Privacy Policy
CashbackPro Legal Center
Table of Contents
- Introduction
- Definitions
- Data Controller Information
- Personal Data We Collect
- Legal Basis for Processing
- How We Use Your Data
- Data Sharing and Disclosure
- International Data Transfers
- Data Retention
- Your Rights
- Security Measures
- Cookies and Tracking Technologies
- Children's Privacy
- Changes to This Policy
- Contact Information
- Jurisdiction-Specific Provisions
1. Introduction
CashbackPro Ltd. ("we," "us," "our," or "CashbackPro") operates a global cashback rewards platform accessible at cashbackpro.org (the "Service"). We are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including:
- GDPR (General Data Protection Regulation - EU Regulation 2016/679)
- CCPA/CPRA (California Consumer Privacy Act and California Privacy Rights Act)
- Israel Privacy Protection Law 1981 (as amended)
- UK GDPR (UK Data Protection Act 2018)
This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and your rights regarding your data.
By using our Service, you acknowledge that you have read and understood this Privacy Policy.2. Definitions
For the purposes of this Privacy Policy:
- Personal Data: Any information relating to an identified or identifiable natural person.
- Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
- Data Controller: The entity that determines the purposes and means of processing personal data (CashbackPro Ltd.).
- Data Processor: An entity that processes personal data on behalf of the Data Controller.
- Data Subject: An individual whose personal data is processed.
- Consent: Freely given, specific, informed, and unambiguous indication of agreement to processing.
- Third Party: Any natural or legal person other than the Data Subject, Controller, Processor, or their authorized representatives.
- Cashback: Commission earned by users through affiliate purchases made via our Service.
- Affiliate Partner: Third-party merchants (e.g., AliExpress) with whom we have partnership agreements.
3. Data Controller Information
Company Name: CashbackPro Ltd. Registration Number: [To be provided] Registered Address: [To be provided], Israel Email: [email protected] Data Protection Officer (DPO): [email protected] Website: https://cashbackpro.org4. Personal Data We Collect
We collect personal data in the following categories:
4.1 Data You Provide Directly
Account Registration:- Full name
- Email address
- Password (encrypted)
- Country of residence
- Preferred language
- Date of birth (for age verification)
- PayPal email address
- Stripe account details
- Cryptocurrency wallet addresses
- Bank account information (if applicable)
- Tax identification numbers (when required by law)
- Government-issued ID documents
- Proof of address
- Selfie photographs (for identity verification)
- Support tickets and correspondence
- Feedback and survey responses
- Email communications with our team
4.2 Data Collected Automatically
Technical Data:- IP address
- Browser type and version
- Operating system
- Device identifiers (device ID, advertising ID)
- Screen resolution
- Time zone settings
- Referral source
- Pages visited
- Time spent on pages
- Click patterns
- Search queries
- Features used
- Error logs
- Cookies and similar technologies
- Device fingerprints
- Session recordings (anonymized)
- Heatmaps (anonymized)
4.3 Data from Third Parties
Affiliate Partners:- Order information (order ID, amount, status)
- Purchase timestamps
- Product categories
- Commission amounts
- Tracking parameters (sub_id, click_id)
- Transaction confirmations
- Payment status
- Fraud risk assessments
- Profile information
- Email address
- Profile picture
- Risk scores
- Device reputation
- Behavioral analysis
5. Legal Basis for Processing
We process your personal data based on the following legal grounds (GDPR Art. 6):
5.1 Performance of Contract (Art. 6(1)(b))
- Creating and managing your account
- Processing cashback rewards
- Facilitating withdrawals
- Providing customer support
5.2 Legitimate Interests (Art. 6(1)(f))
- Fraud prevention and security
- Service improvement and analytics
- Marketing to existing customers
- Network and information security
5.3 Legal Obligation (Art. 6(1)(c))
- Tax reporting and compliance
- Anti-money laundering (AML) checks
- Know Your Customer (KYC) verification
- Responding to legal requests
5.4 Consent (Art. 6(1)(a))
- Marketing communications (where required)
- Non-essential cookies
- Third-party data sharing (where applicable)
6. How We Use Your Data
We use your personal data for the following purposes:
6.1 Service Provision
- Account creation and authentication
- Tracking affiliate clicks and purchases
- Calculating and crediting cashback
- Processing withdrawal requests
- Sending transactional emails (order confirmations, payment notifications)
6.2 Security and Fraud Prevention
- Detecting and preventing fraudulent activities
- Verifying user identity (KYC/AML)
- Monitoring for suspicious behavior
- Protecting against unauthorized access
6.3 Customer Support
- Responding to inquiries
- Resolving disputes
- Investigating complaints
- Providing technical assistance
6.4 Analytics and Improvement
- Analyzing usage patterns
- Improving user experience
- Developing new features
- Conducting A/B testing
- Performance monitoring
6.5 Marketing and Communications
- Sending promotional emails (with consent)
- Personalized offers and recommendations
- Newsletters and updates
- Referral program communications
6.6 Legal and Compliance
- Complying with legal obligations
- Enforcing our Terms of Service
- Protecting our legal rights
- Responding to legal requests
7. Data Sharing and Disclosure
We share your personal data with the following categories of recipients:
7.1 Affiliate Partners
Who: AliExpress, eBay, and other merchant partners What: Click tracking data, order information, user identifiers Why: To track purchases and calculate cashback Legal Basis: Performance of contract7.2 Payment Processors
Who: PayPal, Stripe, cryptocurrency payment gateways What: Payment details, transaction amounts, user identifiers Why: To process withdrawals and payments Legal Basis: Performance of contract7.3 Service Providers
Who: Hosting providers, email services, analytics tools What: Technical data, usage data, contact information Why: To operate and maintain our Service Legal Basis: Legitimate interests7.4 Anti-Fraud Services
Who: Fraud detection and prevention providers What: Device data, behavioral data, transaction patterns Why: To prevent fraud and abuse Legal Basis: Legitimate interests7.5 Legal Authorities
Who: Law enforcement, regulators, courts What: Any data required by law Why: To comply with legal obligations Legal Basis: Legal obligation7.6 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change. We do not sell your personal data to third parties for their marketing purposes.8. International Data Transfers
CashbackPro operates globally. Your personal data may be transferred to and processed in countries outside your country of residence, including:
- Israel (our primary servers)
- European Union (cloud infrastructure)
- United States (payment processors, analytics services)
8.1 Transfer Safeguards
For transfers outside the EEA, we use the following safeguards:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy Decisions (for countries deemed adequate by the EU)
- Binding Corporate Rules (where applicable)
- Your explicit consent (where required)
8.2 Israel Adequacy Decision
Israel has received an adequacy decision from the European Commission, meaning data transfers to Israel are considered to provide adequate protection.
9. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
9.1 Retention Periods
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Account data (active users) | Duration of account + 3 years | Contract performance |
| Financial transaction records | 7 years | Tax and AML laws |
| KYC/AML verification documents | 5 years after account closure | Legal obligation |
| Marketing consent records | Until consent withdrawn + 3 years | Accountability |
| Server logs and analytics | 90 days | Legitimate interests |
| Support tickets | 3 years after resolution | Legitimate interests |
| Fraud investigation data | 7 years | Legal obligation |
9.2 Account Deletion
When you delete your account:
- Personal identifiers are anonymized within 30 days
- Financial records are retained for legal compliance (7 years)
- Aggregated, anonymized data may be retained indefinitely
10. Your Rights
Under GDPR, CCPA, and other applicable laws, you have the following rights:
10.1 Right to Access (GDPR Art. 15)
You may request a copy of your personal data we hold.10.2 Right to Rectification (GDPR Art. 16)
You may request correction of inaccurate or incomplete data.10.3 Right to Erasure / "Right to be Forgotten" (GDPR Art. 17)
You may request deletion of your data, subject to legal retention requirements.10.4 Right to Restriction of Processing (GDPR Art. 18)
You may request that we limit how we use your data.10.5 Right to Data Portability (GDPR Art. 20)
You may request your data in a structured, machine-readable format.10.6 Right to Object (GDPR Art. 21)
You may object to processing based on legitimate interests or for direct marketing.10.7 Rights Related to Automated Decision-Making (GDPR Art. 22)
You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects.10.8 Right to Withdraw Consent
Where processing is based on consent, you may withdraw it at any time.10.9 Right to Lodge a Complaint
You may file a complaint with your local data protection authority:- EU: Your national DPA (list at https://edpb.europa.eu)
- Israel: Privacy Protection Authority (https://www.gov.il/en/departments/the_privacy_protection_authority)
- UK: Information Commissioner's Office (https://ico.org.uk)
10.10 How to Exercise Your Rights
Email: [email protected] Subject Line: "Data Subject Rights Request" Include: Your name, email, account details, and specific request Response Time: We will respond within 30 days (GDPR) or 45 days (CCPA).11. Security Measures
We implement appropriate technical and organizational measures to protect your personal data:
11.1 Technical Measures
- Encryption: SSL/TLS for data in transit, AES-256 for data at rest
- Access Controls: Role-based access, multi-factor authentication
- Firewalls: Network segmentation and intrusion detection
- Regular Security Audits: Penetration testing and vulnerability assessments
- Secure Development: Code reviews and security testing
11.2 Organizational Measures
- Data Protection Policies: Internal policies and procedures
- Employee Training: Regular privacy and security training
- Confidentiality Agreements: All employees sign NDAs
- Incident Response Plan: Procedures for data breach notification
- Vendor Management: Due diligence on third-party processors
11.3 Data Breach Notification
In the event of a data breach, we will:
- Notify affected users within 72 hours (GDPR requirement)
- Notify relevant supervisory authorities
- Provide information about the breach and mitigation steps
12. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience. For detailed information, please see our Cookie Policy.
12.1 Types of Cookies
Essential Cookies:- Authentication and session management
- Security and fraud prevention
- Load balancing
- Google Analytics (anonymized IP)
- Usage statistics and performance monitoring
- Affiliate tracking pixels
- Retargeting and personalization
- Conversion tracking
12.2 Managing Cookies
You can control cookies through:
- Browser Settings: Most browsers allow you to refuse cookies
- Cookie Consent Tool: Available on our website
- Opt-Out Links: For third-party cookies (e.g., Google Analytics opt-out)
13. Children's Privacy
Our Service is not intended for individuals under 18 years of age (or 16 in the EEA).
We do not knowingly collect personal data from children. If we become aware that we have collected data from a child without parental consent, we will take steps to delete it promptly.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us at [email protected].14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.
14.1 Notification of Changes
Material Changes:- Email notification to registered users (30 days' notice)
- Prominent notice on our website
- Updated "Last Updated" date
- Updated "Last Updated" date
- Notice on website
14.2 Continued Use
Your continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.
We encourage you to review this Privacy Policy periodically.15. Contact Information
For privacy-related questions, requests, or complaints:
General Privacy Inquiries: Email: [email protected] Data Protection Officer: Email: [email protected] Legal Department: Email: [email protected] Mailing Address: CashbackPro Ltd. [Street Address] [City, Postal Code] Israel Response Time: We aim to respond within 5 business days.16. Jurisdiction-Specific Provisions
16.1 European Union (GDPR)
Legal Representative in the EU: [To be appointed if required] Data Protection Authority: You may lodge a complaint with your national DPA. Data Transfers: We use Standard Contractual Clauses for transfers outside the EEA.16.2 California (CCPA/CPRA)
California Residents have additional rights: Right to Know: Categories and specific pieces of personal information collected. Right to Delete: Request deletion of personal information (subject to exceptions). Right to Opt-Out of Sale: We do not sell personal information. Right to Non-Discrimination: We will not discriminate against you for exercising your rights. Shine the Light: Request information about data shared with third parties for marketing (if applicable). To Exercise CCPA Rights: Email: [email protected] Subject: "California Privacy Rights Request" Verification: We may request additional information to verify your identity. Authorized Agent: You may designate an authorized agent to make requests on your behalf.16.3 Israel
Privacy Protection Authority Registration: [Registration number to be provided] Data Breach Notification: We will notify the Privacy Protection Authority within 72 hours of becoming aware of a breach. Data Subject Rights: Israeli residents have rights similar to GDPR, including access, correction, and deletion.16.4 United Kingdom
ICO Registration: [Registration number to be provided] UK GDPR Compliance: We comply with UK GDPR and the Data Protection Act 2018. UK Representative: [To be appointed if required]17. Additional Information
17.1 Do Not Track Signals
Our Service does not currently respond to "Do Not Track" (DNT) browser signals. We will update this policy if we implement DNT support in the future.
17.2 Third-Party Links
Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review their privacy policies.
17.3 Automated Decision-Making
We use automated systems for:
- Fraud Detection: Flagging suspicious transactions
- Cashback Matching: Matching orders to user accounts
Last Updated: February 6, 2026 Version: 2.0 Effective Date: February 6, 2026
© 2026 CashbackPro Ltd. All rights reserved.
Have questions about our policy?
[email protected]