Affiliate Privacy Policy

Last updated: April 25, 2026

1. Introduction

This Affiliate Privacy Policy ("Policy") supplements the general ActiPatch® Privacy Policy and describes how Electrome Corporation ("Electrome," "we," "us") collects, uses, discloses, and protects information when you participate in the ActiPatch® Affiliate Program, including the affiliate portal, referral tracking tools, and commission reporting (collectively, the "Affiliate Services"). To the extent this Policy conflicts with the general Privacy Policy, this Policy controls with respect to the Affiliate Services.

2. Information We Collect from Affiliates

Registration and Identity Data

  • Full legal name, email address, and phone number
  • Account credentials and multi‑factor authentication identifiers
  • Business name, type, and legal structure (if registering as an entity)
  • Mailing address for tax documentation purposes

Financial and Tax Data

  • Bank account or PayPal information for commission payments (ACH routing and account numbers, or PayPal email)
  • Tax identification information: Social Security Number or Employer Identification Number (for U.S. persons, W‑9) or international tax forms (W‑8BEN)
  • Commission earnings history, payout records, and payment status

Referral and Performance Data

  • Unique affiliate code and referral link usage statistics
  • Click‑through rates, conversion events, and attributed transactions
  • Audience segment breakdown (consumer, provider, retailer, affiliate, investor referrals)
  • Commission tier, earnings summaries, and payout history

Platform Usage Data

  • Portal login times, feature interactions, and session duration
  • Device, browser, operating system, and IP address
  • Communications with Electrome affiliate support or operations teams

3. Legal Bases for Processing

We process affiliate data under the following legal bases:

  • Contract Performance: To operate the Affiliate Program, track referrals, calculate commissions, and process payments under the Affiliate Terms of Service and executed Affiliate Agreement.
  • Legal Obligation: To comply with IRS reporting requirements (1099‑NEC), anti‑money laundering regulations, FTC disclosure requirements, and other applicable laws.
  • Legitimate Interest: To prevent fraud, detect suspicious referral activity, improve the Affiliate Services, and maintain platform security.
  • Consent: Where required by law, including for optional analytics, marketing communications, and participation in promotional programs.

4. How We Use Affiliate Data

  • Verify your identity and evaluate your affiliate application
  • Generate and manage your unique referral links and affiliate code
  • Track referral clicks, attribute qualifying transactions, and calculate commissions
  • Process commission payments via ACH or PayPal
  • Generate IRS 1099‑NEC and other required tax documents
  • Detect and prevent referral fraud, cookie stuffing, and self‑referral schemes
  • Communicate program updates, commission statements, and payment notifications
  • Provide affiliate support and respond to your inquiries
  • Analyze aggregate referral performance to improve the Affiliate Program

5. How We Share Affiliate Data

We do not sell affiliate data. We share information only as needed to operate the Affiliate Program:

  • Payment Processors: Bank account or PayPal information is transmitted to our payment processors (Stripe, PayPal) to issue commission payments, under their respective privacy policies and PCI DSS compliance.
  • Tax Authorities: Tax identification information (SSN/EIN) is reported to the IRS as required by law (Form 1099‑NEC for earnings of $600 or more per calendar year).
  • Fraud Prevention: Referral activity data may be shared with fraud detection services to identify and prevent deceptive attribution practices.
  • Infrastructure Providers: Hosting, email, and analytics services operating under written confidentiality agreements.
  • Legal and Regulatory: When required by law, subpoena, court order, or to investigate fraud or violations of the Affiliate Terms.
  • Business Transfers: In connection with a merger, acquisition, or asset sale, with notice consistent with applicable law.

6. Data Security

We protect affiliate data using:

  • AES‑256 encryption at rest and TLS 1.2+ encryption in transit
  • Role‑based access controls limiting access to affiliate financial data to authorized personnel
  • Multi‑factor authentication for all affiliate portal accounts
  • Audit logging of all access to financial and tax records
  • Regular vulnerability assessments and penetration testing
  • PCI DSS compliance for all payment processing through Stripe

7. Data Retention

  • Account Data: Retained for as long as your affiliate account is active, plus two (2) years following account closure for audit and dispute resolution purposes.
  • Financial Records: Commission records, payout history, and tax documents are retained for seven (7) years in accordance with IRS record‑keeping requirements.
  • Referral Analytics: Aggregated and de‑identified referral performance data may be retained indefinitely for program analysis.
  • Tax Forms (W‑9, W‑8BEN): Retained for four (4) years following the last tax year in which they were used, consistent with IRS regulations.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access and receive a copy of your affiliate account data and commission history
  • Correct inaccurate registration or payment information
  • Request deletion of your account, subject to our legal and financial retention obligations (particularly tax records)
  • Opt out of non‑essential marketing communications
  • Request a machine‑readable export of your affiliate data within thirty (30) days of written request
  • Appeal a denial of any privacy rights request

To exercise your rights, contact our Privacy team (mention "Affiliate Privacy Request").

9. Cookies and Tracking

The Affiliate Services use first‑party cookies to maintain your portal session and track referral attribution. Referral attribution cookies are set when a prospective customer clicks your referral link and persist for the duration of the attribution window (currently 90 days). We do not use cross‑site behavioral advertising trackers within the affiliate portal.

10. Changes to This Policy

We may update this Affiliate Privacy Policy from time to time. Material changes will be communicated by email and through the affiliate portal at least fourteen (14) days before they take effect. The "Last updated" date above reflects the most recent revision.

11. Contact

Electrome Corporation
Privacy Officer
200 N Vineyard Blvd
Ste. A325 # 5743
Honolulu, HI 96817
Phone: (808) 300-5703
Privacy: contact our Privacy team · Affiliate Operations: contact Affiliate Operations