Legal
Privacy Policy
1. Who we are
This Privacy Policy explains how 123commission, New Delhi, India ("123commission", "we", "us" or "our") collects and uses personal data through 123commission.com (the "Website") and in providing our services. We act as the Data Fiduciary for this data under the Digital Personal Data Protection Act, 2023 ("DPDP Act").
2. What we collect
- Application details you give us: name, email address, phone number (brands), brand or channel link, category or channel type, and your consent choices.
- Partner details, once you sign an agreement: business details, PAN, GSTIN where applicable, bank or UPI details, and campaign and sales records needed to calculate and pay commissions.
- Messages: anything you send us by email.
- Basic technical data: our hosting provider may automatically log IP addresses, browser type and pages requested for security and to keep the Website running.
We do not knowingly collect personal data of anyone under 18. If you believe a child has submitted data, contact us and we will delete it.
3. Why we use it
We process personal data on the basis of your consent, given when you submit a form, or for legitimate uses permitted under the DPDP Act, for these purposes:
- to review your application and contact you about it;
- to set up and run campaigns, track and validate sales, and calculate and pay commissions;
- to meet legal, tax and accounting obligations, including TDS and GST;
- to detect and prevent fraud and Invalid Activity, and to keep the Website secure;
- to respond to questions, complaints and requests.
We do not sell your personal data, and we do not use it for unrelated marketing without your consent.
4. Cookies
The Website does not use advertising or analytics cookies. Campaign tracking links used after you join our network may use cookies or similar identifiers to attribute sales; these are described in your campaign agreement.
5. Who we share it with
- Service providers (Data Processors) who help us run the Website and our business, including our web host, our email provider, FormSubmit (which delivers website form submissions to our inbox), and Google Fonts (which receives your IP address when the Website loads its typefaces). They may process data outside India.
- Brands and Publishers, only to the extent needed to run a campaign you take part in (for example, a Publisher's name and channel shared with a Brand).
- Authorities, where required by law or to protect our legal rights.
We require service providers to protect personal data and use it only on our instructions.
6. How long we keep it
We keep application data for up to 12 months if no partnership follows, and partner data for as long as the relationship lasts and then for the period required under tax and accounting laws (generally up to 8 years). After that, we delete or anonymise it.
7. Your rights
Under the DPDP Act, you may:
- ask for a summary of the personal data we hold about you and how we use it;
- ask us to correct, complete, update or erase your personal data;
- withdraw your consent at any time (this does not affect processing already done, and we may still keep data we must retain by law);
- nominate another person to exercise your rights in case of death or incapacity;
- raise a grievance with us, and if it is not resolved, complain to the Data Protection Board of India.
To exercise these rights, email grievance@123commission.com. We may need to verify your identity before acting on a request.
8. Security
We use reasonable security safeguards, including HTTPS encryption, restricted access to our inboxes and records, and limits on the data we collect. No method of transmission or storage is completely secure. If a personal data breach occurs, we will notify affected people and the Data Protection Board as required by law.
9. Changes to this policy
We may update this policy from time to time. The updated version will be posted on this page with a new effective date.
10. Grievance Officer and contact
Grievance Officer, 123commission, New Delhi, India — grievance@123commission.com. We will acknowledge your request promptly and aim to resolve it within 15 days.
General questions: hello@123commission.com.