Privacy Policy

Last Updated: January 2025

1. Introduction

Evangeler Limited ("we", "our", or "us") is committed to protecting your privacy in accordance with the Privacy Act 2020 of New Zealand. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our affiliate marketing platform at evangeler.app ("Service").

By using our Service, you consent to the data practices described in this policy. If you do not agree with this policy, please do not use our Service.

2. Information We Collect

2.1 Personal Information You Provide

We collect information you provide directly to us, including:

  • Account Information: Name, email address, business name, and contact details
  • Payment Information: PayPal email address for affiliates, billing information for merchants (processed securely through third-party payment processors)
  • Profile Information: Business description, website URL, social media profiles
  • Communication Data: Messages, support requests, and feedback you send to us

2.2 Information Collected Automatically

When you use our Service, we automatically collect:

  • Log Data: IP address, browser type, operating system, referring URLs, pages visited, date/time stamps
  • Device Information: Device type, unique device identifiers, mobile network information
  • Tracking Data: Affiliate link clicks, conversions, commission data, campaign performance metrics
  • Cookies and Similar Technologies: Session cookies, persistent cookies, web beacons, and pixel tags

2.3 Google Analytics

We use Google Analytics to analyze usage of our Service. Google Analytics collects information such as:

  • How often users visit the Service
  • Pages visited and time spent
  • Websites visited before arriving at our Service
  • General geographic location (country/city level)

Google Analytics uses cookies and may collect certain personally identifiable information. You can opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

3. How We Use Your Information

We use collected information for the following purposes:

  • Service Provision: To create and manage accounts, process transactions, track affiliate performance
  • Communication: To send service updates, respond to inquiries, provide customer support
  • Improvement: To analyze usage patterns, improve functionality, develop new features
  • Security: To detect fraud, prevent abuse, maintain service security
  • Legal Compliance: To comply with legal obligations under New Zealand law
  • Marketing: With your consent, to send promotional materials about our services

4. Legal Basis for Processing (Privacy Act 2020 Compliance)

We process your personal information based on:

  • Contract Performance: Processing necessary to provide our Service under our Terms of Service
  • Consent: Where you have given explicit consent for specific processing activities
  • Legitimate Interests: For business operations, fraud prevention, and service improvement
  • Legal Obligations: To comply with New Zealand laws and regulations

5. Information Sharing and Disclosure

5.1 Service Providers

We may share information with third-party service providers who perform services on our behalf:

  • Payment processors (for subscription billing)
  • Email service providers
  • Analytics providers (Google Analytics)
  • Cloud hosting services

5.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5.3 Legal Requirements

We may disclose information when required by New Zealand law or in response to:

  • Court orders or subpoenas
  • Requests from law enforcement agencies
  • Requirements under the Privacy Act 2020
  • Protection of our legal rights or safety of users

5.4 Affiliate Network Data

Merchants can view their affiliates' performance data. Affiliates can view their own performance and commission data. Personal contact information is only shared with explicit consent.

6. Data Retention

We retain your information for as long as necessary to:

  • Provide our services to you
  • Comply with legal obligations (7 years for financial records under New Zealand tax law)
  • Resolve disputes and enforce agreements
  • Maintain business records for legitimate business purposes

When your account is closed, we will delete or anonymize your personal information within 90 days, except where retention is required by law.

7. Data Security

We implement appropriate technical and organizational measures to protect your information:

  • SSL/TLS encryption for data transmission
  • Encryption at rest for sensitive data
  • Regular security audits and updates
  • Access controls and authentication measures
  • Employee training on data protection

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Your Rights Under the Privacy Act 2020

Under New Zealand's Privacy Act 2020, you have the right to:

8.1 Access

Request access to personal information we hold about you.

8.2 Correction

Request correction of inaccurate or incomplete personal information.

8.3 Deletion

Request deletion of your personal information, subject to legal retention requirements.

8.4 Objection

Object to certain processing of your personal information.

8.5 Portability

Request a copy of your personal information in a structured, machine-readable format.

8.6 Complaints

Lodge a complaint with the Office of the Privacy Commissioner if you believe we have breached your privacy.

To exercise these rights, contact us at [email protected]. We will respond within 20 working days as required by law.

9. International Data Transfers

Your information may be transferred to and processed in countries outside New Zealand, including:

  • United States (for Google Analytics and cloud hosting)
  • European Union (for certain service providers)

We ensure appropriate safeguards are in place for international transfers, including contractual clauses requiring protection equivalent to New Zealand standards.

10. Cookies Policy

10.1 What Are Cookies

Cookies are small text files stored on your device when you visit our Service.

10.2 Types of Cookies We Use

Cookie Type Purpose Duration
Essential Required for Service functionality (login, security) Session
Analytics Google Analytics tracking 2 years
Performance Monitor Service performance and errors 1 year
Tracking Affiliate link tracking and attribution 30 days

10.3 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect Service functionality.

11. Children's Privacy

Our Service is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we discover we have collected information from a child under 18, we will delete it immediately.

12. Marketing Communications

We comply with the Unsolicited Electronic Messages Act 2007. Marketing emails will:

  • Only be sent with your consent
  • Clearly identify us as the sender
  • Include an unsubscribe option
  • Honor unsubscribe requests within 5 working days

13. Data Breach Notification

In the event of a notifiable data breach as defined under the Privacy Act 2020, we will:

  • Notify affected individuals as soon as practicable
  • Notify the Privacy Commissioner where required
  • Take immediate steps to contain and remediate the breach
  • Document the breach and our response

14. Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last Updated" date
  • Sending an email notification for significant changes

Continued use of the Service after changes constitutes acceptance of the updated policy.

16. Privacy Officer Contact

For privacy-related questions, concerns, or to exercise your rights, contact our Privacy Officer:

Privacy Officer
Evangeler Limited
Email: [email protected]
Response time: Within 20 working days

17. Complaints to Privacy Commissioner

If you are not satisfied with our response to your privacy concern, you may contact:

Office of the Privacy Commissioner
PO Box 10094
Wellington 6143
New Zealand
Phone: 0800 803 909
Email: [email protected]
Website: www.privacy.org.nz

18. Specific Provisions for EU Users (GDPR)

If you are accessing our Service from the European Union, additional rights and protections apply under the General Data Protection Regulation (GDPR), including:

  • Enhanced consent requirements
  • Right to restrict processing
  • Right to withdraw consent at any time
  • Right to lodge complaints with EU supervisory authorities

19. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to opt-out of the sale of personal information. We do not sell personal information.

20. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects on you.