Last updated: 21st August 2023
NucleusLinks is a SaaS platform for publishers to help them revolutionize how they monetize content.
Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your acceptance of our use of your personal data as set out in this Privacy Notice.
provides the following services to publishers:
- Automated decisions - Creating an auction for every click-out between CPA, CPS, and CPC partners.
- Consolidated reporting - Aggregating revenues from multiple demand partners in one simplified dashboard.
It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.
Domains and Websites for this Policy
For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.Nucleuslinks.ai as well as the other websites that the Affinity Group operates and that link to this Policy.
Information We Collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
When do we collect Information?
We may collect personal data about you in several circumstances:
Data Required by the SaaS Platform:
- Publisher’s Data - We collect personal data when you sign-up for our SaaS platform. For the creation of user accounts, you provide your name, email address, password, telephone number, and other details for invoicing.
- Data shared by the publishers - We do not collect personal data through our SaaS platform. When publishers integrate with our SaaS platform, we get access to the data such as the Publisher’s network/demand partner’s name, Geography from where the publishers get the data, Number of clicks, and earnings per Geography.
- Contact Us Data - When you enquire about our products and services, we collect and store this data to communicate with you and respond to your enquiry.
- Subscription Data - You provide personal data to us as part of signing up for communication from us through our websites. We may also collect personal information from you when you use interactive features of the Websites, promotions, requesting customer support, or otherwise communicating with us.
- Information collected automatically - In certain cases, we automatically collect personal data when you use our website/services. This data is recorded in log files or other such files. Examples of such data include IP addresses.
Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information about your actions to the owners of the website.
We collect data through cookies:
The categories of cookies used are:
- Strictly necessary cookies - These cookies are needed to run our website, keep it secure, and comply with regulations that apply to us.
- Performance/analytics cookies - Our website may use performance/analytics cookies. These cookies collect information about how visitors use our website and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is used to improve how our website functions and performs
Click here to view the Cookie List
How we use your personal data will depend on which Services you use and how you use those Services.
Lawful bases for processing
We process your personal data only when we have a lawful basis.
Presently, we use the following:
- Consent - We process your data if you have given your consent freely for the same. Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time. Please contact us using the details in this notice's ‘Contact us’ section.
- Performance of contract - We process your data when necessary for the contract’s performance. For example, if the processing is necessary to fulfill our commitments under the applicable terms of service.
- Legal Obligation - We process your data if the use of your information is necessary for compliance with legal obligations.
- Legitimate Interest - We may also process your data on the grounds of legitimate interest for a particular processing activity. For example, to safeguard our services, to understand our user preferences, etc.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
Users under 16 years of age
The Sites and Services do not knowingly collect personal information from users under the age of 16
If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
Data Retention Policy
Data Required by the SaaS Platform:
We will retain information collected in the context of our SaaS Platform until the Publisher uses our platform unless otherwise required by law or applicable contract.
We may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfill our contractual obligations.
After the applicable retention period, we may only retain and use your data:
- in an aggregated or anonymized format;
- to comply with its legal obligations;
- to resolve disputes and enforce agreements.
Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.
We retain your personal data as per our retention policy.
Data Subjects have certain rights in respect of their personal data. The rights given with respect to your personal data include:
- The Right of Access - You have the right to access personal data and supplementary information. You can ask us for a copy of your personal information.
- The Right to Rectification - You can ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
- The Right to Erasure - You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you) without undue delay.
- The Right to Restriction of Processing - You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if you think your personal information is inaccurate or unlawfully held).
- The Right to Data Portability - You have the right to data portability which provides the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit the same to another controller.
- The Right to Object - You have the right to object to the processing of personal data.
- Automated individual decision-making, including profiling - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you (data subject).
- The right to withdraw consent - You have the right to withdraw your consent at any time with effect for the future. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
- The right to lodge a complaint - You have the right to lodge a complaint with the supervisory authority if you are dissatisfied with the way we handle or process your personal data.
Whenever you use our services, we aim to provide you with easy means to access, modify, delete, object to or restrict the use of your personal information.
We strive to give you ways to access, update/modify your data quickly, or delete it unless we have to keep that information for legal purposes. These rights can be exercised by contacting us using the details set out in the "Contact Information" section below.
Website user’s rights
We provide the same rights to the users of our services.
We keep some personal data even after account closure.
Once you choose to close your account, we generally delete your personal information within 3 years of the closure of your account. Some information that is necessary for statutory obligations, such as records of payment processing, and invoicing data will be retained as necessary.
Your information shared with others
Recipients of your data:
NucleusLinks may share the Website user’s data we collect or receive about you as described in this Policy as follows:
- Service Providers - We may share personal information we collect about you with our third- party service providers. The categories of service providers to whom we entrust personal information include: IT and related services such as cloud-based data centers, analytics service providers; service providers for fraud detection; CRM and email marketing services.
- Disclosures to Protect Us or Others - We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Disclosures in the Event of Merger, Sale, or Other Asset Transfers - If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Cross-Border Data Transfers
Your data will be stored and processed in multiple countries, including outside of the European Union (EU) Region. These countries may not have the same standard of data protection laws as your own country. These international transfers of your personal information are made pursuant to the appropriate safeguards.
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centers in Europe and India as well as Affinity data centers in USA. Some countries where we process data may not have as protective laws as your own country, and there are risks associated with such transfer.
NucleusLinks offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our European Union publishers and other international data transfers. These clauses are contractual commitments between parties transferring personal data (for example, between NucleusLinks and its Clients, suppliers, or data processors outside the EU), binding them to protect the privacy and security of the data.
Links to other site
Security Measures to Protect your Data
We implement security controls to prevent breaches and unauthorized access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, restricted access to data, monitoring for threats and vulnerabilities, etc.
We also subject our services to internationally recognized certification and attestation standards. Details about our security measures are available on our Group website.
Protection of personal information
Our Sites and Services use commercial efforts to maintain safeguards for the protection of your Personal Information under all the applicable regulations. To refer to our jurisdiction-specific policy, please click on the link.
NucleusLinks takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally identifying and personally-identifying information.
If you have questions or complaints regarding this Policy, you may contact us through email at firstname.lastname@example.org. You may contact us at our mailing address below
20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are aware of how and why we are using such information.
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.
California Privacy Rights Act(CPRA)
CPRA Categories of Personal Data
No Sale of Personal Data
Nucleus Links has not sold Personal Data in the preceding twelve (12) months.
Right To Opt-Out Of The Sale Of Personal Data
Nucleus Links does not sell your personal data.
If in case, Nucleus Links ever changes its policy and choose to sell Personal Data, you would have the right to opt-out of the sale of your Personal Data by clicking on the Cookies Settings.
We do not generally seek to collect sensitive data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with California Privacy Rights Act("CPRA") requirements. If in case, Nucleus Links ever chooses to use Sensitive Personal Data, you would have the right to limit the use of your sensitive personal Data.
The term "sensitive data" refers to the various categories of personal data identified by CPRA as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
Disclosures of Personal Data for a Business Purpose
In the preceding twelve (12) months, Nucleus Links has not disclosed Personal Data for business purposes.
The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.
- Access to Specific Information
You have the right to request that Affinity disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Deletion Request Rights
You have the right to request Affinity delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Right to Correct Inaccurate Personal Information
You have a right to request for correction of Inaccurate personal information. We shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer.
- Right to Know What Personal Information is Sold or Shared and to Whom
You have a right to request us information about what personal information is sold or shared by us and with whom. Once request received, we shall disclose the following:
- The category or categories of consumers’ personal information it has sold or shared, or if we have not sold or shared consumers’ personal information, it shall disclose that fact.
- The category or categories of consumers’ personal information it has disclosed for a business purpose, or if we have not disclosed consumers’ personal information for a business purpose, it shall disclose that fact.
- Right to Opt Out of Sale or Sharing of Personal Information
You have a right to opt out of sale or sharing of personal information if we sell or share such personal information. We shall prohibit from selling or sharing the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides consent, for the sale or sharing of the consumer’s personal information.
- Right to Limit Use and Disclosure of Sensitive Personal Information
You have a right to request us to limit Use and Disclosure of Sensitive Personal Information. Upon such request we shall prohibit, from using or disclosing the consumer’s sensitive personal information for any other purpose after its receipt of the consumer’s direction unless the consumer subsequently provides consent for the use or disclosure of the consumer’s sensitive personal information for additional purposes.
- Right of No Retaliation Following Opt Out or Exercise of Other Rights – Non-Discrimination
We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Response Timing and Format
We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
CONTACT FOR MORE INFORMATION
20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606