Data Processing Addendum

This addendum applies to Business customers and forms part of the Terms. Requests under it go through the contact form.

Scope. Since 5 September 2026 Licensed Data contains no personal data: the registry supplies the official contact channels a programme publishes for affiliates (role mailboxes, sign-up and tracking links), not the names, personal mailboxes or messenger handles of individuals. This addendum therefore governs your account data and records the roles for what remains; it is retained because business buyers are asked for one, not because personal data changes hands.

1. Roles

For your account data we are the controller (see Privacy Policy). We do not process personal data on your instructions and are therefore not your processor. Licensed Data transfers no personal data to you, so no controller-to-controller transfer of personal data arises under it; if a role mailbox you receive is in fact read by an identifiable person, you are the sole controller of whatever you then do with it.

2. Our commitments

Sourcing: official contact channels published by the programmes for affiliate contact; no enrichment from other sources, and no supply of named individuals’ details to any customer.
Security, breach notification and assistance with data-subject requests: to the extent applicable law requires of an independent controller.
Transparency: this policy set is published and versioned.

3. Your commitments

A lawful basis and a compliant notice for your own outreach to the addresses you receive (legitimate interest for B2B outreach where allowed; consent where required); honouring opt-outs; no resale or enrichment; deletion when no longer needed.
Appropriate security for Licensed Data you store; no transfer outside your organisation.
Telling us through the contact form if you receive a complaint that concerns data we supplied, so we can remove it at source.

4. International transfers

Our processors outside the EU/UK are bound by the EU-US Data Privacy Framework and/or Standard Contractual Clauses as listed in the Privacy Policy. Licensed Data itself carries no personal data, so its download raises no transfer question.

5. Liability and term

Each party is liable for its own processing. This addendum lasts as long as you hold Licensed Data. Governing law as in the Terms. Version 2026-09-05.

These documents are written in good faith for a small data business and reviewed against the rules that apply in the EU/UK and the US. They are not legal advice; where mandatory law in your country grants you more rights than stated here, those rights apply.