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Privacy Policy

Effective Date: August 13, 2025

Thank you for visiting the Glitchy performance marketing partner network website (the “Site”). Glitchy (“we”, “us”) is committed to protecting the privacy of your personally identifiable information. We provide this privacy policy (“Privacy Policy”) in order to explain our online information practices and the choices you can make about the way your information is used by us. You must agree to this Privacy Policy, in its entirety, including our use of cookies in order to: register an account (“Account”) with the Glitchy performance marketing partner network (“Performance Marketing Partner Network”) and log in to your Account as member of the Performance Marketing Partner Network. If you do not agree to this Privacy Policy in its entirety, you are not authorized to register for an Account on the Performance Marketing Partner Network.

Privacy Policies Used in Connection with Your Subscription

When you register for an Account on the Performance Marketing Partner Network, we use a password-protected third-party portal to store your personal information, and we may share your personal information with such third party (“Third Party Agent”) as is necessary for the performance of your Account and the Performance Marketing Partner Network.

Personally Identifiable Information

We collect personally identifiable information when you register for an Account or otherwise choose to provide personally identifiable information to us. Personally identifiable information is any information that can be used to identify or locate a particular person or entity. This may include but is not limited to:

  • Business entity name and/or your title with the applicable business entity
  • Personal and/or business entity related e-mail address
  • Mailing address
  • Daytime and/or cellular telephone numbers
  • Fax number
  • Account information (or other information that we require in order to pay any amounts due to you)
  • IP address
  • Any other information requested on the applicable Subscriber registration form

Non-Personally Identifiable Information

We may collect certain non-personally identifiable information about you when you visit certain pages of this Site and/or register for an Account on the Performance Marketing Partner Network, such as the type of browser you are using (e.g., Chrome, Internet Explorer), the type of operating system you are using, (e.g., Windows or Mac OS) and the domain name of your Internet service provider (ISP). We use this information to improve the design and content of the Site and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze Site usage.

Cookies and Web Beacons and Ad Identifiers

To enhance your experience with the Site, we use “cookies.” Cookies are small packets of data stored on your computer used to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. You may set your browser to warn you that cookies are in use, or to block the use of cookies.

We use strictly necessary cookies to allow you to move around the Site and log in to your Account, and functional cookies to improve the services and support available to you. Accepting strictly necessary cookies is a condition of using the Site. You can control whether or not functional cookies are used, though preventing them may mean some services and support will be unavailable.

We may additionally collect information using Web beacons, which are commonly referred to in the industry as web bugs, pixel tags or Clear GIFs. Web beacons are electronic images that may be used on the Site, in your Account, or in our emails to deliver cookies, count visits and determine if an email has been opened and acted upon.

End users can disable cookies in most internet browsers. An overview of the process is available at http://www.allaboutcookies.org/manage-cookies/. Disabling cookies will not, however, stop receipt of all advertisements.

End users can also disable collection of ad identifiers for targeted advertising by enabling the Limit Ad Tracking setting on their smartphone. End users can also reset the ad identifier altogether using their smartphone's privacy settings.

Use of Information

We use your personally identifiable information: (a) to send you information regarding your Account and the Performance Marketing Partner Network; (b) to track your compliance with the Terms and Conditions (“Terms and Conditions”); and/or (c) for validation, suppression, content improvement and feedback purposes.

In addition, we may use your IP address to analyze trends, administer the Site, track users' movements, gather broad demographic information for aggregate use, and to confirm that a particular individual affirmed his/her consent to specific legal terms. You agree that we, or our Third Party Agent, may contact you at any time regarding your Account or any other information that we may deem appropriate for you to receive in connection with your Account on the Performance Marketing Partner Network. You may update your contact preferences as set forth below

Information Sharing

As a general rule, and other than in connection with the limited exceptions set forth below, we will not sell, share or rent your personally identifiable information to or with others. Notwithstanding the foregoing, we may, from time to time, provide such information to certain third-party administrative vendors, including HasOffers, for efficiency purposes in providing administrative or program management services in connection with your Account. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us. Further, we reserve the right to share your personally identifiable information: (a) where required by law, or requested by a court of competent jurisdiction; (b) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; (c) where you are in violation of this Privacy Policy, the Terms and Conditions and/or Services Agreement; (d) in the case of a dispute; or (e) where we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection.

International Transfer of Data

As a general rule, and other than in connection with the limited exceptions set forth below, we will not sell, share or rent your personally identifiable information to or with others. Notwithstanding the foregoing, we may, from time to time, provide such information to certain third-party administrative vendors, including HasOffers, for efficiency purposes in providing administrative or program management services in connection with your Account. Any third-party vendor so used has agreed to protect the confidentiality of information provided by us. Further, we reserve the right to share your personally identifiable information: (a) where required by law, or requested by a court of competent jurisdiction; (b) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock; (c) where you are in violation of this Privacy Policy, the Terms and Conditions and/or Services Agreement; (d) in the case of a dispute; or (e) where we determine, in our sole discretion, that such disclosure is necessary to protect our rights and/or a third party, or necessary to protect us from liability of any kind. The aforementioned includes exchanging information with other companies and organizations for fraud protection. International Transfer of Data. We may transfer information that we collect about you and your end users, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you or your end users are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. You consent to the transfer of your information to the United States and the use and disclosure of information about you and your end users, including personal information, as described in this Privacy Policy. Where we act as a controller under European data law, our lawful basis for collecting and using the information described in this Privacy Notice will depend on the information concerned and the specific context in which we collect or use that information. We normally collect or use information from you only where we have collected your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Specifically, when we:

  • use information to create or manage an account, we need it in order to provide relevant services;
  • use contact information for marketing purposes, we do so with your consent (which you can revoke at any time);
  • gather usage data and analyze it to improve the Site, we do so based on our legitimate interest in safeguarding and improving the Site.

If you have any questions or concerns about how information is processed, including questions about how to exercise your rights as a data subject, please contact us at the contact information provided in this Privacy Notice.

Data Retention

Subject to any mandatory obligations to delete data, your information may be retained by us and in our Third-Party Agent portal, server logs, databases and records. We will keep your information for no longer than necessary for the purposes for which it is processed. Where there are technical limitations that prevent deletion or anonymization, we will safeguard and limit the use of information as required by applicable law.

Your Employees

Your acceptance of the terms of this Privacy Policy, in their entirety, shall extend to your employees. You agree that any of your employees that access your Account or visit the Site under the scope of their employment with you agree to the terms of this Privacy Policy.

Security

We endeavor to safeguard and protect our Account holders' information. When Account holders submit personally identifiable information to the Performance Marketing Partner Network, their personally identifiable information is protected both online and offline. When our registration process asks registrants to submit information such as bank account information and/or credit card information (“Sensitive Information”), and when we transmit such Sensitive Information, that Sensitive Information is encrypted and protected. The Third-Party Agent servers that we utilize to store personally identifiable information are kept in a secure physical environment. The Third-Party Agent has security measures in place to protect the loss, misuse and alteration of personally identifiable information stored on its servers.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personally identifiable information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

You acknowledge that you provide your personally identifiable information to us with knowledgeable consent and at your own risk.

Deleting and Updating Your Information

If you would like to delete or update the personally identifiable information that we have collected from you, simply email us. We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

Opting Out of Receiving E-mail

You may at any time choose to stop receiving emails containing general information regarding Glitchy by following the instructions at the end of each such email or by contacting us. Should you be contacted by our Third-Party Agent through email, you can follow the instructions at the end of each such email to stop receiving such emails. There may be a short delay of up to several business days while your request is being verified, deployed and processed across our servers. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your Account, as well as to respond to any inquiry or request made by you.

Notification of Changes

We reserve the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the Site explaining that we are changing our Privacy Policy. All Privacy Policy changes will take effect immediately upon their posting on the Site. Please check the Site periodically for any changes. Your continued use of the Site and/or acceptance of our email communications following the posting of changes to this Privacy Policy will constitute your acceptance of any and all changes.

CCPA

The following applies solely to California “consumers” as defined in Section 17014 of Title 18 of the California Code of Regulations. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). This policy describes our collection, use, disclosure, and “sale” of “personal information” of California consumers as these terms are defined under the CCPA. Please note that job applicants, current and former employees, and individuals subject to business-to-business communications are not considered “consumers” for the purpose of this policy.

Please note: Glitchy does not knowingly sell personal information of California consumers under the age of sixteen (16) years.

Information We Collect and Share:

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Specifically, we have collected the following categories of personal information from consumers and collected them for the following purposes within the last twelve (12) months:

Disclosure of Personal Information for a Business Purpose

Glitchy may share your personal information with third parties for business purposes, as described herein.

Your California Privacy Rights

Under the CCPA, California consumers are provided with certain privacy rights which they may exercise themselves or through an authorized agent.

The Right to Know: You have the right to request that we disclose to you the personal information we have collected, used, disclosed or sold about you in the previous twelve (12) months. You may also request a copy of the personal information we have collected on you over the past twelve (12) months. See the “Exercising Your California Privacy Rights” section for instructions on submitting a right to know request.

The Right to Deletion: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete and direct our service providers to delete your personal information from our records, unless an exception applies. See the “Exercising Your California Privacy Rights” section for instructions on submitting a right to deletion request.

Exercising Your California Privacy Rights

To exercise the rights described above, please submit a verifiable consumer request to us by email at compliance@glitchy.com. We may require you to provide certain personal information to allow us to verify your identity, such as your email address, most recent order numbers, etc. or by requesting you submit your request via your customer account if one exists. If we cannot comply with a request, we will explain the reasons in our response.

Use of an Authorized Agent: You may designate, in writing or through a power of attorney, an authorized agent to make these privacy requests on your behalf to exercise these rights. An authorized agent may submit a request on your behalf if you have provided the authorized agent with power of attorney in accordance with California law. If this has not occurred, we will require the agent to provide proof that you have authorized it to act on your behalf and may require you to verify your own identity with us directly before we accept a request. We will do this by requiring the authorized agent to present verifiable written authorization from you that you have provided the agent with permission to submit the request and independently verify the agent's own identity with Glitchy.

Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods and services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Shine the Light

California residents may request the categories of personal information that we shared with third parties for the third parties' direct marketing purposes during the previous calendar year, if any. Written requests may be sent to us by email at compliance@glitchy.com

You must write “Your California Privacy Rights” at the top of your inquiry. We will respond within 30 days to requests regarding the categories of personal information that we shared with third parties for their own direct marketing purposes within the previous calendar year. Requests for this information that come to Glitchy by other means may result in a delayed response.

Personal Information from Children

Because of the nature of our business, our services are not provided to minors. We will not ask minors, specifically children under the age of 13, to provide personal information if we have knowledge of their age.

Governing Law; Jurisdiction; Arbitration.

This Privacy Policy will be governed by and construed in accordance with the laws of the State of Florida and the federal laws of the United States of America, without regard to conflict of law principles. Any dispute, claim or controversy arising out of or relating to this Agreement or the breach, termination, enforcement, interpretation or validity thereof, including the determination of the scope or applicability of this agreement to arbitrate, shall be determined by arbitration in Miami, Florida before one arbitrator. The arbitration shall be administered by JAMS pursuant to its Comprehensive Arbitration Rules and Procedures unless the amount in controversy does not exceed $250,000, exclusive of attorney fees and interest, in which case JAMS' Streamlined Arbitration Rules and Procedures shall apply. Judgment on the award may be entered in any court having jurisdiction. This clause shall not preclude parties from seeking provisional remedies in aid of arbitration from a court of appropriate jurisdiction. If the suit is deemed non-arbitrable, either by finding of the arbitrator or agreement of the Parties, any suit, action or proceeding arising out of, or with respect to, this Agreement shall be brought exclusively in the state or federal courts of the State of Florida located in Miami.

Contact Us

If you have any questions regarding this Privacy Policy, or would like more information on our privacy practices, please contact us by email at compliance@glitchy.com.