Privacy Policy

This Privacy Policy explains how NIKHAMZ AGENCY CO., LTD, a company incorporated in Thailand, registration number 0105567244265 ("Affinix", "we", "us" or "our"), collects, uses, discloses and protects personal data in connection with the Affinix affiliate platform, including the Affinix Hub web application and the Affinix Telegram application (together, the "Platform"). This Policy applies to affiliates, prospective affiliates and other individuals who interact with the Platform ("you"). Capitalized terms not defined here have the meaning given in the Affiliate Agreement.

1. Data Controller

1.1 Affinix, operated by NIKHAMZ AGENCY CO., LTD (Kingdom of Thailand, registration number 0105567244265), is the data controller responsible for personal data processed through the Platform.

1.2 You may contact us regarding this Policy or your personal data only through the Platform, using the contact channels made available there.

2. Scope and Applicable Law

2.1 We process personal data in accordance with the Thailand Personal Data Protection Act B.E. 2562 (2019) ("PDPA") and other Applicable Law.

2.2 If you are located in the European Union, the United Kingdom, or another jurisdiction whose data-protection law applies to our processing of your personal data, the relevant provisions of that law (for example the GDPR or the UK GDPR) apply to you in addition to the PDPA, to the extent applicable.

3. Personal Data We Collect

3.1 Registration data. Your name or company name, email address, country, password, payout details (for example wallet or bank account information), and tax or identity information we collect for verification purposes.

3.2 Telegram data. If you register or log in through the Affinix Telegram application, your Telegram ID and the profile information Telegram provides to us for authentication.

3.3 Technical data. IP address, device and browser information, login timestamps, session and authentication logs, and similar data generated by your use of the Platform.

3.4 Traffic and conversion data. Data generated through Tracking Links and postbacks, including clicks, Conversions, sub-IDs and other sub-parameters, timestamps, and Offer and Advertiser identifiers. We do not collect or store personal data of end users exposed to advertising beyond what is technically necessary to record and validate a Conversion (for example, we do not retain end-user contact details unless an Offer Rule and Applicable Law require it for validation, and even then only to the extent necessary).

3.5 Communications. Records of your correspondence with us through the Platform, including support requests and appeals.

4. Purposes of Processing

4.1 We process personal data to: (a) create and administer your Account; (b) record, validate and pay Commissions; (c) detect and prevent fraud and verify the legitimacy of traffic, as described in the Affiliate Agreement; (d) comply with Applicable Law, including tax, anti-money-laundering and regulatory obligations; (e) communicate with you about your Account, Offers and the Platform; and (f) maintain the security and proper functioning of the Platform.

5. Legal Basis for Processing

5.1 We rely on one or more of the following legal bases, as applicable: (a) performance of the Affiliate Agreement with you; (b) our legitimate interests, including fraud prevention, traffic verification and Platform security, balanced against your rights; (c) compliance with a legal obligation, including tax and anti-money-laundering requirements; and (d) your consent, where we request it (for example for optional communications), which you may withdraw at any time.

6. Disclosure to Third Parties

6.1 Advertisers. We disclose Conversion and traffic data to the Advertiser associated with the relevant Offer, to the extent necessary for that Advertiser to validate Conversions and administer the Offer.

6.2 Service providers. We share personal data with service providers that support the Platform, including our tracking provider (Offer18), payment and payout processors, hosting providers, and identity-verification providers, each acting under contractual confidentiality and data-protection obligations.

6.3 Legal and corporate purposes. We may disclose personal data where required by Applicable Law, to enforce our rights under the Affiliate Agreement, or in connection with a merger, acquisition or transfer of our business, subject to appropriate safeguards.

6.4 Cross-border transfers. Your personal data may be transferred to and processed in countries other than your own, including Thailand and the countries where our service providers operate. Where required by Applicable Law, we implement appropriate safeguards for such transfers, such as contractual data-protection commitments with the recipient.

6.5 We do not sell personal data.

7. Data Retention

7.1 We retain personal data for as long as your Account remains active and for such additional period as is necessary to comply with our legal, tax and accounting obligations, resolve disputes, and enforce our agreements.

7.2 After that period, we delete or anonymize personal data, except where Applicable Law requires or permits longer retention.

8. Your Rights

8.1 Subject to the conditions and exceptions in the PDPA and other Applicable Law, you have the right to: (a) access the personal data we hold about you; (b) request correction of inaccurate or incomplete data; (c) request deletion or anonymization of your data; (d) request restriction of processing; (e) object to processing based on our legitimate interests; (f) withdraw consent where processing is based on consent, without affecting processing carried out before withdrawal; (g) request data portability where technically feasible; and (h) lodge a complaint with the Thailand Personal Data Protection Committee or another competent regulator.

8.2 You may exercise these rights by contacting us through the Platform. We may need to verify your identity before acting on your request.

9. Security

9.1 We implement technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse or alteration, appropriate to the sensitivity of the data. No system is completely secure, and we cannot guarantee absolute security.

10. Cookies and Tracking Technologies

10.1 The Platform uses cookies, local storage and similar technologies to authenticate sessions, remember preferences, and operate Tracking Links and postbacks. Where the Telegram application is used, equivalent identifiers provided by Telegram serve the same purpose. You can control cookies through your browser settings, though disabling them may affect the functioning of the Platform.

11. Children

11.1 The Platform is not directed to individuals under 18 years of age, and we do not knowingly collect personal data from them. This does not affect your independent obligations under Section 5 of the Affiliate Agreement regarding the traffic you promote.

12. Changes to this Policy

12.1 We may update this Policy from time to time by posting a revised version on the Platform. Material changes will be indicated by an updated effective date, and where required by Applicable Law we will provide additional notice. Your continued use of the Platform after a change takes effect constitutes acceptance of the revised Policy.

13. Language

13.1 This Policy is written in English, which is the controlling language. Any translation is provided for convenience only.

This Privacy Policy is effective upon publication.