Partner Program · Privacy
This Partner Privacy Policy explains how Pinchuk LLC collects, uses, discloses, and retains personal information about partners and applicants in connection with the Migri Partner Program. It concerns information about you as a partner — not information about end users of the Migri application, which is addressed separately in the App’s end-user Privacy Policy.
By applying to or participating in the Program, you acknowledge this Partner Privacy Policy. It is incorporated by reference into the Partner Agreement.
This Policy applies to personal information we process about applicants to and participants in the Program. The Program is administered from the United States and is directed to partners in the United States or partners whose channels target United States audiences. If you access the Program from outside the United States, Section 10 applies.
We collect the following categories of information about you:
| Category | Examples |
|---|---|
| Identity and contact | Your name or handle and your email address. |
| Channel information | The social-media platforms, channel URLs, and subscriber or follower counts you provide, and information about your content and audience used to assess eligibility. |
| Application data | The invitation under which you applied and your acceptance of the Partner Agreement. |
| Account and program data | Your referral code, dashboard access credentials, status, and assigned revenue-share percentage. |
| Financial and payout data | The payout address you nominate and records of accrued earnings and payments. |
| Tax data | Information contained in IRS Form W-9, Form W-8BEN/W-8BEN-E, or other tax documentation you submit (which may include your legal name, address, and taxpayer identification number). |
| Communications | Correspondence between you and the Company. |
| Technical data | Limited log data, such as IP address and timestamps, generated when you access Program web pages or your dashboard. |
We use your information to: evaluate your application and verify eligibility; administer the Program, including attribution, tracking, and calculation of earnings; communicate with you and send your referral and dashboard links; process payouts; comply with tax and other legal obligations; detect and prevent fraud and abuse; and enforce the Partner Agreement.
Where data-protection law requires a legal basis, we rely on: performance of the Partner Agreement (to administer the Program and pay you); compliance with legal obligations (for tax reporting and withholding); and our legitimate interests (to operate, secure, and improve the Program and prevent fraud), balanced against your rights.
Tax documentation is collected and used solely to meet the Company’s tax-reporting and withholding obligations and to make payouts. Taxpayer identification numbers and related tax data are sensitive; we restrict access to them, retain them only as required by law, and do not use them for any purpose unrelated to tax compliance and payment.
We do not sell your personal information. We disclose it only as necessary to: payment providers, to make payouts; tax and accounting providers and authorities, to meet reporting obligations; service providers that host or support the Program, under appropriate confidentiality obligations; and authorities or other parties where required by valid legal process or to protect our rights, as permitted by law. In a merger, acquisition, or sale of assets, partner information may be transferred as part of that transaction.
To attribute installs and purchases to you, we record that a given anonymous end-user device arrived through your referral link, and the resulting aggregate counts and earnings. Your dashboard shows only aggregate statistics. We do not disclose to you the identity, personal information, or individual data of any end user. End-user information is governed by the App’s end-user Privacy Policy.
We retain your partner information for as long as you participate in the Program and thereafter as necessary to administer wind-down, make final payments, resolve disputes, and comply with legal obligations. Tax records are retained for the period required by applicable tax law. When information is no longer required, we delete or de-identify it.
We implement reasonable technical and organizational measures to protect partner information, including access controls and encrypted connections, and we restrict access to financial and tax data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
The Program is operated from the United States, and your information is processed and stored in the United States. If you participate from outside the United States, you understand and agree that your information is transferred to and processed in the United States, which may have different data-protection laws than your jurisdiction.
Subject to applicable law, you may request access to, correction of, or deletion of your personal information, and may object to or request restriction of certain processing. Some information — in particular tax and payment records — must be retained to meet legal obligations and cannot be deleted on request until the required retention period elapses. To exercise any right, contact us using the details in Section 13. We may take reasonable steps to verify your identity before responding.
We may update this Partner Privacy Policy from time to time. We will revise the “Last Updated” date and post the updated Policy at the URL above. Your continued participation after the effective date constitutes acknowledgment of the updated Policy.
For questions about this Partner Privacy Policy, or to exercise a right, contact us: