Privacy Policy

1. General

1. By providing your personal data, you consent to Fanzoone OÜ (Tornimäe tn 5, Kesklinna linnaosa, Tallinn, Harju maakond, 10145, Estonia, registry code 16537736 — the “Site”) processing, storing and using it in line with applicable data-protection law, including the EU GDPR and, where relevant, US state privacy laws such as the CCPA.
2. The current version of this Policy is a public document, available to anyone at secretdiscounter.net/privacy-policy.
3. We may amend this Policy unilaterally, provided the changes do not conflict with applicable law.
4. Changes take effect once published on the Site.
5. By registering and using the Site, you agree to this Policy.
6. If you do not agree with it, stop using the Site and its services immediately.

2. Using the Site

1. In providing the Site and its services, we act reasonably and in good faith, and we assume that you: hold all rights needed to register and use the Site; provide accurate information about yourself, to the extent needed to use our services; understand that information you post about yourself may become visible to other users and may be copied and distributed by them; and have read this Policy, agree to it, and accept the rights and obligations it sets out.
2. We do not verify the accuracy of the information we collect about users, except where such verification is necessary for us to meet our obligations to you.

3. Why We Process Your Data

We process information about you, including personal data, in order to:

• register you on secretdiscounter.net;
• provide customer support;
• send you information about promotions and offers;
• meet our obligations to you;
• run audits and internal research to improve the quality of our service.

Do Not Track. Some browsers send a “Do Not Track” signal. There is no agreed standard for what a site must do with it, and we do not act on it — we would rather tell you that than quietly ignore it. The controls that do work are the ones in your account settings and in your browser’s cookie preferences. Note that switching off the cashback cookie switches off the cashback with it; that is explained in the Cookie Policy.

4. What We Collect

Personal data means any information that identifies you, such as:

• name;
• date of birth;
• gender;
• country and city;
• email address (required to register and to contact support);
• phone number;
• payout details — the e-wallet, payment-service or crypto-wallet address we send your cashback to. We never ask for, receive or store your bank card number. You pay the store, not us: your card details go to the Advertiser and its payment processor, and never pass through SecretDiscounter;
• on request, a copy of an ID document or another document showing your name and photo, where we reasonably need it to verify who you are and prevent abuse or harm to third parties.

Other Information We Process

We may also store and process information that includes:

• technical data captured when you access the Site — your IP address, operating system, browser type, approximate location, internet provider — and your subsequent activity on the Site;
• information collected automatically through cookies.

SecretDiscounter uses cookies (small text files placed on your device) and similar technologies to run our websites and services and to collect data. Cookies let us remember your settings, keep you signed in, deliver relevant advertising, help fight fraud, and measure how well our services work. Most importantly, cookies are how your purchase is tracked — without them the store cannot tell that we sent you, and no cashback can be paid. You can manage or refuse cookies using your browser controls, though doing so will stop cashback from tracking. See our Cookie Policy.

• click and order records — every click from the Site to an Advertiser that could earn cashback (which store, when, from web, app or extension), and what the Advertiser subsequently reports back to us about the resulting order: its date, its value and its status. This is the core of the service: it is how cashback is credited to you rather than to somebody else, and it is what you see in Visit history in your account;
• information generated by your actions on the Site (reviews you leave, likes).

All of It in One Table

What we hold, why we hold it, and where it came from. If a row has no purpose you recognise, ask us and we will either justify it or delete it.

5. How We Process It

1. We process personal data on the principles of: lawfulness of purpose and method; good faith; consistency between the purposes of processing and the purposes stated when the data was collected; and proportionality between the volume and nature of the data processed and the purpose of processing.
2. We collect your personal data when you register, and later when you add further details about yourself through the Site.
3. Personal data is stored on electronic media only and processed by automated systems, except where non-automated processing is required by law.
4. We do not sell your personal data. We do not trade it, and we do not hand it over for anyone else’s advertising.
5. We pass data to third parties only where the service cannot work without it, and only the minimum required:
   
   • Affiliate networks and Advertisers. A network sits between us and each store; it is what tells the store that a shopper came from us and tells us what to credit you. If cashback goes missing and you file a claim, we pass the details of that order — date, amount, order number and any proof you supply — to the Advertiser through its network, so it can rule on the claim. Without that, a claim cannot be raised at all.
   • Payout providers — the payment service you chose, so it can pay you.
   • Suppliers who run our infrastructure, email and support under a duty of confidentiality.
   • Authorities — in response to lawful requests, on the grounds and in the manner prescribed by law.
   
   Some of these are based outside your country. Where they are, we transfer data only under the safeguards applicable law requires.
6. Who those third parties actually are. “Trusted partners” is the phrase every privacy policy hides behind. Here is the list:

   Who	What they get	Why they need it
   Affiliate networks	An anonymous click identifier; on a claim — the order’s date, amount and number	They sit between us and every store. Without them the store cannot tell your purchase came from us, and no cashback exists at all
   Advertisers (the stores)	Only what a claim needs: date, amount, order number, your proof	Only when your cashback went missing and you asked us to chase it. A claim cannot be raised without them
   Payout providers	The payout address you chose and the amount	To move the money. They see the transfer, not your shopping
   Infrastructure & email	Whatever passes through hosting, storage and mail delivery	To run the site and send the emails you asked for. Bound to confidentiality; they do not use your data for themselves
   Analytics	Aggregated, non-identifying counts of page use	To see which pages people actually use. Nothing in it identifies you
   Authorities	What the law requires, no more	Only on a lawful request, on the grounds and in the manner prescribed by law

   That is the whole list. Nobody else — no advertising brokers, no data resellers, no “marketing partners”, no social networks. Some of these sit outside your country; where they do, we transfer data only under the safeguards applicable law requires.

7. Referrals. If you joined through a friend’s referral link, that friend can see limited information about you — that you registered, when, and whether your cashback has crossed the threshold that pays them. They cannot see what you bought, where, or for how much.
8. How long we keep it. We keep your personal data for as long as your account exists and you are using the service. When an account is deleted — by you, or by us in the cases set out in the Terms of Use — we delete or anonymise your data, except what we must retain to meet legal obligations (tax and accounting records, for example), to settle a dispute already under way, or to prevent fraud. We do not keep it longer than those purposes require.

6. Your Rights

You may:

• access information about yourself, free of charge, by signing in to your account;
• correct or update that information yourself, provided the new information is accurate and current;
• delete information about yourself from your account;
• ask us to correct, block or delete your personal data where it is incomplete, out of date, inaccurate, unlawfully obtained or no longer needed for the stated purpose — if you cannot change or delete it yourself.

Depending on where you live — under the EU GDPR, or under US state law such as the California CCPA/CPRA — you also have the right to:

• know what categories of personal data we hold about you, where we got them, and what we use them for;
• obtain a copy of that data in a portable form;
• delete it, subject to what we must keep by law;
• opt out of your data being shared for anyone else’s advertising. We do not sell personal data and never have — but the right exists and we will honour it;
• withdraw marketing consent at any time in your account settings, or via the unsubscribe link in any marketing email;
• not be discriminated against for exercising any of these rights. Your cashback rate, your loyalty status and your access to the service do not change because you asked.

To exercise any of them, open a ticket in your account. We may need to verify who you are first — that is a protection for you, not an obstacle: we will not hand your data to somebody claiming to be you.

Note that deleting your data means deleting your account. Withdraw any confirmed balance first: once the account is gone there is nowhere to pay it to, and cashback still Pending at that moment is forfeited — the Advertiser has not paid us for it yet.

7. How We Protect Your Data

1. We take technical and organisational measures to protect your personal data from unlawful or accidental access, destruction, alteration, blocking, copying or distribution, and from any other unlawful act.
2. Access to the Site is authorised with your login (email) and password. Keeping these safe is your responsibility. Do not share your login or password with anyone, and take reasonable steps to keep them confidential.

8. Scope

1. This Policy does not apply to the actions or websites of third parties.
2. We are not responsible for the actions of third parties who gain access to information about you through your use of the internet or of the Site.
3. Children. The service is for adults: registration requires you to be 18 or over. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we delete the account and the data. If you believe a minor has registered, tell us and we will act.