Sarafan respects your privacy and protects your personal data in the best possible way. In
all our operations we ensure that your personal data are processed in the safest manner both
describe what data we collect and how they are used.
The main grounds for processing personal data are our relationships or consent of the data
subject or legitimate interests of the data controller.
1. DATA CONTROLLER
Sarafan Technology, Inc. (“Sarafan”, “we”, “us”, “our”, “Company”)
Address: 838 6 Ave., 6 Fl., New York, NY 10001
Phone: +1 347 480 44 26
2. NAME OF THE REGISTER
Sarafan Technology: partner and client register.
3. PERSONAL DATA
Personal data means any information relating to an identified or identifiable individual.
Identification could be made directly or indirectly, by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or
social identity of that person. “Non-personal data” means any information that cannot be
related to your identity and therefore cannot be classified as personal data, like e.g.
information on browser types, operating systems, domain names, access dates and times,
referring website addresses, online transactions and browsing and search activity.
4. COLLECTION AND PROCESSING OF INFORMATION
We collect, process your personal data. “Processing” means any operation or set of operations
which is performed on data such as collection, recording, organization, structuring,
storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure
The scope of how we collect and process personal and non-personal data on you or other
information depends on the way you get in touch with us or our technologies and
- as a visitor of sarafan.tech;
- as a publisher or an advertiser of the Sarafan affiliate network;
- as a user of our publishers’ and advertisers’ websites.
on every stage.
We use personal data only for administering and providing our technologies and services. We
store personal and any other kind of data strictly in compliance with applicable data
protection and privacy legislation and our contractual duties and will prevent unauthorized
access to data to the best of our abilities.
4.1. If you are a visitor of sarafan.tech
If you visit Sarafan website, no personal data is collected and recorded unless you
provided it voluntarily, e.g. as part of a survey. However, we log the following
non-personal data to facilitate the use of our website and to ensure its security and
stability our web servers:
- the IP address of the requesting device;
- the date and time of your visit;
- the data specifications of your browser and operating system;
- the website you were referred from to our website (so-called Referrer URL).
- This information is stored in a log file until it is automatically deleted.
damage to your device, do not contain viruses, trojans or other malicious software. The
cookie stores information, which is linked to a respective device used. This does not
mean, however, that we store personal information about you or are aware of your
identity. Visiting and surfing on our website is possible without cookies. Most browsers
accept cookies automatically. You may alter the security settings of your web browser to
stop your device receiving and storing cookies, to allow receiving and storing cookies
from selected websites only, or to be notified before receiving cookies. Please note,
however, that these settings may have negative effects on the usability and user
guidance of websites and other online services. You may delete cookies stored in your
browser at any time. Information stored in such cookies will be removed from your
4.2. IF YOU ARE A PUBLISHER OF ADVERTISER
To obtain access to our technologies and services, you need to register in our network.
After that in addition to the data described in section 4.1 we collect and process:
- Your first and last name
- Email address,
- Mailing address,
- Phone number,
- Payment information.
Publishers and advertisers voluntary provide to us provide the information while:
- Registration for our Service during which you provide us your name, phone
number, e-mail address for instance,
- Fill into the contact form;
- Contacting us via e-mail or phone number;
- Participating in influencer program;
- Signing into your Account,
- Signing into your Account and using our Services by using other accounts, such
as your e-mail, social media or payments accounts.
This processing of personal data is necessary for the performance of a contract, Art. 6
sec. 1 lit. b GDPR. We do not collect or use any further personal data other than
voluntarily provided by you.
4.3. If you are a user of our publishers’ and advertisers’ websites
We store cookies on devices of users who are visiting websites and using online services
of our publishers and advertisers. These cookies store the information on:
- when and on what device a click on an advertisement occurred;
- the advertiser’s affiliate program;
- the publisher;
- the specific time of the user’s action.
While tracking we may also collect information on the device that is used to perform a
conversion such as a device’s operating system and browser.
The purpose of this data
processing is to track conversions (leads and sales such as installing an application or
placing an order in an online shop) and to allocate them to proper publishers. It is
necessary for the performance of a contract with third parties (our advertisers’ and
publishers) that make use of our services, Art. 6 sec. 1 lit b) GDPR.
If you do not want Sarafan to collect and store your data, please inform us about this.
Please note, that it may affect the functionality of the websites that Sarafan works
with. Please note that although we choose our business partners and clients carefully,
we are not responsible for the privacy practices of websites and mobile applications
operated by such third parties. You should check the applicable privacy policies of such
websites and mobile applications you visit for more information on what kind of data
they are processing with the help of our services and technologies and how they handle
any data they collect from you as well as the legal base(s) for that processing.
Sarafan does not conduct behavioral advertising and does not collect data for these
For this reason, we would like to draw your attention to the possibilities
to object against the collection of data for purposes targeted advertising on the
websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/en/ (for
the European area).
5. PURPOSE FOR INFORMATION COLLECTING
Your information helps us more effectively respond to your needs as our website and Services
user. The information is needed for delivery to you our Services. The information you
provide us couldn’t be used for any other purpose than delivering you the requested Services
or improving them.
6. THE INFORMATION WE COLLECT COULD BE USED IN THE FOLLOWING WAYS
The information and feedback we are getting help us constantly improve our website and our
Services so they meet current and future visitors’ needs. We also use the information to
improve our client and partner services.
We are happy to send you periodical email updates because it helps to be in touch with you.
By subscribing to our newsletter, you agree to the receipt of the newsletter and the
We send out newsletters, e-mails and other electronic notifications with promotional
information (hereinafter "Newsletter") subject to the consent of the recipient or a legal
The registration for our newsletter is handled through a so-called double opt-in procedure,
which means you will receive an e-mail after your registration, in which you will be asked
to confirm your registration once again. The registrations for the newsletter are recorded
to prove the accurate registration process according to legal requirements. This includes
storing the time of login and confirmation. The newsletters can be sent by Sarafan itself or
by means of a third-party service.
At any time, you can unsubscribe from receiving emails, by going to unsubscribe page via the
link located at the bottom of every email.
We may use your personal information for informing you about any changes at website and
Services, such as sending you technical notices, updates, general information or legal and
regulatory provisions or warnings about different types of risks.
7. TERMS OF PERSONAL DATA STORAGE
Your personal data are stored in the register only if it is essential for the purposes set
out in this data protection policy and for compliance with a legal obligation to store data.
It is possible that due to a legal obligation Sarafan can be required to store data longer
than the above mentioned envisaged period.
Any outdated and unnecessary data are erased in an appropriate manner. Data are entered in
the register in the form used by the data subject to give them and they can be updated by
the data subject personally or by Sarafan on request of the data subject.
8. DISCLOSER OF INFORMATIONM
Under no circumstances we couldn’t sell or share your personal information with the third
parties, except to the following extents:
- a. Third party vendors operating our Services, including legal services, payment
processing, billing, IT support, research, analytics, data storage, validation,
security, fraud prevention and payment processing.
- b. Our group companies to provide you constant level of services.
- c. Third parties in the event of any merger, sale, joint venture, transfer or other such
disposition of any portion of Sarafan’s assets.
The access to the information could be done only under appropriate organizational and
technical conditions which would ensure the protectiveness of the information. We take all
reasonable steps to ensure confidentiality and privacy obligations. The disclosure of your
personal data to third parties to the extent required by law, court order or a decision
rendered by a competent public authority and for law enforcement.
9. DATA TRANSFER
Personal data collected by Sarafan may be stored and processed in your region, in the United
States for example, or in any other country where Sarafan, its affiliates, subsidiaries or
service providers are located or maintain facilities. Sarafan has put in place adequate
mechanisms to protect personal information when it is transferred internationally.
10. RIGHTS APPLICABLE TO EU/EEA USERS
If you are based in European Union (“EU/EEA”) or in any other region where the laws governing
data collection and you that may differ from EU/EEA or US law, please note that note that
you may be transferring your Personal Information to the Sarafan in the United States and in
will use all adequate mechanisms to protect your Personal information when it is transferred
internationally. Your personal data could be transferred to the authorities only if required
or for purposes stipulated by law.
If you are a visitor from the European Economic Area, our legal basis for collecting and
using the Personal Information described above will depend on the Personal Information
concerned and the specific context in which we collect it. For the European Economic Area,
there are different legal bases that we rely on to use your Personal Information for
consent, the performance of a contract and legitimate interests.
If you subject to EU you may access, correct, update or request deletion of your information,
object to processing of your Personal Information, ask us to restrict processing of your
Personal Information or request portability of your Personal Information, withdraw your
consent at any time, complain to a data protection authority about our collection and use of
your Personal Information, to exercise any of these rights at any time by contacting us at
e-mail shown above. In order to delete your account and all Personal information please
contact us at firstname.lastname@example.org.
Please note that if you are not subject to EU law, these rights do not apply to you.
information and data about the way the website is used. These data are utilized to develop
the website in order to make it match the demands of our clients even better. We use the
following types of cookies:
- Strictly necessary cookies. These cookies are essential for you to browse our website
and use its features. Without these cookies, some online services cannot be provided.
- Functional cookies. These cookies allow our websites to remember choices you make while
browsing and personalize your experience. We may store your geographic location in a
cookie, for instance, to ensure that we show you the website relevant to your area.
blocked some of the website functions may get slower or access to some parts of the website
can be blocked completely.
We take security seriously, and the security of your personal data is important to us. We
follow industry-standard practices to protect the data we collect and maintain, including
using Transport Layer Security (TLS) to encrypt information as it travels over the internet.
No method of transmission over the internet or electronic storage is completely secure, so
Sarafan cannot guarantee its absolute security.
13. CHANGES TO DATA PROTECTION POLICY
Sarafan is constantly improving its operations and therefore we reserve the right to change
our data protection policy, to be announced through our website. The changes can be related
to changes in legislation. We recommend you review the contents of data protection policy
14. USE BY CHILDREN
Sarafan does not target and is not intended to attract children. Accordingly, our services
are not directed at and should not be accessed by individuals under the age of sixteen (16
years), and we request that such individuals do not provide any personal data to Sarafan.
Minors must obtain express consent from parents or legal guardians prior to accessing or
providing any personal data. If notified by a parent or guardian or discovered by other
means, that a child under age of sixteen has provided his or her personal data to Sarafan,
we will delete the child’s personal data in our possession.
15. CONTACT US