1. Who We Are
MassPartner is operated by Fehu Marketing Limited, a company incorporated in Hong Kong.
Registered address:
31/F., Chinachem Century Tower
178 Gloucester Road, Wanchai
Hong Kong 999077
Contact email: [email protected]
When this Privacy Policy refers to "MassPartner," "we," "us," or "our," it means Fehu Marketing Limited and the MassPartner platform accessible at masspartner.com.
2. Data We Collect
We collect the following categories of personal data:
- Account Data: Full name, email address, password (hashed), phone number, and profile details provided during registration.
- Business Data: Company name, website URL, VAT/tax number, business address, and industry vertical provided by brands and affiliates.
- Financial Data: Bank account details, PayPal address, or cryptocurrency wallet address for payment processing. We do not store full payment card numbers.
- Usage Data: Pages visited, clicks, time on site, referral source, IP address, browser type, operating system, and device identifiers.
- Tracking Data: Affiliate link clicks, conversion events, campaign performance metrics, and UTM parameters.
- Communications Data: Messages sent through our contact form, support tickets, or email correspondence with our team.
- Verification Data: Identity verification documents (e.g., government-issued ID) where required for compliance purposes.
- Cookie Data: Session identifiers, preference cookies, and analytics cookies as described in Section 5.
3. How We Use Your Data
We use your personal data for the following purposes:
- Service Delivery: To create and manage your account, process affiliate commissions, track campaign performance, and provide platform features.
- Payments: To calculate and process commission payouts, issue invoices, and maintain financial records.
- Communication: To send transactional emails (account verification, payout notifications, campaign approvals), respond to support queries, and provide platform updates.
- Marketing: To send promotional communications about new features or partner opportunities where you have given consent or where we have a legitimate interest.
- Analytics & Improvement: To understand how users interact with the platform, identify bugs, and improve our services.
- Compliance & Fraud Prevention: To detect and prevent fraudulent traffic, click fraud, spam, and other prohibited activities; and to comply with applicable laws.
- Legal Obligations: To maintain records required by Hong Kong law, respond to lawful requests from authorities, and enforce our Terms of Service.
4. Legal Basis for Processing (GDPR)
For users located in the European Economic Area (EEA) or United Kingdom, we process personal data under the following legal bases pursuant to Article 6 of the GDPR:
- Contract (Art. 6(1)(b)): Processing necessary to perform the contract between you and MassPartner (e.g., account management, payout processing).
- Legitimate Interests (Art. 6(1)(f)): Platform security, fraud detection, analytics, and improving our services, where our interests are not overridden by your rights.
- Consent (Art. 6(1)(a)): Marketing communications and non-essential cookies where you have provided explicit consent.
- Legal Obligation (Art. 6(1)(c)): Compliance with financial recordkeeping, anti-money laundering (AML), and other applicable regulations.
5. Cookies & Tracking Technologies
We use cookies and similar technologies on our platform. These include:
- Strictly Necessary Cookies: Session cookies required for login, security, and core platform functionality. These cannot be disabled.
- Analytics Cookies: Google Analytics cookies that help us understand traffic patterns and usage behaviour. These are set only with your consent.
- Advertising Cookies: Google Ads conversion tracking cookies (gtag.js) used to measure the effectiveness of our paid advertising campaigns.
- Affiliate Tracking Cookies: First-party cookies that store affiliate identifiers and campaign parameters to attribute conversions accurately. These are essential to the affiliate tracking service.
- Preference Cookies: Cookies that remember your settings and preferences on the platform.
You may control non-essential cookies through your browser settings. Disabling certain cookies may impact platform functionality.
6. Data Sharing & Third Parties
We do not sell your personal data. We share data only with trusted third parties as necessary to operate the platform:
- Payment Processors: PayPal, Wise, and bank transfer networks process financial transactions. These providers operate under their own privacy policies.
- Cloud Infrastructure: Hosting and database providers who store data on secure servers. These providers are contractually bound to data protection standards.
- Email Service Providers: SendGrid for transactional email delivery.
- Analytics Providers: Google Analytics for platform usage analytics.
- CDN Providers: BunnyCDN for delivering banner and creative assets.
- Brand Partners: When you (as an affiliate) are approved by a brand, limited profile information (name, marketing channel summary) is shared with that brand.
- Law Enforcement / Authorities: Where required by applicable law, court order, or governmental authority, including in Hong Kong under the Personal Data (Privacy) Ordinance (Cap. 486).
7. International Data Transfers
MassPartner is operated from Hong Kong. Your data may be transferred to and processed in countries outside your country of residence, including the United States and European Union, where our service providers operate.
For transfers of EEA/UK personal data to third countries, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission.
- Adequacy decisions where applicable.
- Binding Corporate Rules or other appropriate safeguards.
By using MassPartner, you acknowledge that your data may be processed in jurisdictions with different data protection laws than your home country.
8. Data Retention
We retain your personal data for as long as necessary to provide our services and fulfil the purposes outlined in this policy:
- Account Data: Retained for the duration of your account plus 3 years following account closure, for legal and dispute resolution purposes.
- Financial Records: Retained for 7 years in accordance with Hong Kong Companies Ordinance and tax regulations.
- Tracking & Analytics Data: Retained for up to 26 months, then aggregated or deleted.
- Support Communications: Retained for 3 years from the date of the last interaction.
- Marketing Consents: Retained until you withdraw consent, plus 3 years for evidence of consent.
After the applicable retention period, data is securely deleted or anonymised.
9. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
- Right of Access (Data Access Request): Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure ("Right to Be Forgotten"): Request deletion of your personal data where there is no legitimate ground for continued processing.
- Right to Data Portability: Receive your data in a structured, machine-readable format.
- Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
- Right to Restrict Processing: Request that we limit how we process your data in certain circumstances.
- Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.
To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.
If you are in the EEA, you also have the right to lodge a complaint with your national data protection supervisory authority.
Under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486), you also have the right to request access to and correction of your personal data held by us.
10. California Residents (CCPA)
If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the CPRA:
- Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you in the past 12 months.
- Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions.
- Right to Opt-Out of Sale: We do not sell your personal information. We do not and will not sell personal data to third parties.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
- Right to Correct Inaccurate Information: Request correction of inaccurate personal information.
- Right to Limit Use of Sensitive Personal Information: Where we process sensitive personal information, you may request we limit such use.
To submit a CCPA request, contact us at [email protected] with the subject line "CCPA Request."
11. Children's Privacy
MassPartner is not directed to individuals under the age of 18. We do not knowingly collect personal data from persons under 18 years of age. If you are under 18, do not use or register on this platform.
If we become aware that we have collected personal data from a child under 18, we will take immediate steps to delete that information. If you believe we may have collected data from a minor, contact us at [email protected].
12. Security
We implement industry-standard technical and organisational measures to protect your personal data:
- All passwords are hashed using bcrypt with a cost factor of 12.
- Data is encrypted in transit using TLS 1.2 or higher (HTTPS).
- Database access is restricted to authorised personnel only.
- Regular security reviews and access logging.
- Two-factor authentication available for administrative accounts.
No method of transmission over the internet is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify affected users and relevant authorities as required by law.
13. Contact Us
For any privacy-related queries, data access requests, or complaints, please contact our Data Protection contact:
Fehu Marketing Limited
31/F., Chinachem Century Tower
178 Gloucester Road, Wanchai
Hong Kong 999077
Email: [email protected]
14. Policy Updates
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email and/or by displaying a prominent notice on the platform.
The "Last updated" date at the top of this policy reflects the most recent revision. Continued use of MassPartner after any changes constitutes acceptance of the updated policy. We encourage you to review this page periodically.
For significant changes affecting how we process personal data, we will seek your consent where required by law.