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Privacy Policy

Last updated: January 2025

1. Our Role as Intermediary

Sample CPA acts as an intermediary service provider connecting advertisers with traffic sources. We do not directly collect, process, or store end-user personal data from advertising campaigns. All data processing related to advertising campaigns is performed by the respective Advertisers and Publishers who are independent data controllers.

2. Data We Collect

We only collect limited business contact information from our partners:

  • Business name and contact details (Telegram, email, Skype)
  • Payment information for commission processing
  • Campaign performance statistics (aggregated, non-personal data)
  • Communication records for business purposes

3. Data Controller Responsibilities

Advertisers are the sole data controllers for:

  • All personal data collected through their landing pages, forms, and offers
  • Customer data, leads, and conversion information
  • Compliance with GDPR, CCPA, and other applicable data protection laws
  • Providing privacy notices and obtaining consent from end users
  • Handling data subject requests (access, deletion, rectification)

Publishers and Traffic Providers are the sole data controllers for:

  • Data collected through their websites, apps, and traffic sources
  • Cookie consent and tracking compliance
  • User consent for targeted advertising
  • Compliance with platform-specific privacy requirements

4. No Liability for Partner Data Practices

Sample CPA disclaims all liability for the data collection, processing, storage, and protection practices of Advertisers, Publishers, and any third parties. We do not audit, verify, or monitor their compliance with privacy laws. Each partner is independently responsible for their own data protection obligations.

5. Third-Party Services

Our partners may use various third-party services, tracking pixels, analytics tools, and advertising platforms. Sample CPA has no control over and assumes no responsibility for the privacy practices of these third parties. Users should review the privacy policies of each service independently.

6. International Data Transfers

Advertising campaigns may involve international data transfers. Advertisers and Publishers are solely responsible for ensuring appropriate legal mechanisms (Standard Contractual Clauses, adequacy decisions, etc.) are in place for any cross-border data transfers they perform.

7. Data Security

While we implement reasonable security measures for our own systems, we cannot guarantee the security of data processed by our partners. Advertisers and Publishers are responsible for implementing appropriate security measures for data under their control.

8. Data Retention

We retain business partner information for the duration of our business relationship and as required by law. Campaign statistics are retained in aggregated form. For personal data collected by Advertisers or Publishers, please contact them directly.

9. Your Rights

For any personal data we hold about our business partners, you may request access, correction, or deletion by contacting us. For data collected through advertising campaigns, please contact the relevant Advertiser or Publisher directly.

10. Regulatory Complaints

Any regulatory complaints, inquiries, or enforcement actions related to data processing in advertising campaigns should be directed to the respective Advertiser or Publisher acting as data controller. Sample CPA will cooperate with authorities but is not the appropriate respondent for such matters.

11. Changes to This Policy

We may update this Privacy Policy at any time. Continued use of our services constitutes acceptance of the updated policy.

12. Contact

For privacy inquiries, contact us via Telegram: @crissample

Sample CPA

Elite Media Buying Team

Terms of Service Privacy Policy
@crissample

© 2025 Sample CPA. All rights reserved.

Sample CPA acts as an intermediary between advertisers and traffic sources. We do not own or control any advertising content or traffic.