Privacy Policy

1. Introduction

Everon Technologies LLC ("we", "us", or "our") is committed to protecting the personal information of Affiliates who access the Partner Portal to participate in the XGB and EHP Vendor Programs. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in connection with the Portal.

By using the Portal, you acknowledge and consent to the data practices described in this Privacy Policy. This Policy should be read in conjunction with our Terms of Service.

2. Information We Collect

2.1 Information You Provide

When you register and use the Portal, we may collect:

• Identity data: full name, date of birth, government-issued ID details (where required for verification);
• Contact data: email address, phone number, mailing address, and, where you have opted in, your mobile number and SMS opt-in status;
• Business data: company name, business registration number, website URL, tax identification number;
• Financial data: bank account details, PayPal address, or other payment information required to process Commission payments;
• Program data: vendor program selections (XGB, EHP, or both), promotional materials used, and campaign details; and
• Communications: messages, support requests, and other correspondence you send through the Portal.

2.2 Information Collected Automatically

When you access the Portal, we automatically collect:

• Technical data: IP address, browser type and version, operating system, device identifiers;
• Usage data: pages visited, links clicked, time spent, referring URLs, and navigation paths;
• Tracking data: cookies, pixel tags, and similar tracking technologies used to attribute referrals and measure campaign performance; and
• Log data: access logs, error logs, and other system-generated records.

2.3 Information from Other Sources

We may receive information about you from:

• XGB and EHP: transaction data, conversion data, and other program-specific performance metrics;
• Payment processors: transaction confirmations and payment status updates; and
• Identity verification services: results of any identity or fraud checks conducted in connection with your registration.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• Account Management: to create, maintain, and administer your Affiliate account;
• Program Administration: to track referrals, calculate Commissions, and manage your participation in the XGB and/or EHP Programs;
• Payments: to process and remit Commission payments to you;
• Communication: to send you program updates, policy changes, promotional materials (where consented), and transactional notifications;
• Compliance and Verification: to verify your identity, comply with legal obligations, and prevent fraud;
• Analytics and Improvement: to analyze Portal usage, improve functionality, and develop new features;
• Security: to detect, investigate, and prevent security threats, unauthorized access, and other malicious activity; and
• Legal: to enforce our Terms of Service, resolve disputes, and respond to legal processes.

4. Legal Basis for Processing (where applicable)

Where required by applicable data protection law, we rely on the following legal bases to process your personal information:

• Contractual Necessity: processing required to perform our obligations under the Terms of Service;
• Legitimate Interests: processing for fraud prevention, security, and improvement of the Portal;
• Legal Obligation: processing required to comply with applicable laws and regulations; and
• Consent: where you have given explicit consent, such as for marketing communications.

5. Information Sharing and Disclosure

We do not sell your personal information. We may share your information with:

5.1 Vendor Partners (XGB and EHP)

We share relevant Affiliate data with XGB and EHP for the purpose of administering the Vendor Programs, including tracking referrals, validating conversions, and facilitating Commission payments. Each vendor is subject to its own privacy obligations. XGB and EHP are separate data controllers with respect to the personal information they receive, and their handling of your information — and any communications they send you — is governed by their own privacy policies, not this Policy. Everon is not responsible for the privacy practices, communications, or content of XGB, EHP, or any other entity, regardless of any corporate affiliation between such entity and Everon.

5.2 Service Providers

We engage trusted third-party service providers (e.g., payment processors, analytics providers, cloud hosting providers, identity verification services, and our SMS messaging platform and aggregator) who process data on our behalf. These providers are contractually obligated to protect your information and may only use it to perform services for us.

5.3 Legal and Regulatory Authorities

We may disclose your information if required to do so by law, court order, or governmental authority, or where we believe disclosure is necessary to: (a) protect our legal rights; (b) enforce our Terms of Service; or (c) prevent fraud or imminent harm.

5.4 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring, your personal information may be transferred to the successor entity, subject to the same privacy protections.

6. SMS / Text Message Communications

If you opt in to receive text messages from Everon, we will send account-related SMS notifications only — such as sign-in and security alerts, Portal invitations, application and enrollment status updates, deal and commission notices, and support responses. This section should be read alongside our dedicated SMS Terms.

6.1 No Promotional Messages

We do not send marketing, advertising, or promotional text messages. The SMS program is used exclusively for account-related notifications and short operational announcements from your own organization within the Portal, each prompting you to log in for details.

6.2 No Sensitive Information by Text

We will never send protected health information, member or employee personal data, government identification numbers, or financial account details through SMS. Text messages contain only general notifications that prompt you to log in to the Portal, where all sensitive information is available securely.

6.3 Message Frequency

You will receive up to 10 messages per month. Message frequency may vary based on your account activity.

6.4 Message and Data Rates

Message and data rates may apply depending on your mobile carrier and plan.

6.5 Mobile Information Non-Sharing

We do not sell, rent, or share your mobile phone number or SMS opt-in information with third parties or affiliates for their marketing or promotional purposes. Mobile opt-in data and consent are never shared with any third party. Your mobile number is used solely to deliver the account-related messages you have requested.

6.6 Opting Out

You can opt out at any time by replying STOP to any message, or by updating your notification preferences in your account settings. Reply HELP for assistance.

7. Cookies and Tracking Technologies

The Portal uses cookies and similar tracking technologies to:

• Maintain your session and authentication;
• Track referral activity and attribute Commissions accurately;
• Analyze traffic patterns and Portal usage; and
• Detect and prevent fraud.

You may control cookie settings through your browser settings; however, disabling certain cookies may affect the functionality of the Portal, including the accurate tracking of your Referral Links. By continuing to use the Portal, you consent to our use of cookies as described in this Policy.

8. Data Retention

We retain your personal information for as long as your Affiliate account is active or as necessary to fulfill the purposes for which it was collected. Following termination of your account, we may temporarily retain certain information to comply with legal obligations, resolve disputes, prevent fraud, and enforce our agreements. Financial records may be retained for a longer period as required by applicable tax and accounting laws.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, destruction, or alteration. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest;
• Access controls and authentication mechanisms;
• Regular security assessments and monitoring; and
• Staff training on data protection obligations.

While we take reasonable steps to protect your information, no method of transmission over the internet is completely secure. You are responsible for maintaining the confidentiality of your Portal credentials.

10. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your jurisdiction. Where such transfers occur, we take appropriate safeguards to ensure your information is protected in accordance with applicable data protection laws, including the use of standard contractual clauses or other approved transfer mechanisms.

11. Non-Everon Communications and Links

The Portal may contain, transmit, or display communications, content, offers, or links originating from XGB, EHP, other Affiliates, or other entities or persons other than Everon. This Privacy Policy applies only to information collected by Everon through the Portal. Everon does not control, and is not responsible for, the content, accuracy, data practices, or privacy policies of any other entity — including entities that share corporate affiliation, common ownership, or branding with Everon — or any communications such entities send to you on, through, or in connection with the Portal. We encourage you to review the privacy policies of any entity with which you interact.

12. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

• Access: the right to request a copy of the personal information we hold about you;
• Rectification: the right to request correction of inaccurate or incomplete information;
• Erasure: the right to request deletion of your personal information, subject to certain exceptions;
• Restriction: the right to request that we restrict the processing of your information;
• Portability: the right to receive your personal information in a structured, machine-readable format;
• Objection: the right to object to processing based on legitimate interests or for direct marketing purposes; and
• Withdrawal of Consent: where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing; and
• Communication Preferences: the right to opt in or out of text message communications at any time (reply STOP), and to manage your notification settings in your account.

To exercise any of these rights, please contact us using the details in Section 15. We will respond to all requests within the timeframe required by applicable law. We may require verification of your identity before processing your request.

13. Children's Privacy

The Portal is not directed at, and we do not knowingly collect personal information from, individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete that information promptly.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by posting the revised Policy on the Portal and updating the effective date. Your continued use of the Portal after any changes constitutes acceptance of the revised Policy.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact the Everon team (legal@everon.tech).