← adlumen · partner program

Privacy Policy

Effective date: 10 July 2026

This Policy explains how Adlumen OÜ, registry code 17533350, Kooli tn 3-2, Laagri alevik, Saue vald, 76401 Harju maakond, Estonia ("we", the "Controller") processes personal data of visitors of this website and applicants to the Adlumen Partner Program. We process personal data in accordance with the EU General Data Protection Regulation (GDPR).

1. What we collect

• Application data — name, contact details (email or Telegram username) and information about your traffic sources, submitted through the application form or sent to us directly.
• Partnership data — data required to run the partnership: tracking statistics, payout details, correspondence.
• Technical data — basic site usage data (pages viewed, device and browser type) collected through cookies and similar technologies, see Section 6.

2. Why we process it

• to review your application and contact you about it — based on your consent and pre-contractual steps (Art. 6(1)(a), (b) GDPR);
• to operate the Partner Program, calculate rewards and make payouts — performance of a contract (Art. 6(1)(b)) and legal obligations (Art. 6(1)(c));
• to run and improve the website — our legitimate interest (Art. 6(1)(f)).

3. Sharing

We do not sell personal data. We share it only with service providers that help us operate (hosting, analytics, communication and payment infrastructure), under data processing agreements, and with authorities where the law requires it. If a provider is located outside the EEA, we rely on appropriate safeguards such as the EU Standard Contractual Clauses.

4. Retention

Application data is kept for up to 12 months after the last contact if the application does not proceed. Partnership and payout data is kept for as long as the partnership lasts and thereafter as required by accounting and tax law (in Estonia, generally 7 years).

5. Your rights

You may request access to, rectification or erasure of your data, restriction of processing, data portability, and you may object to processing or withdraw consent at any time by writing to hello@adlumen.partners. You also have the right to lodge a complaint with a supervisory authority — in Estonia, the Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee).

6. Cookies

• Essential storage — we use browser storage to remember your cookie choice. It is required for the site to work and does not identify you.
• Analytics cookies — if enabled, they help us understand aggregate site usage (visits, pages, referrers). They are used only with your consent given via the cookie banner.

You can delete or block cookies in your browser settings at any time; the site will keep working.

7. Data processing consent

By submitting the application form you confirm that you have read this Policy and consent to the processing of the personal data you provide (name, contact details, traffic information) by Adlumen OÜ for the purposes of reviewing your application and contacting you about the Partner Program. Consent is voluntary and can be withdrawn at any time by writing to hello@adlumen.partners; withdrawal does not affect processing performed before it.

8. Changes and contact

We may update this Policy by publishing a new version at this address.