HOLYDEEDS INC — Apostolic Partner Network Privacy Policy
Last Updated: 16th of March, 2025

This Privacy Policy (“Policy”) explains how HOLYDEEDS INC (“HolyDeeds,” “we,” “us,” or “our”) collects, uses, shares, and protects personal data related to individuals and organizations (“Partners,” “you,” or “your”) who participate in the HolyDeeds Apostolic Partner Network (Affiliate Program).

This Policy supplements the general HolyDeeds Privacy Policy and applies specifically to affiliate and partner activities.

1. Who We Are

HolyDeeds Inc is a Florida Profit Corporation, registered under document number P25000025726, with offices at:
• USA (Headquarters): 20900 NE 30th Ave, Suite 200, Aventura, FL 33180
• Lithuania: Aukštaicių str. 7, Vilnius, Lithuania
• United Kingdom: 128 City Road, EC1V 2NX, London, United Kingdom

We comply with data protection laws including the EU GDPR, UK GDPR, CCPA, and other international privacy standards.

For any privacy-related inquiries, contact us at: privacy@holydeeds.com

2. Data We Collect from Partners

a) Information You Provide
We collect the following information directly from you:
• Full name, contact details (email, phone, address)
• Business or organization name (if applicable)
• Payment and payout details such as bank or wallet information
• Tax or identification information (for example W-9, W-8BEN, or VAT ID)
• KYC/AML verification data when required by law
• Communication preferences and consent records

b) Automatically Collected Data
We also collect certain data automatically when you use our Partner Portal or share referral links, such as:
• IP address, browser type, and device information
• Login and activity logs
• Referral and conversion data linked to affiliate links
• Cookies and tracking pixels used for attribution

c) Communications
We may store records of communications between you and HolyDeeds, including onboarding correspondence, compliance checks, and payout support.

3. Purpose and Legal Basis of Processing

We use your personal data for the following purposes:
• To register you as a Partner and manage your participation in the Program
• To calculate and process commissions and payouts
• To verify your identity and comply with anti-fraud, AML, and tax laws
• To communicate with you about performance, reports, and updates
• To send occasional marketing or mission-related messages (only with your consent)
• To comply with our contractual and legal obligations

We process this data on the legal bases of contractual necessity, legal obligation, legitimate interest, and where applicable, consent.

4. Cookies and Tracking Technologies

HolyDeeds uses cookies, pixels, and unique tracking links to attribute referrals and calculate commissions.
These technologies collect pseudonymous data such as referral ID, timestamp, and conversion source.
You can manage or disable cookies in your browser settings. Disabling essential tracking may prevent proper referral attribution or payout calculation.

5. How We Use Your Data

We use your data to:
• Register and authenticate your Partner account
• Track link activity and calculate Shared Blessings (commissions)
• Process commission payments and generate related financial records
• Communicate with you about updates, policies, and performance
• Ensure program compliance and prevent misuse
• Improve the Partner Portal and support tools

We do not use affiliate data for unrelated marketing, advertising, or profiling.

6. Data Sharing and Disclosure

We only share your data when necessary and under contractual safeguards with:
• Payment processors and banks for payout processing
• KYC and AML service providers for identity verification
• Analytics providers for partner performance tracking
• Affiliate program management software providers
• Legal or regulatory authorities if required by law
• IT and hosting providers that securely manage our systems

We never sell or rent your personal data.

7. Data Retention

We retain Partner data only for as long as required for the purposes described above.
• Contract and financial records are typically kept for 5–7 years to comply with accounting and tax obligations.
• Compliance and AML documentation are retained for as long as required by applicable laws.
• Active Partner account data is stored for the duration of participation in the Program.

After these periods, data is securely deleted or anonymized.

8. International Data Transfers

Your data may be processed in the United States, the European Union, the United Kingdom, and other jurisdictions.
When data is transferred internationally, we apply safeguards such as Standard Contractual Clauses (SCCs) to ensure appropriate protection.

9. Your Rights

Depending on your jurisdiction, you may have the right to:
• Access your personal data and request a copy
• Correct or update inaccurate data
• Request deletion of your data (subject to retention laws)
• Restrict or object to certain processing
• Withdraw consent for optional processing such as marketing
• Receive your data in a portable format

To exercise your rights, contact us at privacy@holydeeds.com.

10. Data Security

We use encryption, secure servers, and access control systems to protect your information.
All payment and identification data are transmitted securely and stored only for as long as required for legal or operational purposes.
While we maintain strong safeguards, no system is entirely immune from risk.

11. Partner Communications

HolyDeeds may contact you regarding:
• Account, payment, or commission updates
• Policy or technical changes related to the Program
• Mission and campaign notifications relevant to your participation

You may opt out of optional communications at any time by updating your preferences or emailing privacy@holydeeds.com.

12. Children’s Privacy

The Apostolic Partner Network is not intended for individuals under the age of 18.
We do not knowingly collect or process personal data from minors.

13. Updates to This Policy

We may update this Privacy Policy periodically to reflect operational or legal changes.
The latest version will be available on our website or Partner Portal with a revised “Last Updated” date.
Continued participation after an update constitutes acceptance of the revised Policy.

14. Contact Us

HOLYDEEDS INC
20900 NE 30th Ave, Suite 200
Aventura, FL 33180, USA
Email: privacy@holydeeds.com
Website: https://holydeeds.com