⚠ Starter template — not legal advice. Have counsel review before publishing; the sale/sharing and CCPA sections are material to your lead-selling model. Replace every [bracketed] value, then delete this note.

Privacy Policy

Effective date: [DATE] · Last updated: [DATE]

This Privacy Policy explains how [COMPANY LEGAL NAME] ("Portune," "we," "us") collects, uses, and shares personal information in connection with the Portune publisher program, our website, and our embeddable Power-Ups (Product Selection Guides and RFQ Builders). It applies to publishers who join our program and to end users who interact with a Power-Up embedded on a publisher's website.

1. Information we collect

From publishers

Account and contact details: name, work email, company, website URL(s).
Payment/payout details required to pay your revenue share [e.g., via your payments provider].
Usage of your dashboard and support communications.

From end users (via a Power-Up on a publisher's site)

Requirements and selections the user provides while using a guide or RFQ builder (e.g., product category, use case, quantities, constraints).
Contact details the user submits to receive a quote or be matched (e.g., name, business email, company).
Technical/usage data: device type, browser, IP address, and interaction events, collected via cookies and similar technologies.

2. How we use information

To provide the Power-Ups and generate technically qualified leads (TQLs).
To match and sell TQLs to relevant advertisers/vendors, and to pay publishers their revenue share.
To operate, secure, analyze, and improve our services.
To communicate with publishers and, where permitted, end users.
To comply with law and enforce our terms.

3. How we share and "sell/share" information

Core to our service: when an end user completes a Power-Up and becomes a TQL, we share their submitted requirements and contact details with the relevant advertiser(s)/vendor(s) so they can respond. Under laws such as the California Consumer Privacy Act (CCPA/CPRA), this transfer may be considered a "sale" or "sharing" of personal information.

We may also share information with: service providers (hosting, analytics, payments) acting on our behalf; publishers (aggregated conversion data about their own traffic); and authorities where required by law or to protect rights and safety.

4. Your privacy choices (Do Not Sell or Share)

Depending on where you live, you may have the right to opt out of the "sale" or "sharing" of your personal information and targeted advertising. To exercise this right:

Use our [Do Not Sell or Share request form / link], or email privacy@portune.io.
We honor Global Privacy Control (GPC) browser signals where required. [Confirm GPC handling]

5. Your rights

Subject to applicable law (including CCPA/CPRA, and GDPR/UK GDPR where relevant), you may have the right to access, correct, delete, or port your personal information, to opt out of sale/sharing, and to non-discrimination for exercising these rights. To make a request, contact privacy@portune.io. We will verify your request as required by law.

[If you have EU/UK users: identify your legal bases, EU/UK representative, and international-transfer mechanism (e.g., SCCs).]

6. Cookies & tracking

We and our providers use cookies and similar technologies to operate the Power-Ups, remember preferences, measure performance, and (where applicable) support advertising. You can control cookies through your browser and, where offered, our consent banner. [Link/describe your cookie settings tool.]

7. Retention & security

We retain personal information as long as needed for the purposes above and to meet legal obligations, then delete or de-identify it. We use reasonable administrative, technical, and physical safeguards; no method is 100% secure.

8. Children

Our services are intended for businesses and are not directed to children under [16]. We do not knowingly collect their personal information.

9. Changes & contact

We may update this policy; we will post the new effective date here. Questions or requests: privacy@portune.io, [COMPANY LEGAL NAME, MAILING ADDRESS].