Privacy Policy

Last updated: 30 September 2026

This privacy policy explains how 1357s Private Ltd, trading as 31digits (“31digits”, “we”, “us” or “our”), collects, uses, discloses and protects personal data when you visit 31digits.com, contact us, or use our affiliate network as a publisher or advertiser.

We are a company registered in Singapore (UEN 202549984D), with our registered office at 20 Collyer Quay, #09-01, Singapore 049319. We handle personal data in line with Singapore’s Personal Data Protection Act 2012 (“PDPA”). Where the UK GDPR or EU GDPR applies to our processing, for example because you are located in the UK or the European Economic Area, we also follow those laws.

1. The personal data we collect

We collect personal data in the following ways:

• When you visit our website: technical and usage information such as your IP address, browser type, device type, pages viewed, referring website and the date and time of your visit. We collect this through Google Analytics and our hosting provider’s server logs.
• When you contact us: your name, email address, company name and anything else you choose to include in your message.
• When you register as a publisher or advertiser: your name, company details, email address, phone number, website and traffic information, and the payment and tax details we need to pay or invoice you.
• When you run or promote campaigns: campaign performance data, such as clicks, impressions, leads, sales and conversions, recorded by our tracking platform.

Our tracking platform may also record limited technical data about consumers who click on tracked links, such as IP address, device and browser information, and a click or transaction identifier. We use this data only to attribute conversions correctly, prevent fraud and calculate commissions.

2. How we use your personal data

We use personal data to:

• operate, maintain and improve our website and affiliate network;
• review and manage publisher and advertiser applications and accounts;
• track campaign performance, attribute conversions and calculate commissions;
• make payments to publishers and invoice advertisers;
• detect, investigate and prevent fraud, invalid traffic and misuse of our services;
• respond to enquiries and provide account support;
• send service messages about your account, campaigns or payments;
• comply with our legal, regulatory, tax and accounting obligations.

Where the UK or EU GDPR applies, we rely on the following legal bases: performance of a contract with you, our legitimate interests in running and securing our business, compliance with legal obligations, and, where required, your consent.

We do not sell your personal data.

3. Cookies and analytics

Our website uses cookies and similar technologies. We use Google Analytics, provided by Google, to understand how visitors use the site so that we can improve it. Google Analytics sets cookies that collect information such as the pages you visit and how long you stay. You can learn more in Google’s explanation of how it uses data from partner sites.

Our tracking platform also uses cookies and similar identifiers on tracked links, so that we can attribute clicks and conversions to the correct publisher.

You can block or delete cookies at any time through your browser settings. You can also opt out of Google Analytics by installing the Google Analytics opt-out browser add-on. However, if you block cookies, some parts of the website may not work as intended.

4. Who we share your personal data with

We share personal data only where necessary, with:

• Service providers who help us run our business, including our website hosting provider, our affiliate tracking platform provider (Offer18), Google (for analytics), and email, payment and accounting providers. These providers may only use your data to provide services to us.
• Advertisers and publishers on our network, where this is needed to run, report on and reconcile campaigns, for example sharing aggregated performance data or information needed to validate conversions.
• Professional advisers, such as lawyers, accountants and auditors.
• Authorities, where the law requires us to, or where we need to protect our rights, our users or the public.
• A buyer or successor of all or part of our business, if we sell or reorganise it.

5. International transfers

Our service providers may store or process personal data outside Singapore, including in the United Kingdom, the European Union and the United States. When we transfer personal data overseas, we take steps to make sure it receives a standard of protection comparable to that required under the PDPA and, where applicable, the UK or EU GDPR. For example, we rely on contractual safeguards with our providers.

6. How long we keep personal data

We keep personal data only for as long as we need it for the purposes described in this policy, including to meet legal, tax and accounting requirements. For example, we generally keep account, campaign and payment records for as long as your account is active and for a reasonable period afterwards to deal with any disputes, audits or legal obligations. When we no longer need personal data, we delete or anonymise it.

7. How we protect personal data

We use reasonable security arrangements to protect personal data against unauthorised access, collection, use, disclosure, copying, modification or disposal. These include encrypted connections to our website, access controls and working with reputable service providers. However, no method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8. Your rights

Under the PDPA, you can ask to access the personal data we hold about you, ask how we have used or disclosed it in the past year, and ask us to correct it. You can also withdraw your consent to our collection, use or disclosure of your personal data. If you withdraw consent, we may no longer be able to provide some services to you, and we will explain any consequences before acting on your request.

If the UK or EU GDPR applies to you, you also have the right to request erasure of your data, restrict or object to our processing, and receive your data in a portable format. In addition, you can complain to your local data protection authority.

To exercise any of these rights, email us at support@31digits.com. We may need to verify your identity before we respond, and we will reply within the time required by applicable law.

9. Marketing messages

If you are a publisher or advertiser, we may send you updates about new offers, campaigns and services that relate to your account. You can opt out at any time by using the unsubscribe link in our emails or by contacting us.

10. Third-party websites

Our website and emails may link to third-party websites, including advertiser websites and our tracking platform. We are not responsible for the privacy practices of those websites, so we recommend that you read their privacy policies.

11. Children

Our services are for businesses and are not directed at children. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, please contact us and we will delete it.

12. Changes to this policy

We may update this privacy policy from time to time. When we do, we will change the “Last updated” date at the top of this page. If we make significant changes, we may also notify registered publishers and advertisers by email.

13. Contact us

If you have any questions about this privacy policy or how we handle personal data, or if you want to contact our Data Protection Officer, please email support@31digits.com or write to: Data Protection Officer, 1357s Private Ltd, 20 Collyer Quay, #09-01, Singapore 049319.