PILOTS.SOCIAL LIMITED

This Privacy Policy explains how we collect, receive, use, store, disclose, protect, retain, and otherwise handle personal information in connection with our website, our digital marketing and related services, our client onboarding, communications, billing and support activities, our affiliate program, and our use of third-party platforms, tools, software, white-label systems, and service providers used to deliver our services.

This Privacy Policy is based on the New Zealand Privacy Act 2020. We are based in New Zealand and comply with the New Zealand Privacy Act 2020. Other privacy or data protection laws may apply depending on factors such as the location of individuals, the nature of the services provided, and how our services are used. This policy does not necessarily address those laws in full. If you are located outside New Zealand and wish to understand how those laws may apply to you, please contact us.

By using our website, engaging our services, applying to participate or participating in our affiliate program, communicating with us, or otherwise interacting with us, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy does not govern third-party websites, software, tools, or services that have their own privacy policies; how a client uses personal information outside our services or outside systems we manage or provide; how an affiliate uses personal information outside our affiliate program or outside systems we provide or manage; or privacy practices of third-party platforms such as advertising platforms, hosting platforms, analytics tools, payment providers, white-label platform providers, or AI providers except to the extent we describe our relationship with them.

If you interact directly with a third party, their privacy practices may also apply.

Depending on the context, Pilots.social may act in one or more different privacy roles.

We may collect, receive, generate, or otherwise process the following personal information. We will only collect personal information where it is reasonably necessary for the purposes set out in clause 6.

We collect personal information directly from you when you contact us, use our site, engage our services, or join our affiliate program. We also collect your personal information automatically through our website, platforms, portals, analytics, cookies, and tracking technologies; from clients, affiliates, or referral sources; and from third-party service providers and integrations. Where we collect personal information other than directly from you (including from clients, affiliates, referral sources, or third-party platforms), we will take reasonable steps to ensure that you are made aware of the matters set out in Information Privacy Principle 3 of the Privacy Act 2020 (including the fact of collection, the purpose of collection, the intended recipients, and your rights of access and correction), unless an exception under the Privacy Act 2020 applies.

We use personal information for the following purposes for which it was collected, unless an exception applies under the Privacy Act 2020.

Where reasonably necessary to operate the affiliate program, we may disclose or make visible information such as affiliate name or display name, email address or contact details, program participation status, referral or tracking identifiers, performance metrics, attribution or conversion records, commission and payout-related information, hierarchy or multi-tier position information, and fraud, dispute, or compliance status where reasonably necessary.

Affiliate information may be shared with our internal personnel and contractors who administer the affiliate program, relevant platform or network providers who support program operation, payment or payout providers where needed for commission or payout processing, service providers who support fraud detection, analytics, support, or communications, other affiliates or hierarchy participants to the extent hierarchy visibility is a core and configured feature of the program, relevant clients or account administrators where reasonably necessary to administer referral relationships or program participation, and regulators, authorities, advisers, or legal counterparties where required by law or reasonably necessary for enforcement or dispute handling.

If the affiliate program includes hierarchy or multi-tier features, certain information may be visible within the hierarchy to support program administration, collaboration, reporting, attribution, performance tracking, and commission logic. This may include affiliate name or display name, contact information, join date, status, hierarchy position, referral identifiers, and performance metrics.

Where affiliate information is made available within the affiliate program, it must be used only for legitimate affiliate program purposes. It must not be used for unrelated marketing, contact harvesting, spam, or establishing or migrating relationships outside the Platform in a way that bypasses our systems or commercial arrangements.

We may disclose personal information to service providers and contractors, advertising and analytics platforms, payment and payout providers, white-label and platform providers, for legal and regulatory reasons, in connection with business transfers, and in aggregated or de-identified form where it does not reasonably identify any individual.

We do not sell personal information in the ordinary sense of that term. For some jurisdictions, certain advertising disclosures may be treated as "sharing" for targeted advertising purposes under local law. Where applicable, you may exercise available opt-out rights.

Where we disclose or transfer personal information outside New Zealand, we take reasonable steps to ensure that the recipient is subject to comparable privacy safeguards in accordance with information privacy principle 12 of the Privacy Act 2020, including by contractual or other appropriate safeguards where required.

We may use cookies, analytics tools, advertising pixels and tags, local storage, browser identifiers, session markers, and AI-assisted analytics or behavioural tools to analyse website traffic, improve performance and user experience, support attribution and conversion measurement, personalise content or marketing, conduct retargeting or audience analysis, and secure sessions and detect suspicious activity.

Where required by law, we provide or honour appropriate consent or opt-out controls for non-essential technologies.

We take reasonable and industry-standard steps to protect personal information from unauthorised access, loss, misuse, alteration, or disclosure. These measures may include encryption in transit, restricted access controls, secure storage, password and authentication protections, monitoring and logging, staff confidentiality obligations, and internal policies and procedural controls.

No system is completely secure, but we work to reduce risk and respond appropriately to incidents.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide services, administer client relationships and affiliate relationships, comply with legal obligations, maintain business, tax, and accounting records, preserve evidence for disputes, investigations, or claims, maintain fraud prevention and security records, and support platform, system, or operational continuity.

Retention periods may vary depending on the type of data, legal requirements, and operational needs. When information is no longer required, we may delete it, anonymise it, or de-identify it where reasonably practicable.

Our services and affiliate program are not directed to children. We do not knowingly collect personal information from children below the age thresholds that apply under relevant law. If you believe a child has provided personal information to us inappropriately, please contact us.

Depending on your location and the law that applies, you may have rights in relation to your personal information. Under the Privacy Act 2020, these include rights to request access, request correction, and complain to the Privacy Commissioner.

We may need to verify your identity before processing a request. If your request relates to personal information controlled by one of our clients, we may direct you to that client or coordinate with them as appropriate.

We may update this Privacy Policy from time to time to reflect changes in our services, operations, technology, legal obligations, affiliate program structure, or privacy practices.

If we make material changes, we may notify users by appropriate means, such as updating the "Last Updated" date, posting an updated version on our website or portal, or sending email or in-platform notice where appropriate.

If you have any questions, requests, or complaints about this Privacy Policy or our handling of personal information, please contact us:

Pilots.social Limited

Email: hello@pilots.social

If your request relates to information processed on behalf of one of our clients, you may also need to contact that client directly.

If you have concerns about our handling of personal information, please contact us first so we can try to resolve the issue.

If unresolved, you may contact the New Zealand Office of the Privacy Commissioner, or, if applicable, other relevant regulator or supervisory authority, such as the data protection authority in the EEA or UK, or applicable U.S. regulatory bodies where relevant.