Privacy Policy

UPDATED ON JULY 11, 2024 (VER 1.1)

 

BabyDrive (“us”, “we”, or “our”) operates the BabyDrive website (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at https://babydrive.com.au

Information Collection And Use

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information (“Personal Information”) may include, but is not limited to:

  • Name
  • Email address

Log Data

We collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Google AdSense & DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us. If we discover that a child under 18 has provided us with Personal Information, we will delete such information from our servers immediately.

Compliance With Laws

We will disclose your Personal Information where required to do so by law or subpoena.

Commission Factory Consumers

How do we use data from end users?

Commission Factory primarily uses end user data for the purpose of tracking an end user from an Affiliate to an Advertiser. Tracking enables us to see that an end user has visited an Affiliate's service, found a product, and clicked the link to be taken to the Advertiser's service to review or purchase the product.

The purpose of tracking is to attribute sales and marketing effort by an Affiliate to a particular transaction, to enable Advertisers to reward Affiliates on a per transaction basis. Tracking also allows Commission Factory to provide Affiliates and Advertisers with related reports. The majority of these reports contain only aggregated statistical data.

Commission Factory doesn't know who the end user is, simply that the same end user started their journey with the Affiliate and completed it with the Advertiser and that the affiliate marketing campaign was therefore successful in respect of that end user.

By maintaining a limited user profile which does not reveal an end user's name or identity, Commission Factory can also understand an end user journey when it starts on one device and ends on a different device. Through this functionality, Commission Factory can understand whether a referral is commenced on one device and completed on another device. The profile is only used to attribute sales and marketing effort to an Affiliate, even if the end user has changed devices before completing a transaction.

Commission Factory permits Affiliates to enquire as to whether an action by a user ought to have generated a commission for that Affiliate. This necessitates the sharing of information, between Affiliates and Advertisers. Advertisers use the information provided by Affiliates to verify against their own records. Commission Factory enables this data sharing and the payment of any commission due to the Affiliate as a result.

How do we collect data from end users?

The main technologies used for Commission Factory's tracking are Tracking Domain Cookies, Journey Tags and Device Fingerprinting.

Commission Factory Tracking Domain Cookies: These are cookies served by Commission Factory's own domain when an end user clicks on an advertisement displayed by an Affiliate. We use this information to understand which end users are referred by which Affiliates to which Advertiser. Please find some general information on cookies here.

Advertiser Journey Tag: This is JavaScript code integrated into the Advertiser's service to enable Commission Factory to receive transactional information from Advertisers. Commission Factory uses this information to record, validate and report the completion of transactions, for the purposes of apportioning commissions to Affiliates.

Fingerprinting: This is a method by which Commission Factory can uniquely identify a device by considering certain attributes of the browser or the device (incl. screen size/resolution and user configurations).

What data do we collect from end users?

We take care not to collect data that we don't need. The majority of the data Commission Factory uses is machine generated. It lets us single out a person, but it does not reveal who that person is. We do not use this data to make predictions or evaluations of users' interest or personalities.

Commission Factory is one part of the affiliate marketing ecosystem (see our Agreement with Advertisers and Affiliates below) and does not always have absolute control over the personal data that it receives from users, Affiliates or Advertisers.

Commission Factory stores an individual sequence of figures in respect of a transaction that does not reveal the name of a particular end user and contains information on the Advertiser's campaign, the Affiliate, the end user action (i.e. a click or a view and in which country it occurred), and the device that is used.

Commission Factory also receives limited transactional information via the Journey Tag, to confirm that a transaction has occurred and carry out accurate commission allocating, billing and reporting. Such information includes the order value, whether a voucher has been used, product type, and sales channel.

Commission Factory's data processing activities relating to end user data, do not require the direct identification of an individual and therefore Commission Factory mostly holds what is known as “pseudonymous” data in this respect. Pseudonymisation is privacy-enhancing. It is the separation of data from direct identifiers so that data can no longer be attributed to a specific individual without the use of additional information.

Pseudonymisation, therefore, reduces the risks associated with data processing, while also maintaining the data's utility.

Does Commission Factory have legitimate interest in using data?

We have carried out a balancing exercise and have identified legitimate interests as a basis for processing user data for the purposes set out in this section of the Privacy Policy.

When assessing Commission Factory's legitimate interest, the interests of the full affiliate ecosystem were considered. A balancing test was carried out and it was confirmed that tracking carries no risk or a very low risk of undue negative impact on the end user's interests or fundamental rights and freedoms. Legitimate interests are not limited to the interests of Commission Factory but can be legitimate interests of a third party or to society as a whole. In the context of our service, we consider that:

  • Advertisers have an interest in carrying on an online advertising campaign, paid for on a performance basis, whereby third-party referrers of customers or potential customers of the Advertiser are compensated for referrals which generate revenue for the Advertiser, or which undertake another act desired by the Advertiser.
  • Affiliates have an interest in monetising their content, services or other aspects of the Affiliate website by generating advertising revenue which is paid on a performance basis.
  • Advertisers and affiliates have an interest in obtaining reports relevant to their respective business revenue generation.
  • Commission Factory has an interest in operating an affiliate marketing network, and to provide technology, services and reporting, in return for payment from Advertisers.
  • Commission Factory, Advertisers, Affiliates and society at large have an interest in preventing fraud, misuse of services, or money laundering.

What is our arrangement with Affiliates and Advertisers on our network?

Commission Factory's affiliate marketing network connects Advertisers and Affiliates, so that they can work together to run affiliate marketing campaigns.

In running the campaign each party plays their part in pursuing the common purposes and each party can make certain decisions about the way data is used.

Commission Factory contractually requires that its whole network is compliant with data protection law and that they each fulfil their obligations to respond to requests to exercise data subject rights. You can approach each party, if you intend to exercise your rights in respect of the data which that party controls.

Commission Factory works with these Advertisers. For guidance on how to make a request to an Affiliate or an Advertiser, please check their respective privacy notices. For more information of how to make a request to Commission Factory, “What rights do you have in respect of user data” below.

For how long do we keep end user data?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As a general rule, Commission Factory retains tracking data for 5 years after collection.

What rights do you have in respect of user data?

We will honour your rights under applicable data protection laws. These rights are not absolute, and they do not always apply in all cases. If you wish to make a request in respect of your user data, as described in this section of the Privacy Policy, please contact info@commissionfactory.com You may:

  • request access to your information and information related to our use and processing of your information;
  • request the correction or deletion of your information;
  • request that we restrict our use of your information;
  • request a machine-readable copy of your information or that your information be transferred to other IT systems;
  • object to the processing of your information for certain; and
  • withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information.

 

Please note that, as described under “What data do we collect from users?”, Commission Factory mostly holds what is known as “pseudonymous” data in respect of users. Pseudonymisation means that we may not be in a position to identify the individual behind the data we hold and that we therefore cannot provide them with access, rectification, erasure or data portability without the provision of additional information (for example your IP address, or Device ID).

How do we use data to administer our business?

We process personal information for the legitimate interests of ensuring that use of our services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, and to enforce our legal rights and comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

With whom do we share your information?

Group members, personnel, service providers: We keep your information confidential, but disclose it to our group members, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information and have agreed to safeguard it. Activities that are carried out by third party service providers include: website hosting, website analytics, customer relationship management, email marketing, and IT support.

Third parties: We may disclose your personal information to third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. We are not responsible for the privacy or security practices of any third party, including third parties that we are permitted to disclose an individual's personal information to in accordance with this Privacy Policy or any applicable laws. The collection and use of an individual's information by such third parties may be subject to separate privacy and security policies.

Merger or acquisition: If we are involved in a merger, acquisition or sale of all or a portion of our assets.

Required by law: In addition, we disclose your information to the extent that we are required to do so by law (e.g. to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Commission Factory, our customers or others.

How do we keep your data safe?

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide security for information we process and maintain, no security system can prevent all potential security breaches.

How do we apply external laws?

If you are:

  • a resident of the European Union accessing our online platforms or receiving our services in Australia; or
  • accessing our online platforms or receiving our services from within the European Union,

then in addition to our obligations under the privacy laws, we are required to comply with the General Data Protection Regulation (EU) 2016.679 (“GDPR”) with respect to your Personal Information.

If you are a resident of California USA, the California Consumer Privacy Act provides California consumers with the right to obtain information about the personal information that we collect, use, and disclose. You can exercise your by contacting us. If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service.

We take the security and privacy of your personal information seriously and have prepared this Privacy Policy and taken measures to collect, process and hold all personal information in compliance with United States privacy laws and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.

 

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

  • IP Address
  • Operating System type
  • Operating System version
  • Device Type
  • Language of the website
  • Web browser type
  • Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us.