This Partner Privacy Policy describes how Paulius Glavickas, trading as Right Hook ("Right Hook", "we", "us", "our"), Individual Activity Certificate No. 841455, Republic of Lithuania, collects, uses, stores, and protects personal data in connection with the Right Hook Partner Program (the "Program"), accessible via the partner section of righthook.ad.
This policy applies specifically to individuals who apply for, participate in, or interact with the Program. It is separate from the Privacy Policy applicable to Right Hook's general website visitors and service clients.
We process partner data in accordance with the EU General Data Protection Regulation (GDPR) and the law of the Republic of Lithuania on the legal protection of personal data.
Questions? Contact us at admin@righthook.ad.
Paulius Glavickas
Individual Activity Certificate No. 841455
Republic of Lithuania
admin@righthook.ad
We collect only the personal data necessary to operate the Partner Program effectively and lawfully.
When you apply to join the Program, we collect information you provide through the sign-up form. This may include your first and last name, email address, website or social media profile URL, niche or industry focus, and an estimate of your monthly referral capacity. We use this to assess your application and, if accepted, to set up your partner account.
Legal basis: Pre-contractual steps at your request; contract performance (Partner Terms & Conditions).
Once accepted into the Program, we generate a unique affiliate link for you. We collect data on how that link is used — including the number of clicks, referral conversions (i.e. when a referred prospect signs a contract with us), and the date and source of referrals. This tracking is used solely to calculate your earned commissions and monitor program performance.
Legal basis: Contract performance; legitimate interests in accurately calculating and paying commissions.
To process your commission payments, we collect the payout details you provide through the Partner Portal's Payout Settings. Depending on your chosen payment method, this may include:
This data is used solely to send you earned commissions. We do not use it for any other purpose. You are solely responsible for the accuracy of the payout details you provide. Right Hook cannot be held liable for failed or misdirected payments resulting from incorrect information.
We also retain records of commissions earned, payments made, and payout history, as required by Lithuanian accounting and tax legislation (up to 10 years).
Legal basis: Contract performance; legal obligation (financial record-keeping).
Your Partner Portal displays a "Recent Leads" table which may contain the name, email address, referral type, status, and attribution expiry date of individuals or businesses you have referred. This data is generated when a prospect clicks your affiliate link and interacts with the Right Hook site. It is displayed in your portal solely so you can monitor the status of your referrals.
The personal data of referred leads (name, email) is collected by Right Hook directly from those individuals when they enquire or apply. We process that data under our main site Privacy Policy. As a partner, you have visibility of this data within your portal but are not permitted to use it for any purpose other than monitoring your own referral status. You must not copy, export, or otherwise use referred lead data for independent marketing, solicitation, or any other purpose.
Legal basis: Contract performance; legitimate interests in providing partners with referral attribution information.
We may retain records of email and other communications between you and Right Hook relating to the Program, including commission queries, tier updates, and program notices.
Legal basis: Legitimate interests in managing the partner relationship and resolving disputes.
Standard server log data (IP address, browser type, device, pages visited, timestamps) may be collected automatically by our hosting infrastructure when you access the partner section of the Site. This is not used to identify you individually and is retained only as long as necessary for security and operational purposes.
Legal basis: Legitimate interests in maintaining Site security and performance.
We use partner personal data solely for the following purposes:
We will never sell, rent, or share your personal data with third parties for their own marketing or commercial purposes.
Partner application and account data is stored in Notion (Notion Labs, Inc., USA), which we use as our internal database for partner and client relationship management. Notion operates under GDPR-compliant data processing terms.
Payment information and commission records are retained in accordance with Lithuanian legal requirements for financial record-keeping, which may require retention for up to 10 years following the end of the financial year to which the records relate.
Non-financial partner data (application data, communications) is retained for the duration of your participation in the Program and for a period of 3 years thereafter, unless a longer period is required for legal or dispute resolution purposes.
We use a limited number of third-party services that may handle your personal data as part of operating the Program:
We do not use third-party advertising networks, retargeting tools, or data brokers in connection with the Program.
Your unique affiliate link uses tracking technology to attribute referrals to your account. When a prospect clicks your link, a tracking identifier is stored in their browser for a period of 90 days. If that prospect becomes a client of Right Hook within that window, the referral is attributed to you and the relevant commission is calculated.
The tracking data collected relates to your performance as a partner — it is not used to profile or target the referred prospects for any purpose other than attributing the referral.
Right Hook's tracking records are the authoritative source of truth for attribution and commission calculations. In the event of a dispute, our records shall be the primary reference.
As a data subject under the GDPR, you have the following rights. To exercise any of them, contact us at admin@righthook.ad. We will respond within one month.
Please note that exercising certain rights — particularly erasure or restriction — may require termination of your participation in the Program, as we cannot operate the Program or pay commissions without maintaining the relevant data. We reserve the right to verify your identity before responding to any request.
You also have the right to lodge a complaint with the Lithuanian supervisory authority:
State Data Protection Inspectorate (VDAI)
L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania
vdai.lrv.lt
The Partner Program is open only to individuals aged 18 or over. We do not knowingly collect data from anyone under the age of 18. If you believe a minor has submitted data through the Program sign-up, please contact us immediately at admin@righthook.ad.
We may update this Partner Privacy Policy from time to time. Material changes will be communicated to active partners by email. The "Last updated" date at the top of this page will reflect the most recent revision. Continued participation in the Program following notification of changes constitutes your acceptance of the updated policy.
For any privacy-related questions or to exercise your rights:
Paulius Glavickas
Individual Activity Certificate No. 841455
admin@righthook.ad
righthook.ad