Affiliate Privacy Notice
This notice explains how Prime Layer Group, S.A. ("Identiful") processes the personal data of participants in the Identiful Affiliate Program, in accordance with Law 81 of 2019 on the protection of personal data of the Republic of Panama and its regulations. It complements the general Identiful Privacy Policy. Version 1.0, effective September 18, 2026.
1. Who is responsible
The data controller is Prime Layer Group, S.A., domiciled in Panama City, Republic of Panama, operator of the Identiful brand. You can reach us about your data through the contact page of identifulstudio.com.
2. What data we collect
Identity and contact: name, email, phone, country of residence, company and website or main social profile.
Fiscal data: person type, legal name, fiscal address, country of tax residence, tax identification number (RUC and DV, SSN/EIN or foreign tax id), US-person status, the tax forms you upload (W-9, W-8BEN, W-8BEN-E) and the electronic invoices you issue to us.
Payment data: the PayPal account email or the email or US mobile number registered with Zelle, and the account holder's name.
Program activity: referral clicks and attributed orders (with the buyer's country and a masked email, never the buyer's full contact data), commissions, payouts, vouchers, compliance cases and the declarations you accepted.
3. Why we use it and on what legal basis
To evaluate your application and run the program, including tracking, commissions and payouts: performance of the agreement you accept.
To issue vouchers, apply tax withholding, keep accounting records and meet tax and anti-money-laundering obligations: legal obligation.
To screen against sanctions lists, prevent fraud and supervise promotional compliance: legitimate interest and legal obligation.
Anything beyond these purposes requires your prior, informed and unequivocal consent, which you may withdraw at any time without affecting earlier processing.
4. How we protect it
Tax identification numbers and payout identifiers are encrypted before they are stored, and are shown masked (last 4 characters) everywhere in the platform. Only authorized administrators can reveal them, one at a time and with a stated reason, and every reveal is recorded in an audit log.
Tax forms, invoices and payment vouchers are kept in private storage and are only reachable through temporary links. Any change to your payout details must be confirmed with a code sent to your email, and payouts wait 48 hours after such a change.
5. Who we share it with
Our technology providers (application hosting and email delivery), which process the data only on our instructions; PayPal or the banks participating in Zelle to make your payments; our accountants and legal advisors; and tax or other authorities when the law requires it. We do not sell your data or share it with other affiliates or with buyers.
6. International transfers
Our hosting and email providers may store or process data outside Panama, including in the United States. We transfer data only to providers that offer adequate safeguards and under the conditions required by Law 81 of 2019.
7. How long we keep it
Fiscal, payment and accounting records (vouchers, withholdings, invoices, tax forms and the related identifiers) are kept for 7 years after the fiscal year they relate to. The rest of your affiliate data is kept while your account is active and deleted or anonymized within 12 months after it ends, unless a claim or legal obligation requires keeping it longer.
8. Your rights
You can request access to, rectification, cancellation or opposition to the processing of your data, and data portability, through the contact page. We will answer within the time limits set by Law 81 of 2019. Some data cannot be deleted while we are legally required to keep it. If you are not satisfied with our answer, you can file a complaint with the National Authority for Transparency and Access to Information (ANTAI).
9. Changes
We will tell you about material changes to this notice through your affiliate panel or by email before they take effect.