ClickHub Tracker — Privacy Policy

1. Introduction

Verticode, Inc. ("Company," "we," "us," or "our"), located at 1286 University Ave. #510, San Diego, CA 92103, operates the ClickHub Tracker platform (the "Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect information in connection with the Platform and our website at https://clickhub.co (the "Website") and the application at https://tracker.clickhub.co.

By accessing or using the Platform or Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, you should not use the Platform or Website.

This Privacy Policy applies to two categories of individuals: (a) Clients — individuals or entities who register for and use the Platform; and (b) Website Visitors — individuals who visit our Website. This policy does not govern the data processing activities of our Clients with respect to their own end users; Clients are solely responsible for their own privacy practices and compliance.

2. Information We Collect

2.1. Information You Provide to Us

When you register for an Account, contact us, or otherwise interact with the Platform, we may collect the following information:

• Account Information: Name, email address, password (stored in hashed form), company name, and billing address.
• Payment Information: Payment method details (such as credit card number, expiration date, and billing address). Payment processing is handled by third-party payment processors; we do not store full credit card numbers on our servers.
• Communications: Information you provide when contacting our support team or communicating with us via email, including the content of such communications.
• Platform Configuration: Information you input into the Platform, including campaign configurations, tracking domain settings, offer details, landing page URLs, affiliate network settings, traffic source configurations, and related data.

2.2. Information Collected Automatically

When you access the Platform or Website, we may automatically collect certain information, including:

• Log Data: IP address, browser type and version, operating system, referring URL, pages visited, date and time of access, and duration of visit.
• Device Information: Device type, screen resolution, language settings, and unique device identifiers.
• Usage Data: Features used, actions taken within the Platform, and interaction patterns.
• Cookies and Similar Technologies: We use cookies, local storage, and similar technologies to maintain session state, remember preferences, and analyze usage patterns. See Section 7 for details.

2.3. Tracking Data Processed on Behalf of Clients

In the course of providing the Platform's tracking services, we process data related to clicks, impressions, conversions, and other events associated with our Clients' advertising campaigns ("Tracking Data"). This Tracking Data may include information about end users such as IP addresses, user agent strings, device information, geographic location, referrer URLs, and other technical parameters. We process this data solely on behalf of our Clients and in accordance with their instructions. Our Clients are the data controllers of this Tracking Data, and we act as a data processor.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Providing and Operating the Platform: To create and manage your Account, process transactions, deliver the tracking and analytics services, and provide customer support.
• Improving the Platform: To analyze usage patterns, diagnose technical issues, develop new features, and improve the overall performance, security, and reliability of the Platform.
• Communications: To send you service-related notifications, billing information, technical notices, security alerts, and support messages. We may also send you marketing communications about our products and services, which you can opt out of at any time.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, and to protect the rights, property, and safety of the Company, our Clients, and others.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or governmental requests.
• Billing and Payments: To process payments, manage Subscriptions, and handle billing-related inquiries.

4. How We Share Your Information

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

• Service Providers: We engage third-party companies and individuals to perform services on our behalf, including payment processing, hosting, analytics, email delivery, and customer support. These service providers have access to your information only to perform specific tasks and are contractually obligated to protect it.
• Legal Requirements: We may disclose your information if required to do so by law, or if we believe in good faith that such action is necessary to comply with a legal obligation, protect the rights or safety of the Company or others, investigate potential violations of our Terms of Use, or respond to a court order, subpoena, or governmental request.
• Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change via email or a prominent notice on our Website.
• With Your Consent: We may share your information with third parties when you have given us explicit consent to do so.

5. Data Retention

5.1. We retain your Account information for as long as your Account is active or as needed to provide you with the Platform's services. If you cancel your Subscription or your Account is terminated, we may retain certain information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and for legitimate business purposes.

5.2. Tracking Data processed on behalf of Clients is retained for the duration of the Client's active Subscription. Upon termination of a Client's Account, Tracking Data may be deleted in accordance with our data retention schedules. Clients are responsible for exporting any data they wish to retain prior to Account termination.

5.3. We may retain aggregated or de-identified data that cannot reasonably be used to identify an individual for analytical and operational purposes indefinitely.

6. Data Security

6.1. We implement commercially reasonable technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit (TLS/SSL), encryption of sensitive data at rest, access controls, regular security assessments, and secure infrastructure hosting.

6.2. Despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information. You acknowledge and accept that you transmit information to us at your own risk.

6.3. You are responsible for maintaining the security of your Account credentials and for any activity that occurs under your Account. You should use a strong, unique password and take measures to protect your Account from unauthorized access.

7. Cookies and Tracking Technologies

7.1. We use cookies and similar tracking technologies on the Website and within the Platform for the following purposes:

• Essential Cookies: Required for the operation of the Platform, including maintaining your login session and security tokens.
• Functional Cookies: Used to remember your preferences and settings to enhance your experience.
• Analytics Cookies: Used to understand how visitors interact with our Website, including which pages are visited most frequently. This helps us improve the Website and Platform.

7.2. You can control cookie settings through your browser. Disabling certain cookies may affect the functionality of the Platform.

8. Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• Access: The right to request a copy of the personal information we hold about you.
• Correction: The right to request that we correct inaccurate or incomplete personal information.
• Deletion: The right to request that we delete your personal information, subject to certain exceptions (such as legal obligations or legitimate interests).
• Data Portability: The right to receive a copy of your personal information in a structured, commonly used, machine-readable format.
• Objection: The right to object to the processing of your personal information for certain purposes, such as direct marketing.
• Withdrawal of Consent: Where we process your personal information based on consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

9. California Privacy Rights (CCPA)

9.1. If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, use, disclose, and sell; the right to request deletion of your personal information; and the right not to be discriminated against for exercising your privacy rights.

9.2. We do not sell personal information as defined under the CCPA.

9.3. To submit a CCPA request, please contact us at [email protected]. We may need to verify your identity before processing your request.

10. International Data Transfers

10.1. The Platform is operated from the United States. If you access the Platform from outside the United States, you acknowledge and consent to the transfer of your information to the United States and other jurisdictions where we or our service providers operate. These jurisdictions may have data protection laws that differ from those in your jurisdiction.

10.2. Where required by applicable law, we implement appropriate safeguards for international data transfers, such as standard contractual clauses or other mechanisms recognized by applicable data protection authorities.

11. European Privacy Rights (GDPR)

11.1. If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR) or equivalent legislation. Our legal bases for processing your personal information include: performance of a contract (providing the Platform services), legitimate interests (improving our services, security, and fraud prevention), compliance with legal obligations, and your consent where applicable.

11.2. You have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable data protection law.

11.3. For Tracking Data processed on behalf of our Clients, the Client is the data controller and we act as a data processor. Individuals whose data is processed as Tracking Data should direct their privacy inquiries to the relevant Client (the entity conducting the advertising campaign).

12. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to promptly delete that information. If you believe that a child under 18 has provided us with personal information, please contact us at [email protected].

13. Third-Party Links

The Website and Platform may contain links to third-party websites, services, or resources. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices or content of third-party sites and encourage you to review the privacy policies of any third-party services you access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by posting the updated policy on our Website with a revised "Last updated" date. We may also notify you via email or through a notice within the Platform. Your continued use of the Platform after any changes to this Privacy Policy constitutes your acceptance of those changes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Verticode, Inc.
1286 University Ave. #510
San Diego, CA 92103
Email: [email protected]