Privacy Policy

Introduction

Darwin Technologies, Inc. ("Darwin," "we," "us," "our") operates the Darwin platform. This Privacy Policy describes how we collect, use, disclose, and protect your information when you use our Services, including the Darwin website (darwin.so/brands), campaign review pages, tracking technologies, and related services (collectively, the "Platform"). By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform.

1. Information We Collect

We collect information in various ways depending on how you interact with the Platform. The categories of information we collect include the following:

1.1 Account Information

When you create an account or register on the Platform, we collect your name, email address, company or organization name, job title, phone number, billing address, and payment information. Payment information is processed securely by our third-party payment processor, Stripe, and we do not store full credit card numbers on our servers.

1.2 Campaign Data

When you create and manage advertising campaigns through the Platform, we collect campaign budgets, flight dates, targeting parameters, brand assets (including logos, images, and creative materials), calls-to-action (CTAs), tracking links, redirect URLs, and brand preferences and guidelines that you provide.

1.3 Review and Approval Data

When campaigns are submitted for review and approval, we collect placement decisions (approved, counter-offered, or rejected), counter-offer pricing, rejection reasons, section-by-section feedback text and images, reviewer email addresses, and submission timestamps.

1.4 Tracking and Attribution Data

We collect data through various tracking and attribution technologies, including:

Data collected through the Darwin Tracking Pixel installed on Advertiser websites, including page views, conversions, and referral sources.
Click data from Darwin Tracking Links hosted on *.darwin.so subdomains, including click timestamps, referral sources, and device information.
QR code scan data and associated metadata.
Promo code redemption data.
Impression and view counts sourced from creator content platforms.

1.5 Usage Data

When you access the Platform, we automatically collect certain technical information, including your IP address, browser type and version, operating system, device information, pages visited, features used, actions taken, session duration, and referring URLs.

1.6 Communications

We collect information from your communications with us, including support requests, emails, feedback, and any other correspondence you send to Darwin.

2. How We Use Your Information

We use the information we collect for the following purposes:

To operate, maintain, and improve the Platform and our Services.
To process Campaign Reviews and Submissions, including generating placement previews and campaign proposals.
To calculate invoices, process payments, and manage billing.
To provide campaign performance analytics and attribution reporting.
To improve our AI algorithms, placement quality, and matching accuracy.
To communicate with you about campaigns, billing, account matters, and Platform updates.
To send product updates and marketing communications (you may opt out at any time).
To detect, investigate, and prevent fraud, abuse, unauthorized access, and other security incidents.
To comply with applicable legal obligations, resolve disputes, and enforce our Terms of Service.

We do not sell your personal information. We may share your information in the following circumstances:

3.1 With Creators and Publishers

We share campaign details as presented in the approval flow, including brand name, campaign brief, budget ranges, targeting parameters, brand assets, and CTAs. We do not share Advertiser's billing information, internal performance metrics, or counter-offer details with Creators or Publishers.

3.2 With Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including payment processors (Stripe), email services (Loops), hosting and infrastructure providers (Vercel, AWS), analytics providers, and AI/ML processing services. These providers are contractually bound to protect your data and may only use it for the purposes we specify.

Campaign performance data, including impressions, clicks, conversions, click-through rate (CTR), and return on ad spend (ROAS), may be shared with Creators in aggregate form to demonstrate placement effectiveness and inform future collaborations.

3.4 Legal Requirements

We may disclose your information if required to do so by law, subpoena, court order, or government request, or when we believe in good faith that disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others; to investigate potential violations of our Terms of Service; or to detect, prevent, or address fraud, security, or technical issues.

3.5 Business Transfers

In connection with a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you before your personal information becomes subject to a different privacy policy and provide you with the opportunity to opt out where applicable.

We may share your information for purposes not described in this Privacy Policy with your explicit consent.

4. Tracking and Attribution Technologies

4.1 Darwin Tracking Pixel

The Darwin Tracking Pixel is a JavaScript code snippet that Advertisers install on their websites to collect page view, conversion, and referral data. The pixel uses first-party cookies to attribute conversions to specific campaigns and placements. The Darwin Tracking Pixel does not track users across unrelated websites and does not build cross-site browsing profiles.

4.2 Darwin Tracking Links

Darwin Tracking Links are URLs hosted on *.darwin.so subdomains that redirect users to the Advertiser's destination URL. These links record click timestamps, referral sources, device information, and geographic data to provide accurate campaign attribution and performance measurement.

4.3 Cookies

We use essential cookies necessary for Platform functionality, analytics cookies for usage measurement and performance optimization, and preference cookies to remember your settings and choices. You may control cookie preferences through your browser settings. Please note that disabling certain cookies may limit your ability to use some features of the Platform.

4.4 Third-Party Analytics

We use Vercel Analytics for Platform usage measurement and performance monitoring. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP address. For information on how these third parties handle your data, please refer to their respective privacy policies.

5. Data Retention

We retain your information 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. Our specific retention periods are as follows:

Account Data: Retained while your account is active and for three (3) years after account closure for recordkeeping and to address any disputes or inquiries that may arise.
Campaign and Financial Data: Invoices, payment records, and campaign decisions are retained for seven (7) years for tax, accounting, and legal compliance purposes.
Tracking and Attribution Data: Retained for the campaign duration plus two (2) years to support ongoing performance analysis and dispute resolution.
Anonymized and Aggregated Data: Anonymized and aggregated analytics data that cannot be used to identify you may be retained indefinitely for research, product improvement, and statistical purposes.
You may request deletion of your personal data at any time, subject to our legal retention obligations as described above.

6. Data Security

We implement commercially reasonable technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit using TLS/SSL protocols and encryption of data at rest.
Role-based access controls and multi-factor authentication for internal systems.
Regular security assessments, vulnerability scanning, and penetration testing.
Incident response procedures to promptly detect, investigate, and remediate security events.

While we strive to protect your personal information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data, and you transmit information to us at your own risk.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

7.1 Access and Portability

You may request a copy of the personal data we hold about you in a structured, commonly used, and machine-readable format.

7.2 Correction

You may update or correct your account information at any time through your account settings or by contacting us directly.

7.3 Deletion

You may request deletion of your personal data. We will comply with your request subject to our legal retention requirements and other applicable exceptions under law.

7.4 Opt-Out of Marketing

You may opt out of receiving marketing communications at any time by clicking the "unsubscribe" link in any marketing email or by contacting us at privacy@darwin.so. Please note that even if you opt out of marketing communications, we may still send you transactional and service-related messages.

You may control cookies through your browser settings, including blocking or deleting cookies. Please be aware that disabling cookies may affect the functionality of the Platform.

7.6 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information is collected, disclosed, or sold; the right to request deletion of your personal information; the right to opt-out of the sale or sharing of your personal information (we do not sell personal information); and the right to non-discrimination for exercising your privacy rights. To exercise these rights, please contact us at privacy@darwin.so.

7.7 Exercising Your Rights

To exercise any of the rights described above, please contact us at privacy@darwin.so. We will verify your identity and respond to your request within thirty (30) days. If we need additional time, we will notify you of the reason and extension period.

8. International Data Transfers

Your information is processed and stored in the United States. If you access the Platform from outside the United States, please be aware that your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Platform, you consent to the transfer of your information to the United States. Where required by applicable law, we rely on Standard Contractual Clauses approved by the European Commission and other appropriate safeguards to ensure an adequate level of protection for international data transfers.

9. Children's Privacy

The Platform is not directed at individuals under the age of sixteen (16), and we do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal information from a child under the age of 16, we will take steps to delete such information promptly. If you believe that we may have collected information from a child under 16, please contact us immediately at privacy@darwin.so.

10. Third-Party Links and Services

The Platform may contain links to third-party websites, including creator channels, social media platforms, and advertiser websites. These third-party services are not operated by Darwin, and we are not responsible for the privacy practices, content, or data collection policies of these third parties. We encourage you to review the privacy policies of any third-party websites you visit before providing them with your personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will post the updated Privacy Policy on this page and update the "Last Updated" date at the top. For material changes that significantly affect your rights or obligations, we will provide at least thirty (30) days' prior notice via email to the address associated with your account or through a prominent notification on the Platform. Your continued use of the Platform after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@darwin.so
Company: Darwin Technologies, Inc.
Website: darwin.so

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