ViralAgain

Privacy Policy

Last updated: May 29, 2026

⚠ Not legal advice — draft only. This page is business-friendly draft language, not written by a lawyer. It contains placeholders [like this] and reflects common practice, not the law of any jurisdiction. A qualified attorney must review, complete, and tailor it (entity, governing law, operating countries, payment/payout/KYC providers, GDPR/UK GDPR, CCPA/CPRA, ePrivacy, consumer, tax, and AML/KYC rules) before publication.
Plain-English summary. Here’s the data we collect and why. We collect account details you give us, and technical data (like IP and device info) needed to run and verify traffic. We use it to operate the platform, verify traffic, prevent fraud, pay publishers, bill advertisers, and meet legal duties. We minimize personal data — for example, IP addresses are hashed or truncated for storage. We don’t sell your personal data. You have rights over your data (access, correction, deletion, and more), and you can contact us to use them.

Purpose. Explain what personal data ViralAgain collects, why, the legal bases, how it is shared, retained, and protected, and the rights users have.

Key sections

  1. Who we are & contact (controller, [DPO])
  2. Data we collect (provided, automatic, from third parties)
  3. Why we use it + legal bases
  4. Cookies / tracking (see Cookie Policy)
  5. Sharing & sub-processors
  6. International transfers
  7. Retention
  8. Security
  9. Your rights
  10. Children
  11. Changes
  12. Contact / complaints

Representative clauses

2. Data we collect

Provided by you: name, email, company details, country, channel/audience info, payout/payment information (handled by our [payout provider]/[payment processor] — we store only tokenized references, not full account/card numbers), and identity-verification documents (via our [KYC provider]). Collected automatically: device and browser data, IP address (stored hashed/truncated), approximate location, and interaction/traffic data used for analytics and verification. From third parties: fraud / IP-intelligence and verification signals.

3. Legal bases (where GDPR / UK GDPR applies)

Performance of a contract (operating accounts, payouts, billing); legitimate interests (fraud prevention, traffic verification, security, product improvement); legal obligation (tax, AML/KYC); and consent (certain cookies/marketing). [LAWYER: map each purpose to a basis.]

5. Sharing

We share data with service providers acting on our behalf (hosting, payments, payouts, KYC, fraud / IP intelligence, email, analytics), under contract, and as required by law. We do not sell personal data. A current sub-processor list is available at [link].

6. International transfers

Where data leaves [region], we use appropriate safeguards such as [Standard Contractual Clauses / adequacy decisions]. [LAWYER.]

7. Retention

We keep personal data only as long as needed for the purposes above and legal requirements: account data for the life of the account plus [period]; raw verification signals for [short period]; financial records for [statutory period]; aggregated/anonymized data may be kept longer.

9. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, port, or object to processing, and to withdraw consent. To exercise them, contact [privacy@…]. You may also complain to your data-protection authority.

Clauses needing legal review

Legal-basis mapping; CCPA/CPRA “sale/share” and opt-out language; international-transfer mechanism; retention schedules; DPO appointment & EU/UK representative; breach-notification commitments; children’s data.

Related policies