Privacy Policy

Introduction

CW Affiliate Investments, LLC ("Company," "we," "us," or "our") is a Wisconsin-based software company that builds and operates SaaS products, digital tools, educational courses, and automated content publishing services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at cwaffiliateinvestments.com, use any of our products or services, or interact with our social media publishing tools.

Our product portfolio includes MemStack, ConnectStack, ShieldStack, ImageStack, AlgoStack, EpsteinScan, CW Social Publisher, and other SaaS and digital products. By using our services, you agree to the collection and use of information in accordance with this policy.

Information We Collect

Account & Contact Information

When you create an account, purchase a product, or contact us, we may collect:

• Name and email address
• Billing information (processed securely through third-party payment processors)
• Communication preferences
• Any information you voluntarily provide via contact forms or support requests

Social Media Platform Data (CW Social Publisher)

CW Social Publisher is our automated content publishing tool that posts content to TikTok and other social media platforms on behalf of authorized brand accounts. When you connect a social media account through our publishing tool, we collect and process the following data through OAuth authorization:

• TikTok account information: username, display name, and avatar (profile picture) — obtained through TikTok's OAuth 2.0 authorization flow
• OAuth access tokens and refresh tokens — used solely to publish content on your behalf
• Content you submit for publishing: videos, captions, hashtags, and scheduling preferences
• Publishing status and delivery confirmations from the platform APIs

Usage & Technical Data

We automatically collect certain technical information when you use our services:

• Browser type, device type, and operating system
• IP address and approximate geographic location
• Pages visited, features used, and interaction patterns
• Referral source and session duration

Information We Do NOT Collect

We want to be transparent about the boundaries of our data collection. We do not collect:

• Social media passwords — we use OAuth tokens exclusively and never have access to your password
• Private or direct messages from any social media platform
• Your browsing history outside of our own services
• Contact lists, friends lists, or follower lists from connected social accounts
• Financial information from social media accounts
• Content posted by others on your social media accounts

How We Use Your Information

We use the information we collect for the following purposes:

• Providing and maintaining our SaaS products, digital tools, and courses
• Publishing content to TikTok and other social media platforms on your behalf via CW Social Publisher
• Processing transactions and sending purchase confirmations
• Communicating with you about your account, products, and support requests
• Improving our services based on usage patterns and feedback
• Complying with legal obligations and enforcing our terms

TikTok Data & Third-Party Platform Usage

When you authorize CW Social Publisher to connect to your TikTok account, we access your account through TikTok's official API using OAuth 2.0. This means:

• You explicitly grant permission through TikTok's authorization screen before we access any data
• We only request the minimum permissions (scopes) necessary to publish content on your behalf
• Access tokens are stored securely and encrypted at rest
• We do not share your TikTok data with any third parties
• We do not use your TikTok data for advertising, profiling, or any purpose other than content publishing

Our use of TikTok data is governed by TikTok's API Terms of Service and their Privacy Policy.

Revoking Social Media Access

You can revoke CW Social Publisher's access to your social media accounts at any time:

• TikTok: Go to your TikTok account Settings → Security → Manage app permissions → Remove CW Social Publisher
• You may also contact us at cwaffiliateinvestments@gmail.com to request disconnection
• Upon revocation, we will stop publishing to your account and delete stored access tokens within 30 days
• Content previously published to your account will remain on the platform unless you remove it directly

We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We do not sell your TikTok data or any social media account data. Period.

Data Sharing & Third-Party Services

We may share limited information with third-party service providers who assist in operating our business. These providers are contractually obligated to protect your data and use it only for the purposes we specify:

• Payment Processors: Stripe and similar providers for secure transaction processing
• Cloud Hosting: Infrastructure providers (e.g., Netlify, Railway, Supabase) for service delivery
• Analytics: Anonymized usage data to improve our products
• Social Media APIs: TikTok and other platform APIs to publish your content as authorized

Data Retention

We retain your personal information only for as long as necessary to provide our services and fulfill the purposes described in this policy:

• Account data: Retained while your account is active and for up to 90 days after deletion
• OAuth tokens: Deleted within 30 days of access revocation or account disconnection
• Published content metadata: Retained for service records and may be deleted upon request
• Transaction records: Retained as required by applicable tax and financial regulations
• Usage analytics: Aggregated and anonymized data may be retained indefinitely

Data Security

We implement industry-standard security measures to protect your information, including encryption in transit (TLS/SSL) and at rest, secure OAuth token storage, regular security assessments, and access controls limiting data access to authorized personnel only. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

Your Rights (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR):

• Right of Access — request a copy of the personal data we hold about you
• Right to Rectification — request correction of inaccurate data
• Right to Erasure — request deletion of your data ("right to be forgotten")
• Right to Restrict Processing — request limitation of how we use your data
• Right to Data Portability — receive your data in a structured, machine-readable format
• Right to Object — object to processing based on legitimate interests
• Right to Withdraw Consent — withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at cwaffiliateinvestments@gmail.com. We will respond within 30 days.

Your Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know — request disclosure of what personal information we collect, use, and share
• Right to Delete — request deletion of your personal information
• Right to Opt-Out — opt out of the sale of personal information (we do not sell your data)
• Right to Non-Discrimination — we will not discriminate against you for exercising your rights

To exercise these rights, email us at cwaffiliateinvestments@gmail.com with the subject line "CCPA Request."

Cookies & Tracking

Our website may use cookies and similar tracking technologies to improve your experience. You can control cookie preferences through your browser settings. Note that disabling cookies may affect the functionality of certain features. We do not use cookies to track your activity across third-party websites.

Children's Privacy

Our services are not directed to individuals under the age of 13 (or 16 in the EEA). We do not knowingly collect personal information from children. If we become aware that we have collected data from a child without parental consent, we will take steps to delete that information promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of this page. For material changes affecting how we handle social media data, we will notify affected users via email. We encourage you to review this policy periodically.

Contact Us

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your data rights, please contact us: