AWE provides exclusive affiliate Programs (as defined in our Terms of Service).

When you participate in one of the Programs (e.g. Whitelabel, Promo Tools, etc…) and use our platform, you will share some personal information with us. Because we want you to participate in our Programs in a peaceful and trustworthy way, please be assured that we are fully dedicated to the protection of your personal data.

We operate our site and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”). For more information, please see Section “Your Rights Under GDPR”. If you are a California resident, please also see Section “Information for California Residents”.

Your privacy is important to us. We provide you with this Privacy Policy, so that you can make informed choices about the use of your data. This Privacy Policy describes how we collect, use, share, and store the personal data of the participants to our promotional/advertising programs (“Program Participants”).

As used in this Privacy Policy, the term “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Please read this Privacy Policy carefully. This Privacy Policy forms a part of and is incorporated into the Terms of Service. By participating to our programs, you agree that the Terms of Service, including this Privacy Policy, forms a binding legal contract with you. You can contact us if you have any question about our privacy practices or about what we are doing with your personal data. We will be happy to assist you in any way we can.

 

WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The following companies decide how and why your personal data is processed, and for GDPR purposes, are “Joint Controllers”:
JWS Americas S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

JWS International S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249566.

JWS Americas S.à r.l. and JWS International S.à r.l. jointly determine the purposes and means of the processing of your personal data. Both entities collaborate in joint processing activities related to the purposes mentioned in this Privacy Policy.

We have put in place a joint controllership agreement (according to article 26 GDPR) in order to determine the respective roles and responsibilities of the Joint Controllers, in particular, as regards the exercise of data subjects’ rights and the duties to provide information. You can notably contact us through a single contact point as mentioned in Section “How to contact us”? of this Privacy Policy.

Please note that, irrespective of this arrangement, you are free to exercise your rights (as described in the Privacy Policy) in respect of and against each of the Joint Controllers. You also have the right to contact us and request to be informed about how the responsibilities are allocated between the two companies.

 

WHAT PERSONAL DATA DO WE PROCESS?

We collect, use, share, transfer, and store different types of your personal data as a result of your registration on our site and participation to our Programs.
The personal data we collect includes the following categories of data:

• Personal data you provide
• When you create a Program Participant account and complete your profile

When you create a Program Participant account on our site, we only require the following details from you:

• Your email address;
• A username;
• A password.

After your account is created, we will ask you to add additional details to your profile. This information is necessary for us to execute the payment due to you for your participation in our Program(s):

• your identification information, including your first name, your last name, your birth date and your ID card;
• your site URL;
• your full address;
• your payment method.

Please note that, if you choose to receive your money through a virtual account, we will not be responsible for the data you provide to this third party to create and manage your virtual account. Please check directly the privacy policy of the virtual account provider if you want to learn more.
You are also free to add additional information to your profile, such as your Skype name and Tax ID.

When you contact the AWEmpire Support team or communicate with us

We collect all information you choose to share with the AWEmpire Support team, like your personal e-mail, your feedback, comment or request and your conversations with the Support team.

More generally, when you communicate with us in any other way, we will collect whatever information you provide us.

Personal Information we get regarding your Program Participant activity

We collect certain information about you when you use or navigate on our site (even if you have not created an account), for example, when you check you Stats or Dashboard, when you create or edit a Whitelabel and/or generate a Promo Tool.

Usage information

We collect information about your activity on our site and about how you interact with the features of our site. Basically, we know:

• the date of your signup, your Program Participant status (active or inactive) and your referrer (if applicable),
• the type(s) of Program(s) you are using, your URL, and the volume of traffic generated.

Moreover, when you receive your payment, our Billing team collects all information related to the transaction (e.g. date of payment, method of payout) in order to facilitate the payment and to be able to answer any question you might have.

Content information

We collect any content (such as your logo and/or favicon) you upload when you are creating your whitelabel site or participating in any other relevant Program.

We store any other communication data such as telephone conversations, chat logs, text messages, faxes and letters you send to us.

Finally, we also collect any feedback or comment you post on our site.

Earnings/Bonus

Based on your activity and the traffic generated by your Program(s) participation, we calculate what your earnings/bonus are on a given period.

You can access the details of your earnings/bonus in your account settings in your Dashboard and/or in your Stats.

Log data and device information

We automatically collect log data and information from or about your computer, phone, or other device you use to access or navigate on our site. This includes:

• your IP address;
• the date and time you logged into your account;
  pages viewed;
• the hardware, software or internet browser you use;
• information about your computer’s operating system/application version;
  your language settings;
• identifiers associated with cookies or other technologies that may uniquely identify your device or browser.

If you are using a mobile device, we might also collect:

• data that identifies your mobile device;
• device-specific settings and characteristics;
• your location details;
• app crashes and other system activity.

Information collected by cookies and other technologies

Like many websites and applications, we use cookies and other technologies (such as web beacons, web storage, and unique advertising identifiers) to collect information about your activity, browser, and device.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that blocking cookies may impact your use of the services on our site. To learn more about how we use cookies and your choices, please check out our Cookies Policy.

HOTJAR – We are also using Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user.

For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies by following this opt-out link.

Personal Information we process about your authorized person

If you are a legal person (i.e., company, business entity) and have authorized a natural person to register a Program Participant account on our site on your behalf, we process all the data elements listed above under the sections “Personal data you provide” and “Personal Information we get regarding your Program Participant activity” and concerning this natural person (hereinafter referred to as “Authorized Person“).

In the event you want to appoint a new person to manage your account, you may request at any time that we update your Authorized Person personal information, by sending us an email at awe@jwsprivacy.com.

You and your Authorized Person individually confirm that your Authorized Person is authorized to administer and manage your Program Participant account on your behalf, and that you and your Authorized Person are bound by this Privacy Policy. You both confirm that we may require you to provide additional information or documentation demonstrating that your Authorized Person has the authority to engage you in this contractual relationship with us.

 

Open your Program Participant account and allow your participation in our Programs(s)

• First and foremost, we use the personal data you give us when you create your account to open and administer your online account and enable you to participate in our Program(s).
• Your account is also a way to exercise control over your personal data. In your account, you can see your earnings, your stats and you can choose the information you wish to share with us.

We process this information as it is necessary for the adequate performance of the contract we have with you once you register on our site.

Display your Stats and Earnings/Bonus

• We use your payout information and your activity related data in order to display Stats about your activity as a Program Participant and your earnings/bonus.
• Please note that this information is only showed to you in your account and help you to have visibility on your activity, payments made to you and your earnings/bonus.

We process this information given our legitimate interest in providing a good user’s experience and visibility on your activity.

Improve our services

• We use your personal data for analytical and statistical purposes. We place great emphasis on the improvement of our platform, and user’s experience.
• In order to better understand what your needs are (besides the trends in the industry) and how we can improve our services, we use your personal information to generate statistical reports about your activity.
• We also use your personal data for troubleshooting and improving the functionality and quality of our services. Our main goal is to optimize our site and the related services to your needs.

We process this information given our legitimate interest in developing and improving our site and our users’ experience.

Program Participant relationship management and communication with you

• We provide Support service on regular business days in office hours (CET). Sharing your personal details with our Support team allows us to respond to any question you might have about our Programs.All your communications with the AWEmpire Support team and all information you provide in the course of such communications, including any review, opinion or comment about our programs are collected and analyzed so that we may respond to your request.Please be also informed that, when receiving a request or claim from you, our Support team may access all information you provided and all information we collected about you within the course of your participation to our Program(s). We want to make sure that our Support team has all information needed to appropriately respond to your request, but also to be able to detect any fraudulent activity.
• Please note that we may also communicate with you through emails or any other means, if appropriate, in order to inform you of certain changes regarding our site or of certain events/actions, for example, when you successfully register on our site.

We process this information given our legitimate interest in improving our users’ experience and delivering appropriate customer services.

Payment and Accounting

We use your data for payment and accounting purposes to process transactions and maintain legally required business records.

We process this information, as it is necessary for the adequate performance of the contract we have with you once you register on our site.

Ensure a safe and trustworthy environment

• Because we want to create and ensure a safe environment, we use your personal data to detect and prevent fraud and other illegal activities related to the participation in our Programs.
• We also use your data to detect potential breaches to the rules of our site, as explained in our Terms of Service.
• Finally, we use your personal information for security purposes and risk assessment, such as to authenticate you on our site and verify your identity.

We process this information given our legitimate interest in ensuring compliance with the rules of our site, fraud detection and prevention, as well as, information, system, network and cyber security.

Sending of marketing emails

If you have accepted to receive marketing emails, we will use your personal data to send you emails about special offers and services, or information that may be of interest for you.

You can very easily revoke such consent at any time in your “Consent Settings”. Revoking consent means you might miss out special offers.

Comply with any legal requirements and enforce our legal rights

We may rely on a legal obligation to process your personal data, such as for accounting purposes, to respond to requests of competent authorities or to establish, exercise or defend legal claims.

 

HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement various security measures, technical and organizational, to grant protection to your personal data against unauthorized access, modification, disclosure or deletion.

We implement data loss prevention systems against leakage, theft and data breach. We periodically test our IT systems and do penetration tests. Our site incorporates reasonable security technologies available to ensure safety of its users and the safekeeping of their related information.

 

WITH WHOM DO WE SHARE YOUR DATA?

We share your data with the following parties:

With other users of the site

If you manage to become one of our top Program Participants, we may post your username on the website. If you do not wish to appear in the top Program Participants list, please contact our Support Team.

Entities of our company’s group

We share your personal information with the following companies of our group based in Luxembourg and Hungary, as they are helping us to deliver the services to you:

• Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Jasmin Holding SA, 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
• Jasmin SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
• Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
• Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
• Duodecad IT Services Luxembourg S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg

Service providers

We use carefully selected and trusted third parties, who act as service providers to our site.

We ensure that they are bound by contractually binding obligations to process information we share with them in accordance with our instructions, this Privacy Policy and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our site, our third party service providers may regularly change. Such entities mainly belong to the following areas: (a) business intelligence and analytics; (b) customer care; (c) marketing and sales; (d) antifraud service providers and auditing service providers.

Payment providers and financial institutions

In order to receive your payment, you may share certain information with a third party bank or payment processor (e.g. FirstchoicePay, Paxum or ePayService).

You may receive transactional emails from this party confirming the receipt of your fees, including other possible relevant notifications.

This Privacy Policy does not govern the processing of your personal data by these third parties if it was shared directly with them.

We may furthermore share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes.

Law enforcement agencies or governmental authorities

We may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary to (a) comply with our legal obligations, (b) respond to information requests for fraud investigations and alleged illegal activities, (c) enforce and administer our Terms of Service or any other agreement concluded, and/or (d) protect our rights or defend ourselves against any claims.

Business transfers

Your information may be transferred to another entity of our group (i.e. reorganization, restructuring, etc.) or third party (i.e. sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred or falling under the control of the new owner.

This would be the case providing the new owner operates in the same or similar line of business as ours and commits to comply with this Privacy Policy.

 

YOUR RIGHTS UNDER GDPR

Information on the transfer of your personal data outside of the European Economic Area

As we are a Luxembourg based company, we comply with the EU Data Protection Regulation commonly, “GDPR”. Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.

During the course of the operation and exploitation of the site and the provision of the services, your personal information may be transferred outside of the European Economic Area (“EEA”) to third parties data processors for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavor to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

What are your rights regarding your personal data?

We have done our best to explain what your rights are and how you can exercise them. If, despite of our below explanations, you are still unsure about the actions you can take or the conditions of exercise of your rights, do not worry, our Support Team will provide you with all the assistance you need when exercising your rights.

You may also contact us, at any time, before exercising any of your rights, and we will reply to your request as quickly as possible.

Please note that we created a specific interface called “Privacy Rights” in your account settings in order for you to be able to exercise certain of your rights easily.

Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex and a high number of requests, we may extend this period of response up to two further months.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Data access and data portability

You have the right to access the personal information that we hold about you by requesting a copy of your personal data free of charge through the “Data Download” section in your account settings.

Upon verification of your identity, your request will be sent to our Support Team.

If we consider that your request is manifestly unfounded or excessive (for example, because you requested a copy of your data numerous times in a short period of time), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you the information.

In certain cases, you may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). For this purpose, you can send an email to awe@jwsprivacy.com.

Rectification of inaccurate or incomplete data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can send an email to awe@jwsprivacy.com.

Data retention and erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations.

If you no longer want us to use your information, you can request that we erase your personal information and close your account. In such case, please select “Forget my Data” in the “Privacy Rights” section of your account settings.

Your request will be sent to our Support Team who will contact you to learn more about your request. However, if you face any difficulties, please contact us at any time.

Please note that if you request the erasure of your personal information:

• We might retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we close or suspend your account for breach of our Terms of Service, fraud or illegal activities, we may retain certain information about you to prevent you from opening a new account in the future. Such information shall also be kept available in case of ongoing judicial proceedings/and or investigations.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing purposes. Please note that according to Luxembourg legislation financial related information shall be kept for a period of ten years.
• Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• In order to protect our site and your personal information from accidental or malicious loss and destruction, we have backup systems. Residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Right to object

• We process your data for a variety of reasons as explained in Section “Why do we process your personal data”. Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will stop processing your personal data for these purposes.

In specific situations, we may have to refuse the execution of your request. This would be the case where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to the use of your data might disable the use of your account.

• Please note that you may, at any time, ask us to stop processing your data for any direct marketing activities that we may do by sending an email to awe@jwsprivacy.com.

Right to restriction of processing

You have the right to request that we stop processing your personal data, while we resolve any issues.

This is only possible in the following four cases:

• Accuracy: If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.
• Legitimate Interest: If you object to a processing activity based on legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objecting.
• Unlawful Processing: You can request the restriction of data processing if you consider your data is being processed unlawfully, but do not wish your data to be immediately erased.
• Data Storage: We have no further need for the data but you require it to establish, exercise, or defend legal claims.

Despite your request, we may still continue the processing of your personal data if we have to establish, exercise, or defend legal claims. We will notify you before lifting a restriction.

Right to lodge a complaint with a supervisory authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with a supervisory authority (in particular in the Member State where you live, place of work or of an alleged infringement of the GDPR).

 

INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the following special rights under the California Consumer Privacy Act (“CCPA”) in addition to any other rights outlined in this Privacy Policy.

Please note that we do not “sell” your personal data, as that term is defined in CCPA.

Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal data we have collected about you. You have the right to know the categories of sources from which the personal data has been collected, the business or commercial purpose for collecting or selling personal data, and the categories of third parties with whom we share personal data.

You also have the right to request deletion of personal data we’ve collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

To exercise these rights contact us as provided in Section “How to contact us” below. You can also exercise your right to deletion by selecting “Forget my Data” in the “Privacy Settings” section of your account settings. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period. You may also download your data as provided on our website, or exercise your right to delete by deleting your account as provided in your account settings.

Personal Information Disclosed

You also have the right to know what categories of personal data we’ve disclosed for a business purpose, and the third parties to whom that information was disclosed. In the past 12 months, we’ve disclosed for a business purpose the following categories of information to the following parties: Usage/device information (including, without limitation, your IP address, as the case may be) to our business intelligence and analytics service providers; Identification information and payment/transaction data to our payment service providers; Contact information, device/usage information (including, without limitation, your IP address), information relating to the transactions and information as regards your interactions with the emails we sent to our marketing, sales and customer care service providers; and identification information, contact information, device and usage information, payment information (as the case may be) to our antifraud service providers and auditing service providers.

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please note, however, that the exercise of some of your rights (e.g., to delete your data) may render it impossible for us to continue to deliver services to you.

Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section “How to contact us” below. In order to verify you have authorized an agent we may require a signed, written authorization from you.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.

 

CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we handle your personal information or changes in the applicable laws.

If we make changes we consider important, we will let you know by placing a notice on the relevant app/site and/or contact you using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site, unless we specify a date of entry into force. Your continued use of our site from that day on will be subject to the new Privacy Policy.

 

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to awe@jwsprivacy.com or via mail to the address indicated below, and we will get quickly back to you. We are always glad to talk about our privacy practices.

JWS Americas S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

JWS International S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249566.

We are also happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at: dpo@awempire.com or mail to the following address:

To the attention of the DPO
JWS Americas S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249539.

Or

To the attention of the DPO
JWS International S.à r.l.
44, Avenue John F. Kennedy
L-1855, Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register under the number: B 249566.