Privacy Policy

This Privacy Policy explains how JGN MEDIA CORPORATION, doing business as Creator365Media ("Creator365", "we", "us") collects, uses, shares and protects information. It covers our website, the creator and advertiser dashboards, our tracking links and pixels, and the emails we send. We are a Florida corporation at 5794 Bird Rd, Unit #752, Miami, FL 33155.

It applies to four groups of people: creators who promote offers through us; advertisers who run offers; people who visit our website; and people who click a creator's tracked link (consumers). What we collect about each group is different, and we describe each below.

By creating an account you agree to this Policy. If you do not agree, do not create an account.

• —Account details: your name, email address and a password (stored only as a one-way hash).
• —Your promotion: the social accounts you connect, audience size and category, the offers you join, and the tracking links you create.
• —Getting paid: your PayPal email (or other payout details we support), your payout currency, and your earnings and payout history.
• —Tax information: tax forms such as a W-9 or W-8, including your taxpayer identification number, which we store encrypted.
• —Your communications with us: support messages, and the record of when you accepted our terms (version, time, network address and browser).
• —Security records: sign-in activity and the network address and browser used for sensitive changes, such as changing where you are paid.

• —Account and company details: your company name, the people who use the account (name, work email), and the offers, creative materials and landing pages you provide.
• —Conversion reports: the conversions you send us (by postback, pixel or in the dashboard) — a click identifier, an order or transaction reference, a value, and a status. For offers that credit views, we also use an IP address to match a conversion to an impression.
• —Invoicing and account administration details, and your sign-in activity.
• —Please do not send us the names, email addresses, phone numbers or payment details of your customers. We do not need them to run an offer, and our systems are not designed to hold them.

When someone clicks a creator's tracking link, our servers record:

• —the network (IP) address, browser and device type, and the page they came from (the referrer);
• —an approximate location (country, region and city) worked out from the IP address with a location database we run ourselves;
• —the link and offer clicked, the creator it belongs to, and the time.

We also set a cookie that holds a click identifier for 30 days, so that if the person later completes the advertiser's action we can credit the right creator. We may place tracking pixels on pages (including on behalf of advertisers) to record that an ad was viewed or that an action was completed.

We use this to attribute conversions, calculate and pay commission, and detect fraud and invalid traffic. We do not ask the person for their name or contact details and we do not build profiles of them for advertising.

Our servers keep standard logs: IP address, browser, device, the pages requested and the time. We use them to run and secure the site and to understand overall use.

Our website does not currently use third-party advertising or analytics cookies. If that changes, we will update this Policy before it does.

To invite creators who may be a good fit, our team may look at publicly available information about them, such as the name, handle, subscriber count and recent public videos of a channel, and may send an invitation.

Where that information comes from YouTube, it is obtained through YouTube API Services and our use of it is subject to the Google Privacy Policy (https://policies.google.com/privacy). We keep such information for no more than 30 days unless we refresh it from YouTube, and we delete it if you ask us to.

If we have your details and you would like them removed, email info@creator365media.com.

• —Sign-in: we use your browser's storage and cookies to keep you signed in. These are strictly necessary; the dashboards do not work without them.
• —Attribution: the click-identifier cookie described above, which lasts 30 days. It is set on the visitor's browser when they click a tracked link.
• —Pixels and beacons: small images or scripts that tell us that a page was viewed, an ad was shown or an email was opened.

You can block or delete cookies in your browser settings. Blocking the attribution cookie may mean a conversion cannot be credited. On a phone, you can limit or reset your advertising identifier in the device's privacy settings. To stop receiving a particular company's ads, contact that company: blocking cookies does not stop ads from being shown.

• —To run accounts, send you service messages about your account, and give you support.
• —To record clicks and conversions, decide who is owed commission, and pay creators.
• —To prevent, detect and investigate fraud, invalid traffic and abuse, and to enforce our terms. This includes using IP addresses to spot repeated or automated activity and to confirm that a person accepted a legal agreement.
• —To meet tax, accounting and legal obligations.
• —To keep our systems secure, and to understand and improve how the network works, including from combined statistics.
• —To send you information about the network if you have asked for it. You can stop marketing email at any time (see "Your choices").

We do not sell personal information. We share it only as follows:

• —Advertisers see what they need to run an offer: reports on clicks and conversions and a creator identifier. They do not see your tax information or payout details.
• —Creators see their own links, clicks, conversions and earnings. They do not see the personal information of the people who clicked.
• —Payment providers (such as PayPal) receive the details needed to pay you.
• —Service providers that help us run the network, such as hosting, email delivery and error monitoring. They may use the information only to provide their service to us.
• —Tax and government authorities, and anyone else, where the law requires it or a court orders it.
• —Other companies and organisations for fraud prevention, and where needed to protect our rights, our users or the public, or to deal with a dispute or a breach of our terms.
• —A buyer or successor, if we are involved in a merger, sale or reorganisation of our business.

We are based in the United States and the information we collect is processed and stored in the United States and in the other countries where our service providers operate. If you use the network from outside the United States, you understand that your information will be transferred to, and handled under the laws of, those countries, which may not give the same protection as the laws where you live.

• —Click records: the IP address on a click is reduced to a network prefix after 90 days. The rest of the record, without the full address, is kept to support reporting and payment disputes.
• —Prospect information from YouTube: no more than 30 days unless refreshed (see above).
• —Tax forms, and the records of commissions, conversions and payouts: for as long as tax and accounting law requires.
• —Account information: while your account is open, and afterwards as long as needed for the purposes above or required by law.
• —Backups are replaced on a rolling schedule, so information deleted from our live systems disappears from backups after a short delay.

If you ask us to delete your information, we remove or anonymise what we are free to remove. We keep what the law requires us to keep (for example tax forms and the financial ledger) and the record that you accepted our terms, without the IP address and browser.

• —Access, correct or delete: email info@creator365media.com. We will check it is really you before acting, and respond within the time the law allows.
• —Marketing email: use the unsubscribe link at the bottom of any such email, or write to us. We may still send account and security messages.
• —Cookies: see above.
• —If you live in a state with a consumer privacy law (for example California, Colorado, Connecticut, Virginia, Texas or Florida) you may have the right to know what we hold, to correct or delete it, and to opt out of sale or targeted advertising. We do not sell personal information or use it for cross-context behavioural advertising, and we do not discriminate against people who use these rights.
• —You may ask someone to act for you; we will ask for proof that they may.

We protect information with measures that include encrypted connections, hashed passwords, encrypted storage of taxpayer identification numbers, access limited to the people who need it, and optional two-factor sign-in. No system is perfectly secure, and you share information with us at your own risk.

If we learn of a breach that affects your personal information, we will notify you and the authorities as the law requires. We will use email for this, and notice may be delayed where needed for law enforcement or to find out what happened and fix it.

Our network is for adults. Creators and advertiser staff must be at least 18, and we do not knowingly collect personal information from anyone under 18. If you believe we have, tell us and we will delete it.

If you give colleagues or team members access to an account, you are responsible for making sure they know about and follow this Policy. Their use of the account is covered by it.

We may change this Policy. We will post the new version on this page with its version number and effective date, and we will email account holders about material changes. If you keep using the network after a change takes effect, you accept it.

JGN MEDIA CORPORATION, doing business as Creator365Media, 5794 Bird Rd, Unit #752, Miami, FL 33155. Email info@creator365media.com with any question about this Policy or to make a request.