Privacy Policy

Version:
0.1.0
Effective date:
[EFFECTIVE DATE]

DRAFT SKELETON. Headings and topics only. Every bracketed item is a placeholder for the legal team. Nothing in this draft is a legal statement until legal has reviewed it and the file says status: published.

1. Who we are

[COMPANY LEGAL NAME], [REGISTERED ADDRESS] ("we", "us", "the Company") operates affy.ink and bffy.link (together, "the Services"). This policy applies to both Services.

[LEGAL: controller / processor roles, e.g. when a merchant or client app sends us data about its own users.]

2. Data we collect

  • Account data: [LEGAL: e.g. name, email, organization, role]
  • Sign-in data: [LEGAL]
  • Payout and tax data: [LEGAL: e.g. payout account details, tax forms, identity verification files]
  • Tracking data: [LEGAL: e.g. link clicks, referral codes, sub-IDs, IP address, user agent]
  • Sale and commission data reported by merchants and client apps: [LEGAL]
  • Support and contact messages: [LEGAL]

3. Purposes and legal bases

[LEGAL: purpose for each category above and the legal basis where required.]

4. Cookies and tracking

[LEGAL: which cookies, attribution windows, how to opt out.]

5. Service providers (processors)

The Services can use the following providers. [LEGAL: confirm which are enabled in production, their locations and the data each receives.]

  • WorkOS: sign-in and user management
  • Email delivery: NHN Cloud or Resend
  • Vercel: hosting, and Vercel Blob for uploaded verification files
  • Neon: hosted PostgreSQL database
  • Payout providers, depending on the payout method chosen: Stripe Connect, PayPal, Wise, Tipalti, Trolley
  • AI providers, only where the feature is enabled: Anthropic, OpenAI

6. Sharing

[LEGAL: sharing between merchants, affiliates, agencies and client apps; legal requests; business transfers.]

7. International transfers

[LEGAL]

8. Retention

[LEGAL: retention period per data category. Do not fill in periods without legal review.]

9. Your rights

[LEGAL: access, correction, deletion, objection, portability, how to make a request.]

10. Security

[LEGAL: summary of measures, without promises the product does not keep.]

11. Children

[LEGAL]

12. Changes to this policy

[LEGAL]

13. Contact

[COMPANY LEGAL NAME], [REGISTERED ADDRESS], [CONTACT EMAIL]