Privacy Policy

2. Data Controller

Ulk Ltd is the data controller responsible for your personal information. If you have questions about how we handle your data, contact us at:

Ulk Ltd
Email: privacy@kickback.io

3. Information We Collect

3.1 Information You Provide

• Account information: Name, email address, password, and account type (Promoter or Product Owner)
• Profile information: Profile picture, bio, social media links
• Payment information: Bank account details, Stripe account information for payouts
• Product information: Product listings, descriptions, pricing, commission rates (for Product Owners)
• Communications: Messages you send to us or other users through the platform

3.2 Information Collected Automatically

• Usage data: Pages visited, features used, clicks, time spent on the platform
• Device information: IP address, browser type, operating system, device identifiers
• Referral tracking: Click data, conversion data, and attribution information for commission calculation
• Cookies: We use cookies and similar technologies as described in Section 8

3.3 Information from Third Parties

• OAuth providers: If you sign in with Google or X (Twitter), we receive your name, email, and profile picture from those services
• Payment processors: Stripe provides us with transaction status and payout information

4. How We Use Your Information

We use your personal information to:

• Provide the Service: Create and manage your account, process transactions, track referrals, calculate and pay commissions
• Communicate with you: Send account notifications, payout confirmations, platform updates, and respond to your enquiries
• Improve the Service: Analyse usage patterns, troubleshoot issues, develop new features
• Ensure security: Detect and prevent fraud, abuse, and unauthorised access
• Comply with legal obligations: Meet tax reporting requirements, respond to legal requests
• Marketing: Send promotional communications (with your consent, where required)

5. Legal Basis for Processing

Under UK GDPR, we process your personal information based on:

• Contract: Processing necessary to provide the Service you requested
• Legitimate interests: Processing for fraud prevention, security, and service improvement, where our interests don't override your rights
• Legal obligation: Processing required to comply with applicable laws
• Consent: Processing based on your explicit consent, such as marketing communications

6. Information Sharing

We may share your information with:

• Other users: Promoters can see Product Owner product listings. Product Owners can see Promoter performance data for their products.
• Service providers: Third parties who help us operate the platform (hosting, analytics, payment processing)
• Payment processors: Stripe processes payments and payouts on our behalf
• Legal authorities: When required by law, court order, or to protect our rights
• Business transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

7. International Transfers

Your information may be transferred to and processed in countries outside the UK, including the United States (where some of our service providers are located). When we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office.

8. Cookies and Tracking

We use cookies and similar technologies to:

• Essential cookies: Enable core functionality like authentication and security
• Analytics cookies: Understand how users interact with our platform
• Referral tracking: Track clicks and conversions for commission attribution

Referral tracking cookies are essential to our Service and enable us to accurately attribute sales to Promoters. These cookies typically last for the duration specified in each product's "cookie days" setting.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may affect platform functionality.

9. Data Retention

We retain your personal information for as long as:

• Your account is active
• Necessary to provide the Service
• Required to comply with legal obligations (e.g., tax records for 7 years)
• Needed to resolve disputes or enforce agreements

When you close your account, we delete or anonymise your personal information within 90 days, except where retention is required by law.

10. Your Rights

Under UK GDPR, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Rectification: Request correction of inaccurate or incomplete information
• Erasure: Request deletion of your personal information in certain circumstances
• Restriction: Request that we limit how we use your information
• Portability: Request your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Withdraw consent for processing based on consent at any time

To exercise these rights, contact us at privacy@kickback.io. We will respond within one month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

11. Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit (TLS) and at rest
• Secure authentication and access controls
• Regular security assessments and monitoring
• Employee training on data protection

While we strive to protect your information, no method of transmission or storage is 100% secure. Please use strong passwords and keep your account credentials confidential.

12. Children's Privacy

Kickback is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the platform. The "Last updated" date at the top indicates when the policy was last revised.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at:

Ulk Ltd
Email: privacy@kickback.io