LEGAL

Legal Policies

Privacy Policy

Last Updated: 31/08/2026

1. Introduction

This Privacy Policy explains how Sales Machine / Online Blue Hawk (“Sales Machine,” “we,” “us,” or “our”) handles information in connection with our website, digital marketing services, performance marketing activities, technology, and business operations.

Sales Machine operates primarily as an intermediary between advertisers and clients, technology providers, and selected media partners.

We generally do not maintain, own, or independently monetize consumer databases obtained through our clients or media partners for our own unrelated commercial purposes.

Depending on the specific activity, information involved, and contractual arrangement, Sales Machine may act as a controller, processor, service provider, contractor, or other legally recognized intermediary. Our obligations therefore depend on the nature of the relevant processing activity and the role assigned to us under applicable law.

We are committed to handling information responsibly and complying with applicable privacy and data protection laws, including the GDPR and applicable California privacy laws where relevant.

2. Information We May Handle

Depending on the circumstances, Sales Machine may receive, access, transmit, or otherwise handle limited information necessary to provide and administer its services.

This may include:

We seek to limit the information we handle to what is reasonably necessary for the relevant purpose.

3. Our Intermediary Role

Where information relating to consumers or end users is provided or made available by a client, advertiser, media partner, or other third party for the purpose of enabling, measuring, attributing, or administering a campaign, Sales Machine generally handles such information only to the extent reasonably necessary to perform its intermediary, technology, analytics, attribution, verification, fraud-prevention, or related contractual functions.

Sales Machine does not generally determine the purposes for which a client or advertiser collects or independently uses consumer information.

Where Sales Machine processes personal data solely on behalf of a client or other controller, such processing is governed by the applicable contractual arrangements, documented instructions, and applicable law.

4. No Independent Consumer Data Monetization

Sales Machine does not generally acquire, maintain, sell, or independently monetize consumer information received through clients or media partners for unrelated commercial purposes.

Where information is provided or made available to Sales Machine solely for the performance of a specific service or campaign, Sales Machine seeks to use such information only for the purposes reasonably necessary to provide that service and as otherwise permitted or required by applicable law.

Nothing in this section prevents Sales Machine from retaining limited information where such retention is reasonably necessary for security, fraud prevention, legal compliance, accounting, dispute resolution, enforcement of contractual rights, or other purposes permitted by applicable law.

5. Purposes of Use

Depending on our role and the applicable circumstances, information may be handled for purposes including:

6. Legal Bases Where GDPR Applies

Where the GDPR applies and Sales Machine acts as a controller, we process personal data on an appropriate legal basis.

Depending on the circumstances, this may include performance of a contract, compliance with a legal obligation, our legitimate interests, or consent where consent is required.

Where Sales Machine acts as a processor, we process personal data on behalf of the relevant controller in accordance with applicable contractual instructions and applicable law.

7. Third-Party Technology Providers

Sales Machine may use or engage technology and service providers for hosting, analytics, tracking, attribution, security, verification, fraud prevention, communications, measurement, and other technical or operational functions.

Depending on the circumstances, these providers may act as processors, service providers, contractors, independent controllers, or other legally recognized third parties.

Where required, appropriate contractual, confidentiality, security, and data protection safeguards are implemented in accordance with applicable law.

8. Clients and Media Partners

Sales Machine may facilitate the exchange of limited information between clients, advertisers, technology providers, and selected media partners for purposes such as campaign execution, attribution, conversion measurement, traffic validation, reporting, and fraud prevention.

Each party remains responsible for the processing activities that fall within its own role, control, contractual obligations, and applicable law.

Further information concerning our role and reasonable controls in relation to media partners is provided in our Media Partner Responsibility notice.

9. Retention

Sales Machine does not generally retain consumer or campaign information for longer than reasonably necessary for the specific purpose for which it is handled.

Where Sales Machine processes information on behalf of a client or other controller, retention may be determined by the client's documented instructions, contractual requirements, applicable legal obligations, or the relevant technology and service configuration.

Sales Machine may retain limited information where reasonably necessary for legal, regulatory, security, fraud-prevention, dispute-resolution, accounting, audit, or contractual purposes.

10. International Transfers

Where personal data is transferred internationally, Sales Machine implements appropriate safeguards where required by applicable law.

Such safeguards may include adequacy decisions, contractual safeguards, or other legally recognized transfer mechanisms.

11. Security

Sales Machine implements reasonable technical and organizational measures appropriate to the nature and risks of the information it handles.

These measures are designed to protect information against unauthorized access, disclosure, alteration, loss, destruction, or other unauthorized processing.

No electronic system, transmission, or storage method can be guaranteed to be completely secure.

12. Privacy Rights

Depending on applicable law and Sales Machine's role in relation to the relevant information, individuals may have rights concerning their personal data or personal information, including rights of access, correction, deletion, restriction, objection, portability, withdrawal of consent, and applicable rights to opt out of certain processing activities.

Where Sales Machine processes information on behalf of a client or other controller, privacy requests may need to be directed to the relevant controller. Where appropriate, Sales Machine will provide reasonable assistance in accordance with applicable law and its contractual obligations.

Sales Machine may take reasonable steps to verify requests where permitted or required by applicable law.

13. California Privacy

Where the CCPA/CPRA applies, California residents may have applicable rights concerning their personal information.

Sales Machine's obligations may differ depending on whether it acts as a business, service provider, contractor, or other legally recognized recipient.

Where Sales Machine acts as a service provider or contractor, it handles personal information in accordance with applicable contractual requirements and applicable law and does not use such information for purposes prohibited to service providers or contractors under applicable law.

Where Sales Machine acts as a business or in another capacity subject to independent obligations under California law, those obligations apply to the relevant processing activities.

Additional information is provided in our California Privacy notice.

14. Children's Privacy

Our website and services are not directed to children where prohibited by applicable law.

We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, technology, services, legal requirements, or privacy practices.

The updated version will be published on our website with its applicable update date.

16. Contact

For privacy-related questions or requests, please contact:

Sales Machine / Online Blue Hawk — help@sales-machine.ai

Where required by applicable law, additional privacy contact or representative information will be provided.

Cookie Policy

Last Updated: 31/08/2026

1. What Are Cookies and Similar Technologies?

Cookies are small text files or similar technologies that may be stored on or accessed from a user's device when visiting a website.

Sales Machine may also use related technologies, including pixels, tags, local storage, device identifiers, server-side technologies, affiliate tracking technologies, and similar mechanisms.

2. How We Use These Technologies

Depending on the technology and applicable law, cookies and similar technologies may be used for:

3. Strictly Necessary Technologies

Certain technologies may be necessary to operate, secure, or provide requested functionality on our website.

Where permitted by applicable law, such technologies may be used without consent.

4. Analytics, Attribution and Measurement

Sales Machine may use analytics and measurement technologies to understand website usage, traffic patterns, engagement, campaign performance, conversions, attribution, and other statistical indicators.

Where applicable law requires consent for non-essential analytics or tracking technologies, we will seek and manage consent in accordance with applicable law.

5. Marketing, Attribution and Affiliate Technologies

Where applicable, Sales Machine may use tracking and attribution technologies to measure marketing campaigns, attribute referrals or conversions, evaluate traffic quality, prevent fraudulent activity, and administer affiliate relationships.

Depending on the technology and circumstances, such technologies may involve identifiers or technical information that may constitute personal data or personal information under applicable law.

Where consent is required, the relevant technology will be activated only in accordance with applicable consent requirements.

6. Third-Party Technologies

Some cookies and similar technologies may be provided or controlled by third-party technology providers, clients, advertisers, or media partners.

Such parties may process information under their own privacy policies and may have independent legal responsibilities.

Where appropriate, Sales Machine seeks to work with established providers and implement reasonable contractual, technical, and organizational safeguards.

7. Limited Intermediary Use

Sales Machine does not generally use cookies or similar technologies for the purpose of creating, maintaining, selling, or independently monetizing a consumer database for unrelated commercial purposes.

Where tracking or attribution information is handled in connection with a client campaign, it is generally used only to the extent reasonably necessary for measurement, attribution, reporting, fraud prevention, traffic-quality assessment, or the provision of the relevant service.

8. Your Choices

Where applicable, you may manage non-essential cookies and similar technologies through our cookie preference mechanism.

You may also be able to control certain technologies through your browser or device settings.

Rejecting or disabling certain technologies may affect the functionality or availability of some website features.

9. California Privacy Choices

Where applicable, California residents may have rights concerning certain uses or disclosures of personal information, including rights to opt out of certain sales or sharing activities.

Where required, Sales Machine provides applicable mechanisms for exercising these rights, including recognized opt-out preference signals.

10. Updates

Sales Machine may update this Cookie Policy from time to time to reflect changes in its technologies, services, business practices, or applicable legal requirements.

11. Contact

For questions regarding our use of cookies or similar technologies, please contact:

The Sales Machine / Online Blue Hawk — help@sales-machine.ai