This CAM4PAYS Affiliate Agreement Privacy Policy (the "Privacy Policy") is made and entered into by and between Surecom Corporation, N.V., d/b/a “CAM4” and “CAM4PAYS”, and “TEMPTED”, and Languard Corporation, N.V., d/b/a “NAKED NEWS” AS WELL AS ANY FUTURE BRANDS WE INCLUDE IN THE CAM4PAYS OFFERING, (collectively “Brand” or “Brands”, “us” or "we"), and you, ("you" or "Affiliate") the party that becomes a CAM4PAYS Affiliate. The Privacy Policy contained herein applies to your participation with Cam4Pays.com ("CAM4PAYS "), any affiliated websites and the services offered thereon (referred to as the “Websites”), and includes you, any entity you represent, its representatives, successors, assigns and affiliates and any of your or their devices.

Your privacy and security are of paramount importance to us when you choose to use our service. CAM4PAYS is committed to protecting the data you share with us via services offered by CAM4PAYS or affiliated websites and the services offered thereon (“Websites”).

This Privacy Policy is intended to help you understand how CAM4PAYS processes information collected through use of our Website that can be used to directly or indirectly identify an individual (“Personal Data”).

Any user’s information found on CAM4PAYS’s Website is treated as confidential. All data is stored securely and is accessed by authorized personnel only. CAM4PAYS implements and maintains appropriate technical, security and organizational measures to protect all its users’ Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

The following sections cover how we collect and process data received from individuals who are: (a) visitors of the Websites (referred to in this privacy policy as “Guests”) and (b) natural and/or legal persons who have created an Account with the Websites in order to participate in the CAM4PAYS Affiliate Program by creating their own account (referred to in this privacy policy as “Affiliates”). Guests and Affiliates must be aged eighteen (18) years and over or must have attained the age of majority in their respective jurisdiction in order to be able to use the Websites. All persons who do not meet these criteria are strictly forbidden from accessing, viewing the contents of, or otherwise joining the Websites. We do not knowingly seek or collect any personal information from persons who have not attained the age of eighteen (18).

A. Data from Website Guests

If you are a Guest to our website only, then this section is relevant for you.
When you visit CAM4PAYS as a Guest, we will not ask you for any Personal Data.

However, CAM4PAYS does collect, record, aggregate and analyze information of ALL visitors to its website, and we use analytics tracking systems to do this, specifically, FoxMetrics, Fivetran Inc., Snowflake Inc., Dataiku Inc, Dataiku SAS, Dataiku Ltd and Sisense Ltd. CAM4PAYS gathers data about visits to the website, including the numbers of visitors, geo-location data, length of time spent on the site, page view activity and hyperlinks clicked, where visitors have come from and what operating system is being used. We will retain and evaluate information on your visits to our website and how you move around different sections of it in order to understand how people use our website so that we can make it more intuitive. CAM4PAYS collects behaviour data and profile data including what you do on our site, such as whether you add friends or favorites, send private messages, or make a purchase. We will retain your viewing and shopping history and use details of the products you have previously purchased to make suggestions to you for other products in which we believe you will also be interested. We will keep a record of what you have clicked on and use that information to target advertising on this website to you that is relevant to your interests, which we have identified based on what you have viewed. We record information from your web browser, your IP address and we use cookies to do so.

Although such information is not personally identifiable, we use your IP address to determine your Internet Service Provider and the geographic location of your point of connectivity.

If you choose to fill out an optional profile to share information about yourself with CAM4PAYS and our community of Affiliates, we may collect your ethnicity, sexual orientation, marital status, your profile picture and your biography, if you create and share those things with us.
In that case, we will seek your explicit consent to process Special Category of Personal Data, collected by CAM4PAYS or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this Website as anything other than a “Guest” may not be possible.

B. Data from Website Affiliates

In the event you become an Affiliate, or otherwise choose to transact the purchase of goods and services through the site, one or more of our payment processors will collect billing information from you to facilitate your transactions. Such information may include banking routing and account numbers, a credit card number, its expiration date, and a billing address. WE DO NOT HAVE ACCESS TO YOUR FINANCIAL DATA, WHICH IS COLLECTED BY OUR PAYMENT PROCESSORS. Financial data that is collected by our payment processor will only be used as necessary to initiate and complete any of your transactions. Please see our section on Payment Service Providers for more information.

In order to provide additional services to its Affiliates, CAM4PAYS must collect more data from them, some of which is Personal Data.
If you register an account, we will collect your chosen “username” and email address. This information is used by CAM4PAYS to identify you and provide you with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.

If you are a Guest or Affiliate, we may process sensitive data in relation to your ethnic origin or your sexual orientation, provided that you have provided such sensitive data to us and if we have first obtained your explicit consent to do so. We will never request that you disclose your sexual orientation to us.

C. Data for customer relations

To properly manage our relationship with you and provide the best support and customer services, we will use your contact information including your name, your contact details, and any information found in prior communications between us. We will also keep records of our discussions so that we can follow up as needed, and to promote our products and services to you that may help address any service issues.

D. Data for email notifications

When you create an account on CAM4PAYS, we will need to use your email address to notify you of important changes to your account, such as updates to Privacy Policy or Password reset requests.
If you consent to receive emails such as newsletters, product information or special offers and sales, we will use the Personal Data provided in your profile, your user group level, and purchase history order to tailor content and messages to your interest(s) and account type.
Many of these options can be customized in your My account > Privacy section.

E. Chat Communications

CAM4PAYS Affiliates should be aware that making use of chat or any other means of communication via our Website could result in disclosing information that could make you personally identifiable to us or other users or Affiliates or Guests. The security and privacy protection implemented on our Webite does not cover this type of transfer or disclosure of personal information. All users of our Webite are solely responsible for the content of their messaging and any consequent disclosure of Personal Data.  It is every user’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. We will not process Personal Data of our users disclosed in this fashion or by other means than instructed by its users via appropriate consents, as required by contract or law or as necessary to the functionality of the Site. Please, do NOT share anyone else’s Personal Data on the CAM4PAYS Website.

F. Legal claims and management of risk

We will process any of your Personal Data identified in this Policy where it is necessary to establish, exercise or defend legal claims, either in or out of court, or to hire professional advice for the protection of our business against risk and to assert our legal rights, your legal rights and the legal rights of others.

The following sections tell you when and to whom CAM4PAYS will disclose your Personal Data.

A. Legal and vital interests

CAM4PAYS may disclose your Personal Data in order to obtain professional advice, to establish, exercise or defend legal claims, to comply with legal obligations or to protect your vital interests or the vital interests of another natural person.

B. Our companies

In order to accomplish the purposes set forth in this Privacy Policy, and on the legal bases set out herein, CAM4PAYS may share your Personal Data with its group of companies and affiliated companies, including sister companies and so-called “white label” companies, and other subsidiaries of its holding company. For an up-to-date listing of CAM4PAYS’s affiliated websites, please contact support@cam4Pays.com.

C. Banks and Payment services providers

We will share transaction data with your banks and our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and handling complaints and questions. For more information about our payment processors privacy policies and practices, visit their website: Epoch Payment Solutions, Segpay Corp., DialXS, PayGarden, Commdoo, InterAc

D. 3rd party providers of goods/services

A Service Provider (SP) provides organizations with consulting, legal, real estate, communications, storage, processing, etc. Although a service provider can be an organizational sub-unit, it is usually a third party or outsourced supplier, including financial service providers (banks or payment processors), telecommunications service providers, application service providers, storage service providers, Internet Service Providers (“ISP”), etc.
We will disclose some of your Personal Data (but none of the categories of special personal data) to one or more of our third-party suppliers of services (for example to the banks in order to pay Affiliate commissions) so that they can accomplish their duty to give you their best possible service.

E. Our legal obligation to disclose personal data

We will reveal an Affiliates Personal Data without prior permission when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against, a person or persons who are suspected of infringing rights or property belonging to CAM4PAYS or to others who could be harmed by the Affiliate’s activities. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

Government authorities may, without your consent (or our consent), communicate information to other authorities, including relevant police if there is reasonable cause to believe that a criminal or penal offense has been committed or is about to be committed.

Special Categories of Personal Data are defined as Personal Data revealing:

• racial or ethnic origin
• political opinions, religious or philosophical beliefs
• trade union membership
• biometric data for the purpose of uniquely identifying a natural person
• data concerning health
• data concerning a natural person’s sex life or sexual orientation

If you choose to fill out an optional profile to share information about yourself with CAM4PAYS and our community of Guests and Affiliates, the Special Category of Personal Data we collect may include your ethnicity, sexual orientation, marital status, your profile picture and your biography.
Should you consent to such use, and never without your consent, this information is used by CAM4PAYS to identify you and provide you with the best possible user experience, support, and services. We also use this Personal Data to improve our marketing messages and campaigns to be relevant to your interest and experiences. You are of course free to edit, modify, delete and share your own personal information in your profiles, as long as it is compliant with law and our Terms of Service.

A. Operations

The CAM4PAYS Website is supported by a network of computers, cloud-based servers, and other information technologies including 3rd party service providers. Some of these services may come from jurisdictions other than your own, and those countries do not always afford an equivalent level of privacy protection. We have taken strict measures to protect your Personal Data; in particular, we rely on your explicit consent and security and confidentiality of your Personal Data in binding corporate rules and contractual protections. We are required to transfer your Personal Data with those parties in order to be able to provide the requested service to you.

B. Acknowledgement

You acknowledge that Personal Data you submit for publication or broadcast is available via the Internet, worldwide, and we cannot prevent the use or misuse of such Personal Data by others.

CAM4PAYS will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. CAM4PAYS’s Affiliates have control over the purpose for collecting data, and the duration for which the Personal Data may be kept. CAM4PAYS Affiliates will therefore have the responsibility to delete data when required. When a CAM4PAYS’s Affiliate’s account is terminated or expired, all Personal Data collected will be deleted, as required by applicable law, with the exception that we may retain your Personal Data where such retention is necessary for compliance with a legal obligation, or in order to protect your vital interests or the vital interests of another natural person.

CAM4PAYS Affiliates can at any time access and edit, update or delete their contact details by logging in with their username and password to CAM4PAYS’s Website.

A. The rights to access

You have the right to know whether or not we process your Personal Data and you have the right to access it along with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Data concerned and who has received it. Providing the rights of others are not affected, we will supply to you a copy of your Personal Data, at no charge. Additional copies are subject to a reasonable fee. You can access your Personal Data from inside your account details on our site.

B. The rights to rectification

You have the right to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Data about you completed.

C. The right to erasure

In some circumstances, you have the right to have us erase your personal data without undue delay. Those circumstances include: your Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and if the Personal Data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

D. The right to restrict processing

If you contest the accuracy of your Personal Data or if processing is unlawful but you oppose erasure; or if we no longer need the Personal Data for the purposes of our processing but you require personal data for the establishment, exercise or defense of legal claims; or if you have objected to processing, pending the verification of that objection, then you may restrict the processing of your Personal Data. However, in that event, we may continue to store your Personal Data and we will only process it with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural person, or for reasons of important public interest.

E. The right to object to processing

You have the right to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this purpose.

F. The right to data portability

If our legal basis for processing your Personal Data is consent; or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights of others.

G. The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you may have a legal right to lodge a complaint with a supervisory authority responsible for data protection. If you are a EU citizen, you have the right to do so in the EU member state of your residence, your place of work or the place of the infringement.

H. The right to withdraw consent

If the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by contact us at https://www.cam4Pays.com/contact, in addition to the other methods specified in this section.

A. Commencing January 1st, 2020, Cam4Pays.com is compliant with the California Consumer Privacy Act of 2018 (CCPA). As such, CAM4PAYS posts this California-specific addition to its GDPR compliant Privacy Policy. Once a year, prior to January 1 of the following year, this California-specific privacy policy will be amended pursuant the CCPA.

If you are a California resident, regardless of whether you are a customer or have any other relationship with CAM4PAYS, CAM4PAYS affords you five rights respecting your personal information.

These rights are:

1. The right to request disclosure of CAM4PAYS’s collection and sale of your data, including the categories of personal information CAM4PAYS collects, the source of that information, CAM4PAYS’s use of the information and, if CAM4PAYS disclosed your information to third parties, you have a right to know what categories of personal information were disclosed and the categories of third parties to whom such information was disclosed;
2. You have the right to request a copy of the specific personal information collected about you during the 12 months before your request (This, together with right #A, is a “personal information request”);
3. With few exceptions, you have the right to have CAM4PAYS delete such information;
4. You have the right to request that your personal information not be sold to third parties;
5. You have the right not to be discriminated against because you exercised any of these new rights, which is to say, you will receive equal service and pricing even if you exercise any of the above rights.

For purposes of the CCPA, the “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In the last 12 months, CAM4PAYS has collected information in the following categories:

• Identifiers (such as contact information, email address, Internet Protocol address, government IDs, cookies, etc.);Source: Consumer
• Information protected against security breaches (such as your name and credit card information, driver’s license, passport, social security number, username and password); Source: Consumer
• Protected classification information (like race, gender, ethnicity, etc.); Source: Consumer after specific consent
• Internet/electronic activity; Source: Electronic means/ Internet
• Commercial information; Source: Account activity
• Geolocation; Source: Electronic means/Internet
• Audio/video data; Source: Consumer, and
• Biometrics. Source: Consumer (Note: CAM4PAYS only collects information online).

In the last 12 months, CAM4PAYS has “sold” information in the following categories:

• Identifiers, specifically, contact information sent to a contracted third-party to assist consumers with their onboarding efforts.

In the last 12 months, CAM4PAYS has disclosed for a business purpose personal information in the following categories:

• Identifiers (such as contact information, government IDs, cookies, etc.), for the business purpose of law enforcement, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Information protected against security breaches (such as your name and financial account, driver’s license, social security number, username and password); for the business purpose of law enforcement, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Protected classification information (like race, gender, ethnicity, etc.) for the business purpose of analytic services;
• Internet/electronic activity; for the business purpose of analytic services;
• Commercial information; for the business purpose of analytic services;
• Geolocation; for the business purpose of analytic services;
• Audio/video data; for the business purpose of law enforcement, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

B. Exercising your rights

As a consumer of the CAM4PAYS Website, you can only make a personal information request two (2) times in a 12-month period. CAM4PAYS will then be afforded the opportunity to collect information from you so that it can verify your identity. Then, CAM4PAYS will respond to you within 45 days of receiving your personal information request.

To make a personal information request, please contact the customer service department of CAM4PAYS.com by clicking on this link https://www.cam4Pays.com/contact or calling this number +5999 736 6277.

C. Personal Data Sales Opt-Out

To make a choice regarding the selling of personal information, please sign in and visit the Privacy Settings in the My Account section.

Commencing January 1. 2021, CAM4PAYS is compliant with Federal Law No. 13,709/2018 - General Data Protection Law of Brazil ("LGPD"). This section provides additional information required by LGPD and is applicable to residents of Brazil. CAM4PAYS posts this Brazil-specific addition to its GDPR compliant Privacy Policy and will update it as necessary.

When CAM4PAYS acts as data controller with respect to collecting and processing personal data under LGPD, you have the right to make the following requests:

1. The right to confirmation of the existence of processing;
2. The right to access the data;
3. The right to correct incomplete, inaccurate or out-of-date data;
4. The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;
5. The right to the portability of data to another service or product provider, by means of an express request;
6. The right to delete personal data processed with the consent of the data subject;
7. The right to information about public and private entities with which the controller has shared data;
8. The right to information about the possibility of denying consent and the consequences of such denial;
9. The right to revoke consent.

To exercise any of these rights, please contact the customer service department of CAM4Pays.com by clicking on this link https://www.cam4Pays.com/contact or calling this number +5999 736 6277. You will need to provide your first name, last name, email address, and country of residence to submit a request. You will also be required to verify your identity before we are able to fulfill your request.

If you are located in Brazil when you visit the CAM4PAYS Website, we may transfer your personal data outside of Brazil. When we do, we will ensure that an adequate level of protection is provided for the transfer.

CAM4PAYS places cookies to store and then retrieve small bits of information on your computer when you visit. This is to ensure that our content is tailored to your specifications, thereby improving the visitor experience of the site. More details about how we use cookies you can find on Cookies Policy.

We assume that all users of our Website have carefully read this document and agree to its contents. If you do not agree with this Privacy policy, you should refrain from using our Website. We reserve the right to change our Privacy Policy as necessity dictates. Continued use of the CAM4PAYS Website after having been informed of any such changes to these conditions implies acceptance of the revised Privacy Policy. This Privacy Policy is an integral part of CAM4PAYS’s Terms and Conditions.

A. Owner

This Website is owned and operated by Surecom Corporation, NV, a company incorporated and located in Curaçao and principally located at Landhuis Joonchi, Kaya Richard J. Beaujon z/n, Willemstad, Curaçao

B. Contact information

If you have any further questions regarding the data CAM4PAYS collects, or how we use it, then please feel free to contact us:

By Post To: Surecom Corporation, NV Landhuis Joonchi, Kaya Richard J. Beaujon z/n, PO Box 837,Willemstad, Curaçao

Website Contact Form: Contact
General email contact: support@cam4pays.com

Data Protection Officer email contact: dpo@Cam4.com