We supported a client in designing and executing an affiliate marketing program where participants could promote an online store through their own communication channels – including email campaigns and social media. A key feature of the program was that no personal data was exchanged between participants and the program operator.
Our role was to ensure that the campaign complied with data protection and electronic communication regulations. We developed a clear framework of responsibility, along with comprehensive documentation and procedures, allowing the client to run the program in a legally secure manner – even when the campaign triggered complaints from message recipients. We represented the client before the supervisory authority and successfully argued the legal soundness of the program.
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