CPC/CPS Blended Billing Model Privacy Policy

What is the CPC/CPS Billing Model?

How does it work

What data it collects

What data does it generate?

Data lifetime

How they are used

How we share data with third parties

Lawfulness of data processing

Recommended Compliance Actions

Privacy Update

Categorization of Cookies

 

What is the CPC/CPS Billing Model?

The CPC/CPS Billing Model is one of the AlphaDiscounters partner billing models, according to which billing is done depending on the product category commission on sale. This model, in order to record the purchases made on the websites of partner merchants, after the user goes to them from Alphadiscounters.com, in order to calculate the relevant commission, uses cookies. The CPC/CPS Billing Model works alongside, but also partly separately from, the AlphaDiscounters Analytics functionality, the service for extracting statistics about the performance of AlphaDiscounters participating stores.

How does it work

When a user moves from AlphaDiscounters to a partner store that participates in the CPC/CPS Billing Model at AlphaDiscounters — and if a purchase is actually made — browsing data about the user’s session at that store is transmitted to AlphaDiscounters.

Cookies used to support the CPC/CPS Billing Model are deactivated in any case after 15 days, in accordance with generally accepted sales acquisition practices.

It is clarified that the specific “Billing” cookies are activated without the need for the user’s consent, as they are absolutely necessary for the calculation and settlement of the financial transaction. As long as the user does not give his consent for the “Action” cookies on Alphadiscounters.com, only the “Billing” cookies are activated, while the cookies for the operation of the AlphaDiscounters Analytics service are not.

As long as the user gives his consent for the “Action” cookies on Alphadiscounters.com, when switching to a store with a CPC/CPS Billing Model, the AlphaDiscounters Analytics service and the related cookies are activated, a subset of which is now the billing mechanism /provision of the CPC/CPS Billing Model. In this case, given the user’s consent, the AlphaDiscounters Analytics cookies now serve a dual purpose: extract AlphaDiscounters service usage statistics and calculate AlphaDiscounters fees/fees.

What data it collects

When the user visits a merchant partner website that uses the CPC/CPS Billing Model, their web browser sends certain information to AlphaDiscounters.

Specifically, browsing events such as:

• The transition from AlphaDiscounters to a partner store
• Visits to the partner store’s pages
• The purchase of specific products and its details (order number, amount, products, payment method, etc.)
• Timestamp
• The user’s IP address
• Data related to the respective device (such as the version of the operating system, the connection via app or web, the version of the browser)

The above is linked to an order ID, which does not directly identify the user to AlphaDiscounters. For other categories of data collected by AlphaDiscounters when the AlphaDiscounters Analytics service is also activated.

A user’s information that we receive from partners may be directly associated with that user’s AlphaDiscounters Account (AlphaDiscounters username), only after their specific action (e.g. “Save my order on AlphaDiscounters”).

Otherwise, data collected through the CPC/CPS Billing Model may be considered personal data under applicable data protection law, as it may identify an individual (although not directly identifying that individual). For this reason, they are treated by us in any case and in their entirety as personal data and we apply all appropriate technical and organizational security measures in this regard. You will find some of these measures below.

What data does it generate?

The data derived from the Gross CPC/CPS Billing Model is detailed by store and by market. Since the user has also given his consent for the “Action” cookies on Alphadiscounters.com, analyzes are also produced that capture sales statistics based on the store, the product, and the respective category.

Data lifetime

Information associated with a user’s AlphaDiscounters Account is retained until deletion is requested. Either through their account, or by contacting AlphaDiscounters Data Protection Officer at [email protected]

Browsing information collected by AlphaDiscounters through cookies in view of the CPC/CPS Billing Model is considered by AlphaDiscounters as contractual personal data, able to prove the transaction and support any legal claims of AlphaDiscounters. For this reason, this data will be kept for a maximum of 5 years by AlphaDiscounters. Then, this data will be deleted or completely anonymized (that is, it will no longer be considered personal data by law).

How they are used

When a user visits websites or uses apps that use the CPC/CPS Billing Model, we use the information we receive about purchases from those websites and apps to:

• Calculate and properly invoice the partner for the commission from the use of our services.
• Identify and address fraud and other transactional security risks to protect users and partners.

How we share data with third parties

We do not share personal information with companies, organizations, or individuals outside of our group.

As the collected and generated CPC/CPS Billing Model data is treated by us as personal user data, which is processed to serve common billing purposes between the respective merchant partner and AlphaDiscounters, we are — based on and applicable legislation — as Joint Controllers with each merchant partner using the CPC/CPS Billing Model. In terms of our compliance with this, we undertake to inform users and include specific mention in our agreements with partner merchants.

Lawfulness of data processing

The CPC/CPS Billing Model is a tool that works partially through cookies, which are intended to calculate and clear affiliate pricing for commission from using our services. Applicable legislation is in principle the ePrivacy Directive and the Greek Implementing N.3471/2006, as applicable, and the user’s consent is not required for the placement and subsequent reading of such cookies, which are strictly necessary for the provision of AlphaDiscounters services to users.

In this context, we inform users in detail about the processing of their personal data for transactional purposes, both in the Privacy Notice and the cookies policy of Alphadiscounters.com.

Regarding the legality of processing related to the use of AlphaDiscounters Analytics, please see more in the AlphaDiscounters Analytics Privacy Notice.

Recommended Compliance Actions

According to the legislation, the user should in any case be informed about the use of cookies on his device.

Privacy Update

It is suggested that you add in a separate paragraph to your Cookies Policy or alternatively to your Privacy Notice at least the following:

AlphaDiscounters Service Usage Data

Our company, in order to be able to evaluate and constantly improve the quality of the services it provides to the consumer, uses the AlphaDiscounters Analytics service, which works with cookies. Through this service, as long as you have previously given your consent through Alphadiscounters.com, usage statistics are securely shared by us at AlphaDiscounters. The data received by our company through this service is covered by the Privacy Notice as well as the cookies policy of Alphadiscounters.com, at the end of which you can also withdraw your consent.

In addition, we inform you that, since you have been directed to our online marketplace via Alphadiscounters.com and made a purchase from us, data relating to your specific purchase is securely shared by us with AlphaDiscounters, in the context of our commercial cooperation with AlphaDiscounters and your use of AlphaDiscounters services. The sharing of this data by us is done through cookies and is necessary for the financial settlement of this commercial cooperation, which you may have used. Due to this necessity, the law allows us not to ask for your consent to share this data. More information can be found in the Privacy Notice as well as the cookies policy of Alphadiscounters.com.

Categorization of Cookies

It is recommended to inform the user on your website about the cookies used in the framework of the CPC/CPS Billing Model, (hereinafter AlphaDiscounters CPS cookies) as necessary / necessary including cookie name, purpose, duration, as well as AlphaDiscounters access to them.

User consent is not required for the use of AlphaDiscounters CPS cookies, neither on AlphaDiscounters.com, nor on your website, as these are necessary / necessary cookies for the calculation and financial settlement of the CPC/CPS Billing Model of AlphaDiscounters Services.

Therefore, the following cookies should be presented as necessary / necessary on your website, including the full list below in your cookies policy and placed independently of the user’s consent on your website.

Necessary / Necessary

Name	Purpose	Duration	Third Party Access
_b_nltcs_ss	Distinguishing users. Record of user purchases, after switching from Alphadiscounters.com, for the operation of the CPC/CPS Billing Model billing service.	15 days	AlphaDiscounters
_b_alp_nltcs_ss	Distinguishing users. Record of user purchases, after switching from Alphadiscounters.com, for the operation of the CPC/CPS Billing Model billing service.	15 days	AlphaDiscounters
_b_in_session	Distinguishing users. Record of user purchases, after switching from Alphadiscounters.com, for the operation of the CPC/CPS Billing Model billing service.	30 minutes	AlphaDiscounters
_b_alp_nltcs_mt	Logging of user connection type that makes a purchase after switching from Alphadiscounters.com, to support the pricing service of the CPC/CPS Billing Model.	Until closing the browser	AlphaDiscounters
_b_sa_meta	Logging of user connection type that makes a purchase after switching from Alphadiscounters.com, to support the pricing service of the CPC/CPS Billing Model.	Until closing the browser	AlphaDiscounters
_cf_bm	Website security from malicious/automated traffic.	30 minutes	Cloudfalare

In addition, it is recommended to inform the user on your website about AlphaDiscounters Analytics cookies as performance / analysis / statistics, including cookie name, purpose, duration, as well as AlphaDiscounters access to them.

No second user consent is required on your website to use AlphaDiscounters Analytics. On the contrary, the first consent given by the user to Alphadiscounters.com is required but also sufficient. It is noted that, if the user does not give consent to Alphadiscounters.com through the special mechanism of active (opt-in), distinct (per category of cookies – here “Action” category) and informed (three levels of detailed information) consent, or if he withdraws any such -already given- consent through the special consent withdrawal mechanism found in the Alphadiscounters.com cookies policy, AlphaDiscounters Analytics is not used.

Therefore, the following cookies should be presented as performance / analysis / statistics on your website, including the full list below in your cookies policy and placed independently of the user’s consent on your website.

Performance / Analysis / Statistics

Name	Purpose	Duration	Third Party Access
Analytics_session	Distinguishing users. Support of the AlphaDiscounters Analytics functionality and user purchase reporting, following the transition of users from Alphadiscounters.com.	15 days	AlphaDiscounters
_b_alp_nltcs_ss	Distinguishing users. Support of the AlphaDiscounters Analytics functionality and user purchase reporting, following the transition of users from Alphadiscounters.com.	15 days	AlphaDiscounters
_in_session	Distinguishing users. Support of the AlphaDiscounters Analytics functionality and user purchase reporting, following the transition of users from Alphadiscounters.com.	30 minutes	AlphaDiscounters
_alp_nltcs_mt	Analysis of the interaction of the website users, after their transition from Alphadiscounters.com. The purpose is to evaluate and improve our services, as well as the AlphaDiscounters services, through relevant statistical analysis of usage. May be used in parallel to report user purchases.	Until closing the browser	AlphaDiscounters
_b_sa_meta	Analysis of the interaction of the website users, after their transition from Alphadiscounters.com. The purpose is to evaluate and improve our services, as well as the AlphaDiscounters services, through relevant statistical analysis of usage. May be used in parallel to report user purchases.	Until closing the browser	AlphaDiscounters

It is emphasized that the above advice does not in any way constitute legal advice from AlphaDiscounters to its partners and should not be taken as such. Each partner must ensure their company’s legal and regulatory compliance, including the legislation on the protection of personal data and privacy.