PRIVACY POLICY

Freedom Partner Program · Last updated 17 August 2026

This Privacy Policy explains how the Freedom Partner Program ("Freedom Partner", "we", "us") collects, uses, shares, stores and protects personal data when you register as a partner, use the partner portal, or visit a page through a partner referral link. We act as controller for the partner data described here. Please read it together with our Terms & Conditions.

1. Data we collect

Data you give us

  • Identity and contact data: first and last name, email address, username, member type, and the sponsor code used at signup.
  • Payout data: your USDC (ERC20 / Ethereum) wallet address and payout history.
  • Content you create: campaigns, campaign names and links, AI prompts, generated posts, uploaded or selected media, notes and support messages.
  • Verification data, where legally required: identity or tax documentation you send us on request.

Data we generate or collect automatically

  • Account and authentication data: user ID, login events, session tokens, provider used to sign in, and administrative role.
  • Tracking data on referral traffic: click timestamps, referral code, campaign identifier, referrer URL, landing path, coarse country/region, device and browser type, and a truncated or hashed IP-derived identifier used for de-duplication and fraud checks.
  • Performance data: clicks, registrations, sales, commission and tier records, leaderboard position and multilevel network relationships.
  • Fraud and security signals: risk scores, bot/click-farm indicators, velocity anomalies, self-referral matches, content-duplication matches, suspensions and moderation actions.
  • Technical logs: error reports and diagnostic events needed to keep the platform reliable and secure.

We do not knowingly collect data from anyone under 18, and we do not deliberately collect special-category data. Do not send us health, biometric, political or similar sensitive information.

2. Why we use your data and on what legal basis

  • To operate your partner account, attribute sales and pay commissions — performance of our contract with you.
  • To provide the marketing kit, media library, campaigns, academy and reporting — performance of our contract.
  • To detect, investigate and prevent fraud, bot traffic, plagiarism and abuse, and to secure the platform — our legitimate interest in a fair, lawful program, and compliance with law.
  • To measure and improve the platform through aggregated analytics — legitimate interest.
  • To send service and transactional messages (payout, security, policy and account notices) — contract and legitimate interest.
  • To send optional marketing or program news — your consent, withdrawable at any time.
  • To meet accounting, tax, anti-fraud and other legal obligations, and to establish or defend legal claims — legal obligation and legitimate interest.

3. Automated processing and fraud scoring

We use automated rules to score partner accounts and campaigns for fraud risk. A high score can lead to withheld commissions, disabled links or account suspension. Decisions with a significant effect on you are reviewed by a human before they become final where the law requires it, and you may contest an outcome and ask for a manual review through the support channel in your portal.

4. Cookies and similar technologies

We use strictly necessary cookies and local storage for authentication, session security and to remember the referral code and campaign of the link you arrived through, so commissions can be attributed correctly. These are essential to the service. We do not use third-party advertising cookies inside the partner portal.

Blocking or deleting this storage can break attribution, and we are not liable for commissions lost as a result. Platforms you promote on (social networks, ad platforms) set their own cookies under their own policies, which we do not control.

5. Who we share data with

We never sell your personal data. We share it only with:

  • Infrastructure, database, hosting and email providers that run the platform on our instructions.
  • AI providers that process the prompts you submit to generate marketing content.
  • Payment, blockchain and accounting service providers needed to execute and record payouts.
  • Program administrators, who can see partner profiles, performance, campaigns, fraud signals and payout records in order to run the Program.
  • Your upline sponsor, who sees limited team information such as your partner name and aggregated team performance where the multilevel feature is active.
  • Professional advisers, auditors, and competent authorities where a legal obligation or valid legal request applies.
  • An acquirer or successor in the event of a merger, reorganisation or transfer of the business.

Publicly visible elements, such as your username or display name on the leaderboard, are shown to other partners; ask us if you prefer to be listed anonymously.

6. International transfers

Our providers may process data outside your country, including outside the European Economic Area. Where that happens we rely on an adequacy decision or on Standard Contractual Clauses together with additional technical and organisational safeguards such as encryption in transit and at rest, and access limitation.

7. How long we keep data

  • Account, profile and campaign data: for as long as your account exists, then up to 12 months after closure for dispute handling.
  • Commission, payout and invoicing records: as long as accounting and tax law requires, typically 7 to 10 years.
  • Click and tracking data: normally up to 24 months, in aggregated form thereafter.
  • Fraud, suspension and abuse records: up to 5 years, to prevent repeat abuse and to defend claims.
  • Security and error logs: normally up to 12 months.

8. Security

We use encrypted transport, encryption at rest, row-level access control in the database, role-based administrative access, least-privilege service credentials and monitoring of suspicious activity. Wallet addresses are stored for payout purposes; we never ask for and never store your private keys, seed phrase or exchange credentials, and anyone requesting them is attempting fraud.

No system is completely secure. You are responsible for protecting your own login credentials, email account and wallet. We will notify you and, where required, the competent supervisory authority of a personal data breach that affects you, within the deadlines the law sets.

9. Your rights

Subject to applicable law, you may request:

  • Access to the personal data we hold about you, and a copy of it.
  • Correction of inaccurate or incomplete data.
  • Erasure of your data, where we do not have to keep it for legal, accounting, fraud-prevention or claim-defence reasons.
  • Restriction of processing, or objection to processing based on legitimate interest.
  • Portability of the data you provided to us, in a machine-readable format.
  • Withdrawal of consent for optional marketing, at any time, without affecting past lawful processing.
  • Human review of an automated fraud decision that significantly affects you.

Send requests through the support channel in your portal or to the contact address published there. We respond within one month and may extend that period for complex requests. We may need to verify your identity first. You also have the right to lodge a complaint with your local data-protection authority.

10. Data you process as a partner

If you collect personal data from your own audience — for example email addresses on your own landing page or list — you act as an independent controller for that data. You are responsible for your own lawful basis, privacy notice, consent collection and affiliate-link disclosure, and you must not upload third-party personal data into the portal without a lawful basis.

11. Changes to this policy

We may update this Privacy Policy as the Program evolves or the law changes. The updated version is published here with a new "last updated" date, and material changes are announced in the portal. Continued use after publication means you accept the updated policy.