offlabel.io
CNPJ: 09.345.821/0001-76

3. Personal Data We Process

3.1 Through Our Tracking Technology

  • Device Information: IP address, device type, browser type, operating system
  • Behavioral Data: Pages visited, clicks, conversions, session duration
  • Technical Data: Cookies, pixel tags, local storage identifiers
  • Transaction Data: Purchase details, conversion values (when applicable)

3.2 Through Our Website and Services

  • Contact Information: Name, email address, company details
  • Business Information: Integration requirements, traffic volume, business type
  • Communication Data: Messages, support requests, feedback

4. Legal Basis for Processing

We process personal data based on the following legal grounds under GDPR Article 6:

  • Consent (Article 6(1)(a)): For tracking cookies and behavioral advertising
  • Legitimate Interest (Article 6(1)(f)): For fraud prevention, analytics, and service improvement
  • Contract Performance (Article 6(1)(b)): To provide our tracking and optimization services
  • Legal Obligation (Article 6(1)(c)): For compliance with applicable laws

5. How We Use Personal Data

  • Campaign Optimization: Improve ad targeting and conversion rates
  • Attribution Tracking: Track affiliate marketing performance and commissions
  • Fraud Prevention: Detect and prevent fraudulent activities
  • Analytics: Generate reports and insights for our clients
  • Service Provision: Deliver our tracking and optimization services
  • Communication: Respond to inquiries and provide customer support

6. Data Sharing and Disclosure

We may share personal data with:

  • Affiliate Network Partners: To facilitate commission tracking and payments
  • Service Providers: Third-party vendors who assist in our operations
  • Legal Authorities: When required by law or to protect our rights
  • Business Transfers: In connection with mergers, acquisitions, or asset sales

All data sharing is conducted under appropriate legal safeguards and data protection agreements.

7. International Data Transfers

As a Brazilian company serving global markets, we may transfer personal data internationally. All international transfers are protected by:

  • European Commission adequacy decisions
  • Standard Contractual Clauses (SCCs)
  • Other appropriate safeguards under GDPR Chapter V

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

  • Tracking Data: Up to 24 months for optimization purposes
  • Contact Information: Until you withdraw consent or request deletion
  • Legal Requirements: As required by applicable laws and regulations

9. Your Rights Under GDPR

You have the following rights regarding your personal data:

  • Right of Access (Article 15): Request copies of your personal data
  • Right of Rectification (Article 16): Request correction of inaccurate data
  • Right of Erasure (Article 17): Request deletion of your personal data
  • Right to Restrict Processing (Article 18): Request limitation of data processing
  • Right to Data Portability (Article 20): Request transfer of your data
  • Right to Object (Article 21): Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for consent-based processing

10. Exercising Your Rights

To exercise any of your rights, please contact our Data Protection Officer:

Email: dpo@off-label.xyz
Subject Line: "Data Subject Request - [Your Right]"

We will respond to your request within 30 days as required by GDPR Article 12.

11. Cookies and Tracking Technologies

Our tracking technology uses cookies and similar technologies. You can manage cookie preferences through:

  • Browser settings and preferences
  • Opt-out tools provided by industry organizations
  • Direct contact with our DPO

12. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication systems
  • Regular security assessments and updates
  • Staff training on data protection practices

13. Data Breach Notification

In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you within 72 hours as required by GDPR Article 34.

14. Children's Privacy

Our services are not directed at children under 16 years of age. We do not knowingly collect personal data from children without appropriate parental consent.

15. Updates to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated through our website and direct notification where appropriate.

16. Contact Information

For privacy-related questions or concerns, please contact:

Data Protection Officer
Email: dpo@offlabel.io
Address: Av. Conselheiro Nébias, 754/756 - sala 1422, Santos - SP, 11045-002 - Brazil

17. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe we have not complied with data protection laws. For EU residents, you can contact your local Data Protection Authority.

Regulatory References: