Privacy Policy

(Last Updated: [09/09/2025])

1. Introduction

Holding Black Software LLC ("Netaclick," "we," "our," or "us") operates the affiliate marketing platform available at www.netaclick.com (the "Platform"). This Privacy Policy explains how we collect, use, share, and protect your personal information when you interact with our services, as well as your rights and choices. We comply with:

• General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA) and the UK.
• California Consumer Privacy Act (CCPA) for California residents.
• Children's Online Privacy Protection Act (COPPA) for minors in the USA.
• CAN-SPAM Act for electronic communications.
• Other international privacy and data protection regulations.

Company Details:
Holding Black Software LLC
407 LINCOLN RD STE, 12-N
Miami Beach, Florida, 33139, USA

If you have questions about this Privacy Policy or your personal data, contact us at:
📧 privacy@netaclick.com

2. Scope

This policy applies to:

• Affiliates, advertisers, and visitors using our Platform worldwide.
• All services provided by Netaclick, including tracking links, affiliate dashboards, and APIs.
• Information collected via websites, mobile devices, or third-party integrations.

3. Data We Collect

We collect the following categories of data to operate effectively:

A. Personal Information

• Name and surname.
• Email address and phone number.
• Company information (if applicable).
• Billing and payment details (e.g., bank account, PayPal, Stripe ID).
• Tax data (VAT ID, EIN, etc.).
• Login credentials (securely encrypted).

B. Non-Personal Information

• IP address.
• Browser type, device information, and operating system.
• Pages visited, clicks, and traffic source data.
• Campaign tracking identifiers (affiliate IDs, sub-IDs).

C. Data from Third Parties

We may collect information from:

• Social media platforms (e.g., Facebook, LinkedIn).
• Fraud prevention and anti-spam providers.
• Payment processors (e.g., Stripe, PayPal).
• Advertising partners providing conversion data.

4. Methods of Data Collection

• Directly from you: when registering, filling forms, or contacting us.
• Automatically: through cookies, pixels, and similar technologies.
• From partners: advertisers, affiliates, or third-party integrations.

5. Purposes of Data Processing

We process data for the following purposes:

• To create and manage affiliate and advertiser accounts.
• To process payments and generate invoices.
• To track campaign performance and calculate commissions.
• To prevent fraud, abuse, or prohibited traffic sources.
• To comply with legal and regulatory obligations.
• To send important service-related communications.
• To provide marketing communications (only with consent).
• To improve our services and user experience.

6. Legal Basis for Processing (GDPR)

For EU/EEA users, data is processed under:

• Consent – for marketing and cookie usage.
• Contractual necessity – to fulfill our agreement with you.
• Legal obligations – tax, accounting, AML compliance.
• Legitimate interests – fraud prevention, platform optimization.

7. Sharing & Disclosure of Data

We do not sell personal data. However, we may share it with:

• Service providers: hosting, analytics, payment gateways, fraud detection tools.
• Legal authorities, when required by law.
• Business partners, if necessary for providing services.
• In case of merger or acquisition, your data may be transferred to the new entity.

All partners are bound by strict confidentiality and data protection agreements.

8. International Data Transfers

Data may be processed in countries outside your residence, including the USA. We use:

• Standard Contractual Clauses (SCCs) for EU data transfers.
• Secure hosting providers with GDPR-compliant safeguards.

9. Data Retention

• Affiliate and advertiser data: retained while the account is active and up to 7 years after closure for tax/legal reasons.
• Analytics and tracking data: kept for 24 months.
• Marketing consents: stored until withdrawal.

10. User Rights

Depending on your location, you have the right to:

• Request access to your personal data.
• Correct inaccurate or incomplete data.
• Request deletion of your data ("right to be forgotten").
• Object to specific processing activities.
• Restrict processing under certain conditions.
• Receive data in a portable format.
• Withdraw consent at any time.

To exercise your rights, email privacy@netaclick.com with the subject "Data Request".

11. California Residents (CCPA)

If you are a California resident, you have the right to:

• Know what data we collect and how we use it.
• Request deletion of your personal data.
• Opt-out of data sale (Netaclick does not sell data).
• Receive equal services without discrimination.

Submit requests at privacy@netaclick.com.

12. Children's Privacy (COPPA)

Our services are not directed at individuals under 18. We do not knowingly collect data from minors. If we discover such data, we will delete it immediately.

13. Security Measures

We implement advanced security protocols:

• SSL/TLS encryption.
• Regular vulnerability testing and security audits.
• Restricted access to sensitive data.
• Anti-fraud monitoring and real-time alerts.

14. Cookies and Tracking

We use cookies to:

• Authenticate users.
• Track affiliate conversions.
• Analyze website traffic.
• Prevent fraudulent clicks and abuse.

For detailed information, see our Cookie Policy.

15. Third-Party Links

We are not responsible for privacy practices of third-party websites linked from our platform.

16. Changes to This Policy

We may update this policy periodically. Users will be notified via email or website notice before changes take effect.

17. Contact Information

For privacy-related inquiries:
Email: privacy@netaclick.com
Address: Holding Black Software LLC, 407 LINCOLN RD STE, 12-N, Miami Beach, Florida, 33139, USA