Liquid Luck is a Myth

Privacy Policy

Effective Date: 30 September 2026
Last Updated: 30 September 2026

1. Introduction and Who We Are

This Privacy Policy explains how Elixify Ltd ("we", "us", "our", or the "Company") collects, uses, stores, and protects personal data when you visit our website at elixify.co.uk, engage our bespoke web design and advertising services, participate in our affiliate network, or interact with our digital marketing and lead generation assets.

Elixify Ltd is a company registered in England and Wales under Company Registration Number 17463769.

Our registered office is:
6b, The Barns, Caddsdown Industrial Park, Bideford, Devon, EX39 3BT, United Kingdom.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Elixify Ltd acts as a Data Controller in relation to our clients, website visitors, publisher/affiliate partners, and direct business contacts. Where we capture, route, or process leads specifically on behalf of advertiser clients or through our affiliate tracking architecture, we may act as a Data Processor or Joint Controller depending on the specific commercial engagement.

If you have questions regarding this policy or our data practices, contact us:

• Data Inquiries & Sales: sales@elixify.co.uk
• Accounts & Finance: finance@elixify.co.uk
• Telephone: 01237 722055 (International: +44 1237 722055)

2. Scope of this Policy

This Privacy Policy applies to personal data collected across all Elixify Ltd operational touchpoints, including:

• Visitors to our website (elixify.co.uk) and related landing pages.
• Prospective and existing clients utilizing our bespoke development, lead generation, and advertising solutions.
• Affiliates, publishers, and media buyers applying for or registered within our affiliate network.
• Advertisers and merchant partners integrating their conversion tracking with our network.
• End users and consumers who interact with affiliate referral links, promotional campaigns, or lead capture funnels operated or tracked by Elixify Ltd.

3. The Personal Data We Collect

A. Information Provided Directly to Us

• Contact & Commercial Information: Full name, business name, company registration details, email address, telephone number, job title, and physical address provided via our contact forms, quote builder, or email communications.
• Affiliate & Publisher Registration Data: Identity and business credentials, tax identification numbers, company registration details, website/traffic source URLs, promotion methods, and banking details (for commission settlement).
• Advertiser & Client Account Data: Contractual records, billing addresses, invoicing records, and corporate banking details processed via our payment and banking partners (including Tide).
• Lead Generation Data: Personal information submitted by end users through our landing pages and client-directed funnels (e.g., name, contact details, service requirements, budget ranges, and qualifying responses).

B. Affiliate Network & Tracking Data (Automated)

When an end user clicks an affiliate link, views an ad creative, or triggers an acquisition event within our affiliate network, our tracking architecture automatically captures:

• Attribution & Click Identifiers: Unique Click IDs, Transaction IDs, SubIDs, Campaign IDs, and affiliate/publisher partner identifiers.
• Technical & Device Telemetry: IP address (often truncated or pseudonymised for attribution), browser type and version, operating system, device fingerprint/type, language settings, and referring URL.
• Conversion & Event Data: Timestamps of clicks, page impressions, conversion status (e.g., lead submission, checkout confirmation), transaction values, and currency.

C. Website & Analytics Data

Standard server logs, HTTP request headers, time spent on pages, scroll depth, and interaction data captured via essential and analytical cookies.

4. Lawful Bases for Processing Under UK GDPR

We only process personal data where we have a lawful basis under Article 6 of the UK GDPR:

• Contractual Necessity (Art. 6(1)(b)): To perform our obligations under our Terms of Service, client agreements, or Affiliate Network Agreements (e.g., tracking clicks, calculating and remitting commission payments, delivering web application projects).
• Legitimate Interests (Art. 6(1)(f)): To run and secure our affiliate tracking architecture, monitor traffic quality, detect click fraud and bot activity, optimize ad campaigns, manage business relationships, and improve our services, provided these interests do not override your fundamental rights.
• Consent (Art. 6(1)(a)): Where you have provided clear, affirmative consent (e.g., subscribing to direct marketing communications, opting into non-essential tracking cookies via our consent banner, or submitting quote request forms).
• Legal Obligation (Art. 6(1)(c)): To comply with statutory requirements under the Companies Act 2006, tax obligations under HMRC rules (e.g., maintaining financial and payout records for a minimum of 6 years), and responding to lawful regulatory requests.

5. Specific Provisions: Operating an Affiliate Network

Elixify Ltd operates a proprietary or managed performance affiliate network connecting advertisers (merchants) with publishers (affiliates). Operating this infrastructure requires precise data processing:

A. Attribution, Tracking, and Cookies

Our affiliate tracking relies on tracking tokens, conversion pixels, postback URLs (server-to-server / S2S tracking), and first-party/third-party cookies. When a consumer clicks a publisher link:

1. A unique, pseudonymised tracking token (Click ID) is generated.
2. The user is redirected to the advertiser’s landing page.
3. If the user completes a qualified event (such as a purchase or lead submission), a postback or pixel notifies our network using the Click ID.

This data is used strictly to validate the referral, prevent duplicate entries, and calculate performance compensation for the referring affiliate.

B. Anti-Fraud and Network Integrity

To protect our advertisers and network from commercial fraud, we process technical telemetry (including IP addresses, geolocation estimates, and browser user-agents) using automated algorithms. This identifies:

• Artificial click inflation, click farms, and automated bots.
• Geo-mismatching (traffic originating outside targeted campaign zones).
• Cookie stuffing, malicious redirects, or non-compliant traffic sources.

C. Publisher Compliance & Due Diligence

All publishers joined to the Elixify Ltd network must warrant that they obtain all legally required consents (under the Privacy and Electronic Communications Regulations / PECR) before placing tracking cookies on consumer devices or running email/SMS marketing campaigns. We reserve the right to audit publisher compliance and terminate non-compliant partners.

6. How We Share and Disclose Personal Data

We never sell personal data. We disclose personal data only to the following recipients for legitimate business, contractual, and regulatory purposes:

• Advertisers & Clients: When leads are generated through our conversion funnels, relevant prospect data is transmitted securely to the designated client via secure API, webhook, or encrypted CRM integration.
• Affiliate Publishers: Publishers receive aggregate reporting, conversion timestamps, SubIDs, and payout statements. We do not provide publishers with consumers’ full names, addresses, or payment card details.
• Banking & Payment Processors: Payout and transaction data shared with commercial banking platforms (including Tide) and financial compliance processors to execute vendor payments and affiliate disbursements.
• Infrastructure & SaaS Sub-Processors: Cloud hosting providers (e.g., AWS, Vercel), email service providers, database hosts, fraud monitoring vendors, and customer relationship management (CRM) software.
• Professional Advisers & Legal Bodies: External accountants, legal counsel, auditors, and law enforcement or regulatory authorities (such as HMRC, the ICO, or the National Crime Agency) where required by law.

7. International Data Transfers

Where our servers, service providers, or client platforms are located outside the United Kingdom, we ensure that appropriate safeguards are in place before personal data is transferred internationally. This includes:

• Transferring data to countries deemed by the UK Government to provide an adequate level of data protection.
• Utilizing the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses (SCCs), accompanied by transfer risk assessments where required.

8. Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, satisfy commercial contracts, and comply with UK statutory obligations:

9. Data Security

Elixify Ltd enforces technical and organizational measures to safeguard personal data against unauthorized access, loss, alteration, or disclosure:

• HTTPS / TLS 1.3 encryption across all domains and tracking redirects.
• End-to-end encryption for API postbacks and credential transfers.
• Role-based access controls (RBAC) ensuring only authorized personnel have access to sensitive commercial and publisher banking data.
• Routine security reviews, secure coding standards in Next.js/React development, and vulnerability scanning.

10. Your Rights Under UK GDPR

Under the UK Data Protection Act 2018 and UK GDPR, you have the following enforceable rights:

• Right of Access (Subject Access Request): Request a copy of the personal data we hold about you.
• Right to Rectification: Request the correction of inaccurate or incomplete personal information.
• Right to Erasure ("Right to be Forgotten"): Request the deletion of your personal data where there is no compelling legal reason for its continued processing.
• Right to Restrict Processing: Request the suspension of processing under specific circumstances (e.g., while data accuracy is contested).
• Right to Data Portability: Request the transfer of your structured personal data to yourself or a third party in a machine-readable format.
• Right to Object: Object to our processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these statutory rights, please submit a written request to sales@elixify.co.uk or call our office on 01237 722055. We will respond within one calendar month.

11. Cookies and Tracking Technologies

Our website and tracking systems utilize cookies, local storage, and server tokens to ensure site stability, remember preferences, measure analytics, and record affiliate attributions.

• Strictly Necessary Cookies: Essential for the operation of the site, authentication, and security.
• Analytical / Performance Cookies: Measure traffic metrics and page responsiveness.
• Affiliate Attribution Identifiers: Store anonymized click identifiers to verify traffic provenance and calculate publisher compensation.

Visitors can manage non-essential cookie preferences at any time through our on-site cookie banner or by modifying browser settings. Note that disabling tracking cookies may affect the tracking accuracy of our affiliate referral links.

12. Regulatory Authority and Complaints

If you have concerns about our data handling, we ask that you contact us first so we can resolve the matter directly:

• Email: sales@elixify.co.uk
• Postal Address: Elixify Ltd, 6b, The Barns, Caddsdown Industrial Park, Bideford, Devon, EX39 3BT, United Kingdom

You also have the right to lodge a complaint directly with the UK supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: https://ico.org.uk
Helpline: 0303 123 1113

13. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect operational, technological, or legal developments (such as additions to our affiliate tracking architecture). Any updates will be published directly to elixify.co.uk/privacy-policy with a revised "Last Updated" timestamp. Significant changes will be communicated to registered clients and publishers directly via email.