1. Introduction

We at Winzilla Limited and/or any of our related entities (herein referred to as: “Winzilla”, “We”, “Our”, “Us”) have created this Privacy Policy to demonstrate our dedication to respecting your privacy.

This Privacy Policy sets out our practices with respect to personal information collected from the visitors of https://cannonball.partners/ (hereafter referred to as the “Website”) as well as registered affiliates (collectively referred to as “you”).

The Site operates the Cannonball Affiliate Program (hereafter referred to as the “Platform”) owned by Winzilla Ltd, incorporated and registered under the laws of the laws of the Republic of Cyprus with registration No. ΗΕ 474611 and having its registered office at 39 Dimofontos Street, 3rd Floor Office 301, Nicosia, 1075, Cyprus.

We take our responsibility to be transparent about how we safeguard your information seriously. This Privacy Policy is designed to provide clarity on these matters. It outlines the types of Personal Information we collect, as well as how we collect, use, store, protect, and share this information. Additionally, it explains the rights and choices available to you regarding your Personal Information.

2. Definition Of Personal Information

Personal Information refers to any data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user. Personal Information doesn't include publicly available, de-identified, or aggregate user information.

3. Personal Information We Collect

We may collect and process the following types of Personal Information:

• Personal Details: Includes but not limited to your name, username or login credentials, password, date of birth/age;
• Contact Information: Such as your email address, telephone number and any additional contact details provided;
• Location Data: General geographic information;
• Consent Records: Documentation of any consent you have given, including the date, time, and method of consent, along with any relevant details;
• Usage Data: Information about how you use our Website and Services, including statistical usage metrics, device used, its settings, and installed software, device IDs, advertising IDs, and Internet Protocol (IP) addresses.
• Payment Information: payment method information such as bank account information (to the extent needed to pay for or receive payment as part of providing services of our Platform), invoices, prices, billing addresses, and payment histories.

4. Legal Basis For Processing Your Personal Information

As a rule, our legal basis for the processing of personal data are:

• your consent; 
• performance of a contract;
• legal obligation; and 
• our legitimate business interest.

Purposes and legal bases. We rely on the following legal bases for each purpose:

• Provide our Services and manage your account. Performance of a contract (Art. 6(1)(b) GDPR).
• Process requests and payments; pay affiliate commissions. Performance of a contract (Art. 6(1)(b)) and legal obligation for tax/accounting (Art. 6(1)(c)).
• Communicate with you about the Platform. Performance of a contract (service communications) (Art. 6(1)(b)); Legitimate interests for service improvement and admin notices (Art. 6(1)(f)). 
• Improve, secure and debug the Website/Platform; prevent fraud/abuse. Legitimate interests (network and information security; fraud prevention) (Art. 6(1)(f); Recitals 47, 49). 
• Marketing (including email/SMS/push). Consent where required by e-privacy rules; otherwise Legitimate interests (Art. 6(1)(a)/(f); Recital 47). You can object or opt out at any time.
• Analytics and audience measurement.Consent (Art. 6(1)(a)). 
• Compliance with laws, regulatory inquiries, enforcement of terms. Legal obligation and/or Legitimate interests (Art. 6(1)(c)/(f)).

When we rely on legitimate interests, we balance our interests against your rights using a documented test. Typical interests include ensuring platform security, preventing fraud, and limited direct marketing to our affiliates. 

• You may object to processing based on our legitimate interests at any time—especially to direct marketing—by contacting us at dpo@cannonballcode.com or using any unsubscribe mechanism (Art. 21 GDPR).

5. How We Collect Personal Information

The data we collect about you depends on the context of your interaction with us, the Site or the Platform, the choices you make, and the services and features you use. We obtain your personal data mainly through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal information.

Information you directly provide to us:

• when you complete our registration or other forms, which are available on our Site or Platform;
• when you performing contractual obligations;
• when you contact us for any requests, support, complaints, or for any other reason

Personal information collected from other sources:

• via third parties including our business partners, advertisers, contractors, and/or vendors in a manner that is permitted, through tags in websites you use and/or manage or control.

Automatic Information. Like many websites, we use “cookies” and other unique identifiers (if used alone, these technologies do not personally identify you) and we obtain certain types of information:

• when your web browser or device accesses the Website or Platform.
• when you interact with content and services available through Website or Platform.

Cookies:

We automatically collect certain information when you visit, use, or navigate the Site. This information does not reveal your specific identity (like your name or contact information). Still, it may include device and usage information, such as your IP address, browser and device characteristics, operating system, referring URLs, device name, country, location, information about how and when you use our Site, and other technical information. This information is primarily needed to maintain the security and operation of our Site and for our internal analytics and reporting purposes.

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

• Note: that certain cookies are necessary to enable the Site to operate and refusing or disabling some or all cookies may limit your ability to make use of the Site.

6. We Use The Information We Collect For The Following Purposes

7. Who Do We Share Your Personal Information With

We may share your personal information with the following categories of third parties:

• Payment providers who assist us with the verification of payments and the processing of payments;
• Web hosting, optimization, email marketing services, management, and CRM companies who assist us with the hosting, operation, optimization, and maintenance of our Site, the administration of the Platform accounts, and the provision of access to secure areas and functionality on our Site;
• Analytics. We may use web analytics services offered by Google or other third parties that track and report website traffic

We may also disclose information about you:

• if we are required to do so by law or legal process;
• to law enforcement authorities or other government officials;
• when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• if necessary to protect the vital interests or legal of another individual;
• in connection with a corporate reorganization or a sale or transfer of all or a portion of our business or asset; or
• to any other person with your consent to the disclosure.

8. Transfer Of Personal Information

The collected Personal Information may be stored, processed, and transferred to any country in which we or our affiliates or processors have facilities. If the country to which we transfer Personal Information does not guarantee sufficient levels of protection, the transfer will only take place once we have reached a specific agreement with the receiving third party that includes safeguard clauses and/or the necessary safeguards to protect your Personal Information will be carried. By submitting your Personal Information, you agree to the aforementioned transfer, storage, processing and sharing of your Personal Information. We may transfer personal data outside the EEA/UK (e.g., to service providers). Where we do so, transfer of personal data will be handled under Standard Contractual Clauses (“SCC”).

9. Retention

We will retain your Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy, including providing our Services to you. We may also retain and use your Personal Information to comply with legal obligations, resolve disputes, and enforce our agreements. In certain instances, Personal Information may be stored for extended periods if it is processed for purposes such as archiving in the public interest, scientific or historical research, or statistical analysis. In such cases, we will implement appropriate technical and organizational measures to protect your rights and freedoms.

10. Information For The Residents Of The European Union

If you are located in the European Economic Area, the United Kingdom, or Switzerland (the “European Countries”), you have certain rights and protections under Regulation (EU) 2016/679 (General Data Protection Regulation) and The United Kingdom General Data Protection Regulation (UK-GDPR) regarding the processing of your “personal data” as defined under applicable law. Some of the information that Winzilla collects from you through its operation of the Site may constitute “personal data” under these laws.

Winzilla is the controller for personal data it collects about affiliates and visitors to the Website/Platform. Where we provide services to advertisers or other partners that require us to handle personal data on their documented instructions, we act as a processor for that partner. In those cases, the partner’s privacy notice applies to their processing and our obligations are set out in our data processing agreements.

Notice that Winzilla will not be held responsible for the data collected by affiliates or advertisers who contract the services of Winzilla.

What Data Protection Rights Do You Have

As available and except as limited under applicable law, the rights afforded to residents of European Countries are:

• Right of access – the right to be informed of, and request access to, the personal data we process about you;
• Right to rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to erasure – the right to request that we delete your personal data;
• Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
• Right to withdraw – You have the right to withdraw your consent at any time.
• Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
• Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

We do not make decisions based solely on automated processing that produce legal or similarly significant effects about you. If we ever introduce such processing, we will provide meaningful information about the logic involved and your rights in advance.

Exercising Your Rights

We respond to GDPR/UK-GDPR requests without undue delay and within one month of receipt. We may extend by up to two months for complex/multiple requests and will tell you why within the first month.

Requests are free of charge unless manifestly unfounded or excessive. We may ask for information needed to verify your identity.

We have assigned a Data Protection Officer (DPO) who may be reached via dpo@cannonballcode.com Our DPO is tasked with ensuring that we acknowledge and abide by our data protection responsibilities.

You also have the right to lodge a complaint with an EU/UK supervisory authority, including in Cyprus (Office of the Commissioner for Personal Data Protection), your country of residence, place of work, or where you believe an infringement occurred.

11. California Consumer Privacy Rights

The California Consumer Privacy Act (“CCPA”) (as augmented and amended by the California Privacy Rights Act, or “CPRA” (California Civil Code Section 1798.100 et seq.)) gives California residents certain rights with respect to the processing of personal data. Under CCPA, “Personal Information” is defined as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.

The categories of personal information the Winzilla collects as well as the Purposes and Legal Basis for Processing Personal Information are described in Section 3 and Section 4 above.

What Data Protection Rights Do You Have

As a California resident, you have certain rights with respect to the personal information collected by businesses.

• Right to Access. You have the right to receive information about the types of personal information that Winzilla collects, uses, discloses, and sells. Specifically, this right allows you to ask Winzilla for the following information: (a) the categories of personal information that Winzilla collects about you; (b) the categories of sources from which Winzilla has obtained personal information about you; (c) Winzilla’s business or commercial purpose for collecting or selling your personal information; (d) the categories of your personal information that Winzilla sells to third parties; (e) the categories of third parties that Winzilla sells your personal information to; and (f) the specific pieces of personal information that Winzilla has collected about you. Winzilla must disclose this information to you when you exercise your right to know, subject to proper verification of your request. You may make a verifiable consumer request related to your personal information free of charge twice per 12-month period.
• Right to Correct Inaccurate Personal Information. If you have reason to believe that Winzilla maintains inaccurate personal information, you have the right to request Winzilla to correct your inaccurate personal information.
• Right to be Forgotten. You have the right to request that Winzilla delete any personal information it has collected or maintains about you, subject to certain exceptions for business purposes outlined in the applicable law. Once Winzilla receives and confirms your verifiable consumer request, Winzilla will delete your personal information from its records, unless an exception applies.
• Right to Non-Discrimination. You have the right to non-discrimination if you exercise any of your rights under the CCPA. 
• Right to Opt-Out. You have the right to direct Winzilla to not sell or share your personal information to third parties at any time.

We do not “sell” or “share” California Personal Information.

Exercising Your Rights

We will respond within 45 days; we may extend once by 45 days where reasonably necessary and will notify you within the first 45 days. We will not require you to create an account to submit a request.

We have assigned a Data Protection Officer (DPO) who may be reached via dpo@cannonballcode.com Our DPO is tasked with ensuring that we acknowledge and abide by our data protection responsibilities.

12. Security

We maintain appropriate technical and organizational measures to safeguard the information we collect about you, including compliance with legal, privacy, and contractual obligations. Additionally, we require our partners to uphold contractual commitments regarding the collection, use, and handling of user data. However, no system can guarantee absolute security, and you accept certain risks regarding the security of Personal Information shared with us. If a breach involving your Personal Information occurs, we will notify you as required by applicable law.

13. Changes To The Policy

We may make changes to this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Privacy Policy in the future will be posted on this page, and where we change this Privacy Policy in ways that also affect how we process personal information about you, where appropriate, we will notify you via email or other contact with you, and we also may post a notice on our home page that this Privacy Policy has changed.