SHOPTHRU LIMITED (“Shopthru”) is a company registered under company number 10295802, with its address at Severn House, Middle Street, Brighton, East Sussex, England, BN1 1AL
Shopthru operates an embedded commerce platform that enables publishers (“Publishers”) to promote products from participating advertisers (“Advertisers”) using hosted storefronts and embedded checkout tools. Publishers earn commissions on qualifying sales completed through the Shopthru platform. These Terms & Conditions govern the relationship between Shopthru and the Publisher.
The participants in the Shopthru Network include:
a) advertisers who have agreed with Shopthru to join the Shopthru Network to promote its products and/or services (“Advertisers”);
b) publishers who are operators of a website, application or service, and who have joined the Shopthru Network to market Advertisers’ products as an affiliate (“Publishers“), and
c) Shopthru itself.
Advertisers promote their products and services via Shopthru through Partner Programs (“Partner Programs”) . Publishers participate by sharing curated product recommendations, storefronts, or embedded Shopthru content across their websites, newsletters, or social channels. For every successful transaction completed via these experiences, Shopthru pays the Publisher a pre-defined commission (“Commission”).
These Terms and Conditions for Publishers (“Terms & Conditions“) shall govern your participation in the Shopthru Network as a Publisher.
Unless otherwise specified in these Terms & Conditions, capitalised terms shall have the meanings given to them in Schedule A (Definitions), and the interpretation of these Terms & Conditions shall be in accordance with paragraph 1 of Schedule A (Definitions).
1. JOINING THE SHOPTHRU NETWORK AS A PUBLISHER
1.1 Publishers must register on the Shopthru website (shopthru.com) to join the Shopthru Network (registration being the “Effective Date“).
1.2 The registration with and participation in the Shopthru Network is free of any charge.
1.3 After joining, Publishers may apply to participate in Advertisers’ Partner Programs and begin promoting their products through Shopthru storefronts or product links embedded in their content.
1.4 Legal entities or private individuals over 18 years of age may register as Publishers, and each Publisher must have a bank account. Shopthru reserves the right to verify the Publishers’ personal data. Registration with the Shopthru Network is not transferable and Shopthru reserves the right to refuse a registration without citing any reasons for its refusal.
1.5 Access to the Shopthru Network will be gained upon registration and by following the activation instructions sent by Shopthru confirming the Publisher’s registration.
1.6 The portal for registered members (“Shopthru Portal”) will provide Publishers with an overview and all relevant details of the Advertisers’ Partner Programs that are open at that time for their participation.
1.7 Using the Shopthru portal, the users can review and alter their personal data and information.
2 PARTICIPATION IN THE SHOPTHRU NETWORK AS A PUBLISHER
2.1 On the Shopthru Network:
2.1.1 Publishers (whether individuals or legal entities) may promote Advertisers and their products by including Shopthru storefronts or product links within their websites, emails, newsletters, or other content channels.
2.1.2 Publishers may also operate as content networks that include additional contributors or creators (“Sub-Publishers”) who share Shopthru experiences through their own content.
2.1.3 By participating in the Shopthru Network, including by applying to Partner Programs or sharing Shopthru content, the Publisher agrees to be bound by these Terms & Conditions. This constitutes a legally binding agreement between the Publisher and Shopthru..
2.2 Publishers may apply to participate in Partner Programs listed on the Shopthru platform. Where approved, they can promote Advertisers’ products using Shopthru storefronts or embedded commerce tools across their content. For the avoidance of doubt, Shopthru does not review, monitor, or take responsibility for product information or content provided by Advertisers.
2.3 When a consumer completes a purchase via a Shopthru storefront or checkout experience associated with a Publisher’s content, the Publisher will earn a Commission in accordance with the terms of the relevant Partner Program. Commissions are based on completed transactions and tracked automatically by Shopthru’s platform.
2.4 The types of transactions eligible for Commission, and the applicable Commission amounts, are defined in each Advertiser’s Partner Program as listed in the Shopthru Portal. Unless otherwise specified, Commission is paid on completed sales only. Any variations, such as lead-based campaigns, will be clearly stated within the Partner Program terms.
2.5 Shopthru records all transactions completed through its platform (“Tracking”) and credits the resulting Commission to the Publisher’s account within the Shopthru Portal. Shopthru’s tracking system shall be the sole source of truth for determining valid transactions and calculating Commissions. Shopthru warrants that its tracking and data handling practices comply with all applicable laws.
2.6 Publishers can manage their commerce activity using the Shopthru interface. They are able to select products, create curated storefronts, and access links or widgets to share within their content. All available tools and features are visible in the interface.
2.7 Shopthru will use reasonable endeavours to ensure that, where possible, the available features are up-to-date, complete, and correct. Certain functions may be temporarily unavailable due to maintenance or other improvements. Where any interruption or failure has a greater than a minor impact, Shopthru will reasonably endeavour to remedy the same without delay and to the extent that it is feasible to do so.
2.8 Shopthru endeavours to continuously develop and improve the Shopthru Network. In the course of such development, Shopthru may enhance, expand, or modify individual features. This includes discontinuing functionalities or other features of the services. Shopthru reserves the right to make such changes at its sole discretion, including the withdrawal of features or services, provided such changes do not materially and adversely affect the core purpose of this Agreement. Where reasonably practicable, Shopthru will provide prior notice of material changes.
3 PARTICIPATION IN PARTNER PROGRAMS
3.1 Publishers shall apply to participate in available Partner Programs using the Shopthru Interface and must provide all relevant information about where and how they intend to promote Shopthru content, such as their website, newsletter, or social platforms.
3.2 As part of the application process, the Publisher’s submitted information, including details about their content channels and promotional approach, will be reviewed against the eligibility criteria of the relevant Partner Programs.
3.3 By submitting their application for a Partner Program, Publishers accept any additional conditions for participation displayed in the context of that Partner Program, which shall become an integral part of this contract.
3.4 The Advertisers may accept or reject Publishers’ applications at their sole discretion, and Publishers are not entitled to automatic acceptance as a participant in respect of any Partner Program on the Shopthru Network.
3.5 Publishers warrant that the information they provide about their content channels, audience, and promotional approach is accurate and complete. If Shopthru determines that a Publisher’s actual use of Shopthru tools does not align with the information provided during the application process, Shopthru reserves the right to suspend or block the Publisher’s account without delay. The procedure following such suspension is set out in clause 5.3 of these Terms.
3.6 During the term of this contract, the Publisher must not circumvent Shopthru by concluding new contracts or entering contractual negotiations with the Advertisers of the Shopthru Network that cover the subject matter of this contract or services alike.
4 DUTIES OF THE PUBLISHER
4.1 By registering to join the Shopthru Network:
4.1.1 Publishers agree that their registration and participation in the Shopthru Network will be subject to these Terms & Conditions.
4.1.2 Publishers warrant that all information and data provided at registration on the Shopthru website is correct and complete. Should the information and data provided at registration change at any time after registration, the Publisher shall promptly change their profile stored on the Shopthru Interface.
4.1.3 Publishers subject to turnover tax are under obligation to submit to Shopthru, as part of their contact details, their taxpayer identification number issued by their local tax authority or the VAT identification number.
4.1.4 Publishers undertake to keep the access data selected at registration (email address and password) confidential, not to communicate such data to third parties, and to keep such data away from third parties. No third party must be enabled to use the access data. Publishers who have reason to assume that third parties have become aware of their access data must inform Shopthru without delay in writing or by email sent to servicedesk@shopthru.com.
4.2 Publishers must only share Shopthru links or storefronts within content or platforms they own, manage, or have the right to publish on.
4.3 By participating in a Partner Program and promoting products through Shopthru storefronts or links, Publishers warrant that:
(a) The content or platforms they use to share Shopthru experiences comply with all applicable laws and regulations;
(b) Their promotional activities do not infringe any third-party rights, including intellectual property or privacy rights; and
(c) Their content does not promote or include hate speech, violence, racism, pornography, or any material that could reasonably be considered harmful, offensive, or inappropriate for a general audience.
4.4 If a Publisher shares Shopthru links or storefronts via email, they must comply with all applicable anti-spam laws. This includes obtaining valid consent from recipients before sending such emails. Upon request, the Publisher must provide evidence of consent for any marketing emails that include Shopthru-related content.
4.5 Publishers must not use paid search, display ads, or any other promotional methods that include the Advertiser’s trademark or brand name, or that of the Advertiser’s competitors, without the prior written consent of the Advertiser. This includes bidding on brand terms in search engines (“Brand Bidding”).
4.6 Publishers hereby undertake to refrain from attacks of any kind on the Shopthru Network. Attacks are, without limitation, defined in particular as attempts to overcome or circumvent the security mechanisms of the Shopthru Network or to otherwise incapacitate them, using computer programs enabling automatic data readouts, as well as using and/or circulating viruses, worms, trojans, brute force attacks, or using other links, programs, or procedures that are suited to damage the Shopthru Network or individual participants in the Shopthru Network.
4.7 Publishers who are operating a network with Sub-Publishers hereby guarantee to communicate these Terms & Conditions to their Sub-Publishers and to monitor and enforce their compliance. Publishers will be liable for all acts or omissions by their Sub-Publishers, and their failure to abide by these Terms & Conditions.
5 MISUSE OF SHOPTHRU NETWORK
5.1 The Publisher shall not engage in any conduct that constitutes misuse of the Shopthru Network. For the purposes of this clause, “misuse” includes, but is not limited to, procuring business transactions through unfair methods or inadmissible means, including any that violate applicable law, these Terms & Conditions, or the guiding principles of the Shopthru Network.
5.2 Without prejudice to clause 5.1 above, Publishers are prohibited from attempting to earn Commissions through fraudulent or manipulative means. This includes, but is not limited to:
5.1.1 generating or simulating transactions themselves or through third parties for the sole purpose of earning Commissions (e.g. placing fake orders, using unauthorised third-party data, or submitting false customer information)
5.1.2 manipulating embedded checkout or storefront placements in a way that misleads users or misrepresents the source or intent of the content
5.1.3 Any use of paid search, including bidding on brand terms related to Advertisers, unless explicitly approved in writing by Shopthru or the relevant Advertiser.
5.3 If Shopthru reasonably suspects that the Publisher has procured business transactions using unfair, deceptive, unlawful, or otherwise inadmissible methods (including those referred to in Clause 3.5), it may immediately suspend the Publisher’s account. Shopthru shall promptly notify the Publisher of any such suspension and the reasons for it. The Publisher may object to the suspension within one month (e.g., via letter or email) and submit a statement with supporting evidence demonstrating that the advertising activity in question was in accordance with these Terms & Conditions or that the suspension was otherwise unwarranted.
Shopthru shall review the Publisher’s submission in good faith and determine, in its reasonable opinion, whether a breach has occurred. If such a breach is confirmed, Shopthru will issue a notice of termination. Upon termination, the agreement shall be wound up and liquidated pursuant to Clause 5 of these Terms & Conditions. The Publisher shall not be entitled to any further remuneration.
6 PAYMENT OF COMMISSION
6.1 The amount of the Commissions, and the type of business transactions entitling the payment of Commissions, shall depend on each respective Advertiser’s Partner Program and will be set out in the relevant Partner Program specifications.
6.2 The Advertiser may modify the conditions of the Partner Program or terminate the entire Partner Program at its sole discretion. Publishers are not entitled to demand that a Partner Program is run by an Advertiser or is run on any certain conditions other than those set out by the Advertiser in the Partner Plan specification. Publishers have no claim to compensation, cost, expenses or losses in any form if a Partner Program does not proceed or is cancelled by the Advertiser.
6.3 The entitlement to receive Commissions are conditional upon:
6.3.1 a qualifying transaction being completed via Shopthru-hosted checkout
6.3.2 the transaction being recorded within Shopthru’s attribution system; and
6.3.3 no breach of these Terms & Conditions
6.4 Shopthru will set up a dedicated account for Publishers on the Shopthru Portal (“Publisher Accounts“) for the payments of the Commissions. The Publisher balance will be settled according to the condition laid out in the corresponding partner program. Shopthru will credit the respective Commissions to the Publisher Accounts without requiring an invoice. No interest will be paid on the credit balance in the Publisher Account. Once the minimum disbursement amount of GBP 25.00 has been reached, Shopthru will automatically issue a corresponding credit statement and disburse the amount to the Publisher’s nominated bank account at the beginning of the following calendar month. Payments are processed on a monthly basis, free of charge. If requested by the Publisher, Shopthru may agree to receive invoices instead of operating under the self-invoicing arrangement.
6.5 The commission amount displayed in the Shopthru portal reflects the net amount payable to the Publisher after Shopthru’s standard 10% platform fee has been applied. This fee is deducted automatically from the gross commission paid by the Advertiser before disbursement to the Publisher. Shopthru will process all commission payments on a monthly basis, and any deductions will be itemised in the Publisher Portal. By participating in the Shopthru Network and using its services, the Publisher agrees to this standard deduction as part of the platform model.
7 TERM OF AGREEMENT AND TERMINATION
7.1 This Agreement shall commence on the date the Publisher opens a Shopthru Account (or upon execution of a separate written agreement, if applicable) and shall continue until terminated by either party in accordance with the terms of this Agreement.
7.2 The Publisher may terminate this Agreement at any time by providing written notice (including by email), or by closing their Shopthru Account via the Publisher Portal, in which case no further payments shall be due other than any outstanding balance earned prior to termination.
7.3 Shopthru may terminate this Agreement for convenience by providing at least thirty (30) days’ written notice to the Publisher. Termination by Shopthru shall be without prejudice to its other rights of termination under this Agreement and shall not affect Shopthru’s obligation to pay any Commission earned by the Publisher prior to the effective date of termination
7.4 Any transactions completed via the Publisher’s content prior to termination will be processed in accordance with clause 6, provided they were validly tracked before the termination notice was received. Upon termination of this agreement, any remaining credit balance will be paid to the Publisher, minus a processing fee of £5.00. If the credit balance is £5.00 or less, no funds will be disbursed.
7.5 Once participation in the Shopthru Network has been terminated, the data record stored at registration will be deleted completely upon expiry of the statutory obligation to keep records in safe custody.
8 TERMINATION OF PARTICIPATION BY SHOPTHRU ON GROUNDS OF INACTIVITY / STATUTE OF LIMITATIONS
8.1 Registration requires the account to be activated on the Shopthru platform. The registration of Publishers with Shopthru who fail to activate the registration will be automatically cancelled after 60 days. It is possible to re-register.
8.2 If no Commissions have been credited to the Publisher Account for a period of twelve months after registration, Shopthru reserves the right to close the account and to cancel the registration. It is possible to re-register.
8.3 Individual Commissions credited to the Publisher Account must be disbursed within three (3) years from the end of the calendar year in which each Commission was credited. If not disbursed within this period, the Commission shall be deemed forfeited and removed from the Publisher Account balance. Shopthru will provide the Publisher with at least thirty (30) days’ prior written notice before any such forfeiture, giving the Publisher the opportunity to update payment details or request disbursement of the outstanding balance
9 DATA PROTECTION
9.1 Shopthru does not collect, process, or store personal data such as customer names, email addresses, or other identifying information.
9.2 Shopthru only collects non-personal data that is necessary to operate the Shopthru Network. This data is used to facilitate tracking, attribution, and reporting within the Shopthru Network.
9.3 Shopthru may contact Publishers using the contact information provided during registration or onboarding, for example to share relevant network updates, performance insights, or changes to terms. Publishers can unsubscribe from non-essential communications via the link provided in each message.
9.4 Any data collected will only be used for the purposes outlined above. Shopthru will not use this data for any other purpose unless required to do so by law or explicitly agreed to by the Publisher.
9.5 Publishers can request details of any data held about their activity within the Shopthru Network by contacting us at servicedesk@shopthru.com.
10 RIGHTS OF USE
10.1 Publishers (and, where applicable, Advertisers) shall use the information and data obtained through participation in the Shopthru Network solely in connection with the Shopthru Network. They shall not disclose such information or data to third parties, nor use it for any other purpose.
10.2 The Shopthru Network, Portal and Interface and all Intellectual Property Rights therein together with all Intellectual Property Rights created by Shopthru in the course of providing the Shopthru Network (Shopthru IPR) are and shall remain the sole and exclusive property of Shopthru (or its third-party licensor(s)).
10.3 Shopthru hereby grants to the Publishers a revocable, non-exclusive, non-transferable right to use the Shopthru Network, Portal and Interface and its applications as well as the data contained therein, in accordance with the terms of this Agreement applicable laws, and solely for the purpose of participating in the Shopthru Network. Upon termination of this Agreement, for any reason, this right of use shall be immediately revoked.
10.4 Publishers will not be granted any further rights of use. Publishers shall not: (i) transmit the applications or the data contained in the Shopthru Network to third parties; (ii) allow third parties to access such applications or data; (iii) modify or otherwise process such applications or data; (iv) incorporate the applications or data into another work, or use them in order to create databases or information services of their own.
10.5 The Publisher grants Shopthru a non-exclusive, royalty-free right to use the Publisher’s name, logo, and brand marks for the purpose of identifying the Publisher as a participant in the Shopthru Network, including on Shopthru’s website, sales materials, investor presentations, and other promotional content. The Publisher may withdraw this consent at any time by providing written notice to Shopthru, after which Shopthru will cease further use within a reasonable period.
11 INDEMNIFICATIES
11.1 Compliance with these provisions is essential for the operation of the Shopthru Network.
11.2 If a Publisher or their Sub-Publisher materially breaches this Agreement and such breach results in a third-party claim against Shopthru, the Publisher shall indemnify Shopthru against all reasonable costs, liabilities, and expenses (including legal fees) arising directly from that claim.
11.3 This includes, in particular, claims arising from:
(a) infringement of intellectual property rights by Publisher content; or
(b) unauthorised use of Advertiser Materials in breach of this Agreement.
11.4 Shopthru shall indemnify the Publisher against any third-party claim that the Shopthru Network, including its software or any materials provided by Shopthru, infringes intellectual property rights. This indemnity shall be unlimited.
11.5 Each party is responsible for its own content and conduct. Shopthru shall not be liable for the actions or content of other participants, including Advertisers or Publishers, but will use reasonable endeavours to ensure all participants comply with applicable advertising standards and the terms of this Agreement.
12 LIABILITY AND LIMITATION OF LIABILITY
12.1 Shopthru shall not be held liable for the content of websites of third parties, nor shall it be liable for any damages or other failures resulting from any defects of the participants’ software or hardware or their incompatibility with the Shopthru Network, Portal or Interface; Shopthru shall not be liable for losses resulting from the fact that the internet was not available or malfunctioning.
12.2 Nothing in this Agreement shall limit or exclude either party’s liability for:
- death or personal injury caused by negligence.
- fraud or fraudulent misrepresentation.
- any other liability which cannot be excluded or limited under applicable law.
Each party’s liability to the other under any indemnity in this Agreement shall be unlimited.
12.3 Each party’s liability in respect of any breach of applicable data protection laws shall be limited to £1,000,000.
12.4 Subject to Clauses 12.1 to 12.3, the total liability of each party in contract, tort (including negligence or breach of statutory duty), misrepresentation, restitution or otherwise arising in connection with this Agreement shall be limited to an amount equal to the total Commission paid or payable under this Agreement in the 12-month period immediately preceding the date on which the claim arose.
13 MODIFICATION OF THESE TERMS & CONDITIONS
13.1 Shopthru reserves the right to amend these Terms & Conditions where such amendments are minor in scope or nature and do not result in a fundamental restructuring of the Agreement. Any such modifications will be communicated to the Publisher by email at least 30 days prior to the effective date. If the Publisher objects to the changes, it must notify Shopthru in writing within 14 days of receiving the notice. In the absence of any objection, the changes shall be deemed accepted. If the changes would significantly disadvantage the Publisher or alter the nature of the Agreement in a way that undermines the Publisher’s trust, they will not take effect without the Publisher’s express consent.
13.2 If the Publisher does not raise an objection, then the modified Terms & Conditions shall be deemed to have been accepted. Shopthru will inform the Publisher, in its notification of amendment, about the right to object and of the significance of the objection deadline.
14 GENERAL PROVISIONS
14.1 These Terms & Conditions shall be governed by the laws of England and Wales, to the exclusion of the UN Sales Convention. The courts of England shall have exclusive jurisdiction over any and all disputes arising out of or related to this Agreement.
14.2 Should one or more provisions be or become invalid, this shall not affect the validity of the agreement as a whole.
14.3 Neither party may assign, transfer, or otherwise dispose of its rights or obligations under this Agreement without the prior written consent of the other party, such consent not to be unreasonably withheld or delayed. However, Shopthru may assign or transfer this Agreement without prior consent in connection with a merger, acquisition, corporate reorganisation, or sale of all or substantially all of its assets, provided that the Publisher is notified of such transfer.
In such cases, if prior written consent has not been obtained, the Publisher shall have the right to terminate this Agreement by giving written notice within 30 days of receiving notice of the transfer. If the Publisher does not exercise this right within that period, the Agreement shall continue with the new entity.
15 NOTIFICATION
15.1 General correspondence between the Publisher and Shopthru may be conducted via email or through the Shopthru Network interface.
15.2 Formal notices under this Agreement (including notices of termination or legal objection) must be sent in writing and delivered by post or courier to the recipient’s registered office address or another address expressly provided for correspondence. Notices will be deemed received two Business Days after posting within the UK, or five Business Days if sent internationally.
15.3 Shopthru may, at its discretion, disregard any formal notice sent by email unless Shopthru has expressly confirmed in writing that such notice will be accepted by email.
SCHEDULE A
DEFINITIONS
The following definitions and rules of interpretation apply in these Terms & Conditions:
“Approved Transaction” means a Transaction approved by the Advertiser;
“Business Day” means a day other than a Saturday, Sunday, or national public holiday in the United Kingdom;
“Confidential Information” means any information disclosed by or relating to a party, including: information arising during the term of this Agreement; information about a party’s business affairs; any reports generated by use of the Interface, information about a party’s operations, products, or trade secrets; information about a party’s technology (including any know-how and source code) and any derivatives of any part of any of them and which (i) is marked or identified as confidential; or (ii) would be regarded as confidential by a reasonable business person;
“CPA” means a Commission charged per Approved Transaction;
“Data Regulation” means any data protection, privacy or similar laws that apply to Personal Data Processed in connection with this Agreement, including without limitation, any regulations or restrictions under (i) the Electronic Communications Privacy Act (ECPA), (ii) the Children’s Online Privacy Protection Act of 1998 (COPPA), (iii) the GDPR, (iv) ePrivacy,
“ePrivacy” means the Privacy and Electronic Communications Directive 2002/58 (including any replacing or superseding legislation);
“GDPR” means the EU General Data Protection Regulation 2016/679.
“Group Company” means any holding company or subsidiary of a party or any of its holding companies. A company is a “subsidiary” of another company, its “holding company”, if that other company (i) holds a majority of the voting rights in it, or (ii) is a member of it and has the right to appoint or remove a majority of its board of directors, (iii) or is a member of it and controls alone, pursuant to an agreement with other members, a majority of the voting rights in it. For the avoidance of doubt, reference to Shopthru in these Terms & Conditions shall include reference to its Group Companies;
“Intellectual Property Rights (IPR)” means all copyright and related rights, patents rights to inventions, utility models trade marks, service marks, trade, business, and domain names, rights in trade dress or get-up, rights in goodwill or to sue for passing off, unfair competition rights, rights in designs, rights in computer software, database rights (including any database rights in the Shopthru Network), topography rights, moral rights, rights in confidential information (including know-how and trade secrets) and any other intellectual property rights, in each case whether registered or unregistered and including all applications for and renewals or extensions of such rights, and all similar or equivalent rights or forms of protection in any part of the world;
“Interface” means the intranet and software platform provided by Shopthru and any functionality accessed or made available through such platform;
“Product” means a product, service or equivalent offered for sale by the Advertiser on any Advertiser URL.
“Publisher” means (i) the operator of a website, application or service, which has joined the Shopthru Network to to promote Advertisers or their Products using Shopthru-hosted storefronts and tools
“Publisher Website” means a website, application or service operated by a Publisher to market Advertisers or their Product.
“Sub-publisher” means the operator of a website, application or service, which has agreed with the Publisher Network to market Advertisers or their Product.
“Term” means the term of this Agreement from the Effective Date until its termination or expiry in accordance with these Terms & Conditions.
SCHEDULE B – DATA PROCESSING ADDENDUM (DPA)
This Data Processing Addendum (“DPA”) forms part of the Shopthru Publisher Terms & Conditions (“Agreement”) between Shopthru Ltd and the Publisher. By accepting the Agreement, the Publisher also agrees to the terms of this DPA.
1. Definitions
1.1 “Personal Data,” “Processing,” “Controller,” and “Processor” have the meanings set out in the UK General Data Protection Regulation (UK GDPR).
1.2 “Data Protection Laws” means all applicable laws and regulations relating to the processing of Personal Data, including the UK GDPR and Data Protection Act 2018.
2. Roles and Scope
2.1 Shopthru acts as an independent Controller of any Personal Data it collects in relation to Publisher accounts or platform usage.
2.2 This DPA does not apply to end-customer data, as Shopthru does not process such data on behalf of the Publisher.
3. Purpose of Processing
Shopthru may process Publisher-related Personal Data for the following purposes:
- Setting up and managing accounts
- Enabling access to the Shopthru platform
- Tracking transactions and calculating Commissions
- Monitoring platform usage and preventing fraud
- Meeting legal and regulatory obligations
4. Data Security
Shopthru shall implement appropriate technical and organisational measures to protect Personal Data against unauthorised access, loss, or damage.
5. Data Subject Rights
Shopthru will comply with its obligations under applicable Data Protection Laws in respect of data subject access requests or similar rights.
6. International Transfers
Any transfers of Personal Data outside the UK or EEA shall only be made:
- To countries with an adequacy decision; or
- With appropriate safeguards in place (e.g. Standard Contractual Clauses).
7. Retention and Deletion
Personal Data will be retained only for as long as necessary to fulfil the above purposes or as required by law.
8. Governing Law
This DPA is governed by and construed in accordance with the laws of England and Wales.