Privacy Policy

Last updated: 30 September 2026

This Privacy Policy explains how Griffin Digital Solutions ltd collects, uses, stores and discloses information from users (each, a "User") of the tulpn.com website (the "Site"). It applies to the Site and to all products and services we offer through it.

Griffin Digital Solutions ltd is a company incorporated under English law, with its address at 28 Peel Place, IG5 0PS, London, UK (“tulpn.com”, “Griffin Digital”, “We”, “Us”).

About tulpn.com and the people who use it

tulpn.com is a technical platform for running affiliate programs. Three groups of people are involved:

• Customers are businesses that run their own affiliate program on tulpn.com. Each Customer has its own subdomain (for example, customername.tulpn.com) and connects its own systems to ours.

• Promoters (also called affiliates) sign up to one or more Customers' programs, share referral links, and use tulpn.com to see their referrals and commissions and to request payouts from the Customer.

• Referred Users are people who sign up with, or buy from, a Customer after following a Promoter's link.

We provide the software that records referrals and calculates commissions. We do not run the affiliate programs, set their terms, or handle any money. Commissions are owed and paid by the Customer, directly to the Promoter. The service is currently free, and we do not take a share of any commission.

Personal identification information

We may collect personal identification information from Users in a number of ways, including when they visit the Site, register on the Site, subscribe to the newsletter, or use other activities, services, features or resources we make available on the Site. Where appropriate, Users may be asked for an email address.

Users may visit the Site anonymously. We collect personal identification information only if Users voluntarily submit it to us. Users can always refuse to supply it, although this may prevent them from using certain parts of the Site.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with the Site. This may include the browser name, the type of computer, and technical information about how Users connect to the Site, such as the operating system, the Internet service provider, and other similar information.

Web browser cookies

The Site may use "cookies" to enhance the User experience. A User's web browser places cookies on their device for record-keeping purposes and sometimes to track information about them. Users may set their web browser to refuse cookies, or to alert them when cookies are being sent. If they do so, some parts of the Site may not function properly.

How we use collected information

We may collect and use Users' personal information to:

• operate and improve our product;

• send you advertising or promotional materials, where you have agreed to receive them;

• provide and deliver the product or other services you request, record referrals and commissions, and send you related information;

• send you technical notices, updates, security alerts, and support and administrative messages;

• respond to your comments, questions and requests, and provide the customer support you ask for;

• monitor and evaluate trends, usage and activities in connection with our product;

• secure our systems, prevent fraud, and help protect your account;

• prevent, detect and investigate potentially prohibited or illegal activities, and enforce our terms and policies;

• personalize and improve the product, and provide content, communications or features that match your interests; and

• link or combine it with other information we obtain from third parties, to help us understand your needs and provide you with a better service.

We reserve the right at all times to review your content and information to help resolve problems with our software or product.

Information we may share

We will never sell your personal information. However, we may share your personal information with third parties as follows:

• Service providers: We use other companies, agents or contractors to perform services on our behalf, or to help us provide services to you. For example, we engage service providers for marketing, advertising, communications, security, payment processing, infrastructure and IT services, to customize, personalize and optimize our Product, to provide customer service, and to analyze and enhance data. While providing these services, they may have access to your personal information. They have agreed to maintain the confidentiality, security and integrity of the personal information they obtain from us, and we do not authorize them to use or disclose it except in connection with providing their services.

• Protection of Griffin Digital and others: We and our service providers may disclose and otherwise use your personal information where we or they reasonably believe this is needed to (i) satisfy applicable law, regulation, legal process or governmental request; (ii) enforce applicable terms of use, including investigating potential violations; (iii) detect, prevent or otherwise address illegal or suspected illegal activity, security or technical issues; or (iv) protect against harm to the rights, property or safety of Griffin Digital, our Users or the public, as required or permitted by law.

• Business transfers: In connection with any reorganization, restructuring, merger, sale or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your privacy in a manner consistent with this Privacy Policy.

• Other users: Content that you create, upload or copy into our Product may, if you choose, be read, copied, used and distributed by people you know, your members, or people you don’t know. Information that you disclose using the chat function of the Product may be read, copied, used and distributed by people participating in the chat. Take care when including sensitive information, such as home addresses or phone numbers, in content you share or in chat sessions.

• With your consent: We may share your personal information when we have your consent.

Whenever, in the course of sharing information, we transfer personal information to countries within the European Economic Area or other regions with comprehensive data protection laws, we will ensure that it is transferred in accordance with this Privacy Policy and as permitted by the applicable data protection laws.

Advertising and analytics services provided by others

We may allow others to provide analytics services and display advertisements for our product. These providers (for example, Google Analytics) may use cookies, web beacons, device identifiers and other tracking technologies that collect information about your use of our product. We and others may use this information to determine the popularity of our product, to deliver advertising and content targeted to your interests, in the product and on other websites, apps and services, and to better understand your online activity.

You can find out more about this practice, or opt out of having your web browsing activity used for interest-based advertising, by visiting https://aboutads.info/choices. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

How we store and protect your information

We adopt appropriate data collection, storage and processing practices, and security measures, to protect against unauthorized access to, or alteration, disclosure or destruction of, your personal information, username, password, transaction information and data stored on the Site.

Our servers are hosted in data centres in the United Kingdom and Europe. Some of our service providers may store or process data in other regions. Your data is encrypted and stored on secure servers.

Sharing your personal information

We do not sell, trade or rent Users' personal identification information to others. We may share generic, aggregated demographic information about visitors and Users, not linked to any personal identification information, with our trusted business partners and advertisers for the purposes outlined above.

Data retention and deletion

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to comply with legal, accounting or reporting requirements. Once that period has expired, we will securely delete or anonymize your data so that it can no longer be reconstructed or retrieved. This also applies to any data received from Google through API services, which is used exclusively to enhance our user-facing features.

You have the right to request the deletion of your personal data at any time. We will process such requests in accordance with applicable data protection laws and our internal data retention policies.

Third party websites

Users may find advertising or other content on the Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites, and we are not responsible for the practices of websites linked to or from the Site. These sites and services, including their content and links, may change constantly, and they may have their own privacy and customer service policies. Browsing and interacting on any other website, including websites that link to the Site, is subject to that website's own terms and policies.

Third parties who provide or publish content through our Product are the data controllers for any personal data contained in the content they upload to the Product (“Third-Party Content”), and for any other personal data processed in relation to it. This Privacy Policy only covers the processing for which Griffin Digital Solutions ltd is the data controller. If you have any questions about personal data contained in Third-Party Content, please contact the third party responsible for it.

Disclosure of use of Google API services

We may use Google’s Application Programming Interface (API) services to let you sign in to our platform with your Google account.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Types of data collected with Google API services

The information we collect and use through these API services includes personal data such as email addresses and first and last names.

Use of Google API services data

Our developers use your Google information to provide or improve user-facing features that are important to your experience. Our policies and procedures prohibit the unauthorized use of data within the platform.

To improve the platform, we may need to share your information with other members of the Griffin Digital team. Our policies allow this only where it is:

• necessary to provide or improve user-facing features that are prominent in the requesting app’s user interface; or

• necessary to comply with applicable laws.

Griffin Digital team members are never allowed to use or transfer restricted scope data to serve Users advertisements. This includes personalized, re-targeted and interest-based advertising.

Securing your data

We take data security seriously. We have put in place technical and organizational measures to protect your information from unauthorized access, loss or alteration. These include encrypted storage, restricted internal access, regular backups, and continuous monitoring of our systems. All data is stored on secure servers.

Data privacy

We collect and use your data only to deliver our services, improve your experience, or meet legal requirements. We do not sell your personal information, and we do not use it for advertising without your permission. If you have any questions or concerns about your data, please contact us through the "Contact us" section of the Site.

Changes to this privacy policy

We may update this Privacy Policy at any time. When we do, we will revise the "Last updated" date at the top of this page. We encourage Users to check this page frequently for changes, to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and to be aware of any modifications.

Your acceptance of these terms

By using the Site, you accept this Privacy Policy. If you do not agree to it, please do not use the Site. Your continued use of the Site after changes to this policy are posted will be deemed your acceptance of those changes. Acceptance records, including the IP address, are kept.