Thor Affiliate Program Terms & Conditions

The binding agreement between you (the "Affiliate") and Phoenix Technologies ("Thor", "Company", "we", "us", "our") governing participation in the Thor Affiliate Program (the "Program").

Last Updated: July 16, 2026 · Version 2.0

Version française

Please read carefully. By clicking "Activate" on your affiliate link or submitting your PayPal payout address in your Affiliate dashboard, you accept these Terms in full. If you do not accept them, do not use the Program.

Contents

  1. Definitions
  2. Enrollment & eligibility
  3. Affiliate link & tracking
  4. Commission structure
  5. Payout terms
  6. Prohibited marketing practices
  7. Brand assets & trademark use
  8. Refunds, chargebacks & clawbacks
  9. Tax responsibility
  10. Relationship of the parties
  11. Confidentiality
  12. Representations & warranties
  13. Indemnification
  14. Limitation of liability
  15. Term & termination
  16. Modifications to these Terms
  17. Governing law & disputes
  18. Miscellaneous
  19. Personal data (RGPD)
  20. Contact

1. Definitions

  • "Company", "Thor", "we", "us", "our" means Phoenix Technologies, a French société par actions simplifiée (SAS) with a share capital of 1,000 euros, registered with the Trade and Companies Register of Paris (RCS Paris) under number 938 548 112, intra-Community VAT number FR31938548112, with its registered office at 60 rue François Ier, 75008 Paris, France. Legal contact: [email protected].
  • "Affiliate" means any individual or legal entity that has enrolled in the Program and agreed to these Terms.
  • "Professional Affiliate" means an Affiliate who participates in the Program in the course of a commercial, industrial, craft, liberal or agricultural activity.
  • "Non-Professional Affiliate" means an Affiliate who is a natural person acting for purposes outside any trade, business, craft or profession (a consumer), or a non-professional within the meaning of French consumer law.
  • "Affiliate Link" means the unique tracking URL issued to the Affiliate in the format https://thortradecopier.com/t/{code}.
  • "Referred Customer" means a new customer who (i) clicks the Affiliate Link, (ii) is not already a registered Thor customer, and (iii) completes a paid subscription to a Thor product within the attribution window.
  • "Qualifying Payment" means any invoice actually paid by a Referred Customer and not subsequently refunded, charged back, or reversed.
  • "Approved Balance" means the sum of all commissions earned on Qualifying Payments that have cleared any applicable review or clawback period.
  • "Commission" means the affiliate fee payable to the Affiliate under Section 4.

2. Enrollment & eligibility

To participate in the Program, you must:

  • Complete the affiliate signup form (no Thor subscription is required to join the Program; if you already have a Thor customer account, it includes affiliate access);
  • Be at least 18 years of age (or the age of majority in your jurisdiction);
  • Be legally capable of entering into a binding contract;
  • Not reside in, or be a citizen of, a country subject to comprehensive U.S., EU, UK, or UN sanctions (including but not limited to Cuba, Iran, North Korea, Syria, the Crimea, Donetsk, and Luhansk regions);
  • Provide a valid and verified PayPal email address before any payout can be issued.

We may decline an enrollment application at our discretion. Once you are enrolled, we may suspend your participation only on legitimate grounds (in particular suspected fraud, suspected breach of these Terms, sanctions compliance, or an invalid payout destination), notified by email to the address on your affiliate profile; suspension and termination of enrolled Affiliates are otherwise governed by Section 15, and you may contest a suspension through the evidence procedure in Section 3.

3. Affiliate link & tracking

Upon enrollment, you will be issued a unique Affiliate Link. Referrals are attributed to you when a visitor clicks your link and subsequently completes a paid subscription within the attribution window configured by the Program (currently one hundred eighty (180) days from the click, matching the lifetime of the thor_aff cookie described below, subject to change under Section 16).

You may not alter, obscure, cloak, or shorten the Affiliate Link in a manner that conceals its destination from the end user, except via reputable public URL shorteners that preserve full click-through transparency.

Where multiple affiliates could be credited for the same customer, the last click wins within the attribution window.

Cookie consent. Attribution relies on the thor_aff first-party cookie. That cookie is set only if the visitor accepts marketing cookies in the site's consent banner, where "Accept all" and "Reject all" are offered with equal prominence; the visitor's choice is stored for six (6) months and can be withdrawn at any time via the "Manage cookies" link in the footer. If the visitor refuses marketing cookies, referral information is kept for the current visit only and the referral may not be attributed; no Commission is due for a referral that cannot be attributed for this reason. You acknowledge that Thor does not track visitors who have refused cookies.

Attribution evidence. The data recorded by Thor's tracking system constitutes the primary evidence of attribution. It is not, however, irrebuttable: if you believe a referral was not correctly attributed to you, you may submit any contrary evidence in your possession (correspondence, timestamps, screenshots, or other records) to [email protected]. We will examine that evidence and resolve any attribution dispute in good faith.

4. Commission structure

Subject to these Terms, Thor will pay you a Commission equal to fifteen percent (15%) of each Qualifying Payment made by a Referred Customer, for the full lifetime of that customer's subscription. The rate applied to your account (for first and recurring payments) is displayed in your Affiliate dashboard; if a different rate has been agreed with you individually in writing, that agreed rate prevails.

  • Commissions are calculated on the net amount invoiced, excluding any taxes, fees, refunds, and chargebacks.
  • Commissions are tracked and paid in U.S. dollars (USD).
  • Commissions accrue automatically the moment a Referred Customer's invoice is successfully paid on Thor's payment processor.
  • A commission becomes part of your Approved Balance after the applicable review period (see Section 8) has elapsed without a refund or chargeback.

The Commission rate, attribution window, and product eligibility may only be changed following the notice procedure in Section 16 (at least 30 days' notice by email). Any change to the Commission rate applies only to Commissions accruing after the effective date of the change; Commissions already accrued remain payable at the previous rate.

5. Payout terms

5.1 Method

Payouts are issued exclusively via PayPal, sent to the verified PayPal email address saved in your Affiliate dashboard. Thor does not offer bank transfers, wire transfers, cryptocurrency, gift cards, or any other payout method under this Program.

5.2 Threshold

The minimum payout threshold is one hundred U.S. dollars ($100 USD). Payouts will not be issued until your Approved Balance equals or exceeds this amount on the payout-calculation date.

5.3 Frequency

Thor processes payouts once per calendar month, typically within the first ten (10) business days of the following month. Only one (1) payout per Affiliate per calendar month is permitted.

5.4 Roll-over

If your Approved Balance is below $100 USD at the payout-calculation date, the balance rolls over to the next month's cycle automatically. There is no expiration on unpaid balances, provided the Program and your participation in it remain active, subject only to the dormancy rule in Section 5.6.

5.5 PayPal fees & currency conversion

Any PayPal receiving fees, currency-conversion charges, or withdrawal fees imposed by PayPal on your account are your sole responsibility. Thor pays gross in USD; your net receipt after PayPal's fees may be lower.

5.6 Inactive accounts & dormant balances

If your PayPal email becomes invalid, or if you do not respond to payout-verification requests within sixty (60) days, we may suspend your payouts until a valid address is confirmed. A balance may be forfeited only if both of the following conditions are met: (i) the balance has remained dormant, with no valid payout destination and no response from you, for twenty-four (24) months; and (ii) Thor has first sent you a written warning by email to the address on your affiliate profile, giving you a reasonable period to provide a valid payout destination or claim the balance. If you are a Non-Professional Affiliate, no forfeiture applies: your dormant balance simply remains suspended and stays payable on request until your claim is extinguished by the statutory limitation period.

6. Prohibited marketing practices

Strict prohibition. Violation of any item in this Section 6 may result in immediate termination from the Program and, in the cases and within the limits set out in Section 15 (fraud or material breach that caused the commissions concerned), forfeiture of those commissions. Thor may also pursue damages where warranted.

6.1 No paid advertising

You may not run, buy, place, or cause to be placed any paid advertising that promotes your Affiliate Link, the Thor brand, or any Thor product, including (without limitation):

  • Google Ads (Search, Display, Shopping, YouTube, Discovery, Performance Max);
  • Meta Ads (Facebook, Instagram, WhatsApp, Messenger);
  • TikTok Ads, X/Twitter Ads, LinkedIn Ads, Reddit Ads, Pinterest Ads, Snapchat Ads;
  • Microsoft Advertising / Bing Ads, Yahoo Gemini, Yandex Direct, Baidu, Naver;
  • Native-ad networks (Taboola, Outbrain, MGID, Revcontent, etc.);
  • Programmatic display, pop-ups, pop-unders, interstitials, and push-notification ads;
  • Sponsored-post placements or paid "shout-outs" on any platform where the primary consideration is monetary (or equivalent) payment to a third party for traffic;
  • SEO cloaking, doorway pages, and black-hat redirect chains designed to siphon branded search traffic.

6.2 No brand-keyword bidding

You may not bid on, purchase, or optimize any paid placement for search terms that include, consist of, or are confusingly similar to "Thor", "Thor Trade Copier", "Thor Copier", "Phoenix Technologies", "Phoenix Trader Funding", any Thor product name (Odin, Saga, TFeed, etc.), or any misspelling, plural, or close variant of the foregoing, on any search engine or ad platform worldwide. This prohibition applies regardless of whether paid ads are otherwise permitted.

6.3 No incentivized traffic

You may not offer cash, cash-equivalents, rebates, points, airdrops, raffle entries, or any other incentive in exchange for clicks on your Affiliate Link or for subscribing to Thor through your link.

6.4 No spam

You may not promote your Affiliate Link through unsolicited email, SMS, direct-message spam, forum spam, comment spam, automated bot traffic, or any form of bulk unsolicited communication. All email and electronic marketing must comply with the applicable anti-spam, e-privacy, and data-protection rules of every jurisdiction in which the recipients are located.

6.5 No misleading or deceptive claims

You may not:

  • Guarantee, suggest, or imply specific financial returns, profits, or income from using Thor;
  • Display fabricated, doctored, or non-representative screenshots of trading results;
  • Misrepresent your relationship with Thor (e.g., claiming to be an employee, official partner, or sole authorized reseller);
  • Claim that Thor endorses you, your content, or any third party where no such endorsement exists;
  • Make any statement that is false, misleading, or reasonably capable of deceiving a prospective customer.

6.6 No self-referrals or family/household referrals

You may not use your own Affiliate Link to purchase Thor subscriptions for yourself, for accounts you control, or for members of your household. Referrals identified as self-referrals or household referrals are ineligible and will be reversed.

6.7 No cookie-stuffing or forced-click

You may not use iframe stuffing, pixel stuffing, auto-redirect chains, forced clicks, or any technical method that drops Thor tracking cookies without the user's deliberate, informed action.

6.8 No regulated-product claims

Thor is trading software published by a software company; it is not a licensed financial advisor, broker, or investment product, and Phoenix Technologies does not provide any investment service within the meaning of Article L321-1 of the French Code monétaire et financier, is not an investment services provider within the meaning of Article L531-1 of the same code, and is not authorised or regulated by the AMF or the ACPR. You may not describe Thor as "guaranteed profits", a "risk-free opportunity", a "regulated investment", or anything that could reasonably be mistaken for a regulated financial service.

6.9 Mandatory disclosure

Whenever you promote the Affiliate Link, you must clearly and conspicuously disclose that the link is an affiliate link and that you may earn a commission if the visitor subscribes. This disclosure must comply with the U.S. FTC rules (16 CFR Part 255), the UK CMA online influencer guidance, and any analogous rules in your jurisdiction. For any promotion addressed to a French audience, the French regime described in Section 6.10 is the governing standard: the label "Publicité" or "Collaboration commerciale" must be used as described there.

6.10 French-audience rules (loi n° 2023-451 du 9 juin 2023)

If your promotion is addressed to an audience in France, you act as a commercial influencer within the meaning of loi n° 2023-451 du 9 juin 2023. In that case:

  • Every promotion of Thor (post, story, video, live stream, or any other format) must carry the label "Publicité" or "Collaboration commerciale", clearly legible and visible during the whole duration of the promotion;
  • Where the thresholds set by that law apply, you must comply with the written-contract formalities of art. 8 of that law;
  • You remain solely responsible for complying with every other obligation that law imposes on commercial influencers.

6.11 No combined financial promotion; how Thor may be presented

Toward French audiences, you may not promote Thor in combination with referrals to CFD or forex brokers, prop-firm challenges presented as investments, or any regulated financial product or service.

In all cases and toward all audiences, you may never present Thor as an investment service, as "copy trading of other traders", as a signals service, or as a product that generates profits. Thor may only be presented as what it is: a software tool that copies the user's own trades between the user's own trading accounts.

6.12 Mandatory risk warning

Thor is used with leveraged products. Trading futures and CFDs carries a high risk of loss; leverage amplifies both gains and losses, and losses can be rapid and substantial. Past performance, whether real or simulated, is not a reliable indicator of future results. Thor does not improve the probability of profit; it only replicates the user's own orders. You must never remove, obscure, minimise or contradict these warnings, and any promotion that shows trading activity or trading results must carry a clearly visible risk warning covering futures and CFD risk, leverage and past performance.

7. Brand assets & trademark use

Thor grants you a limited, revocable, non-exclusive, non-transferable license to use the official Thor name, logo, and marketing screenshots solely for the purpose of truthfully promoting the Affiliate Link. You must:

  • Use only unaltered versions of the official logos and screenshots provided by Thor;
  • Not register, own, or use any domain name, social-media handle, app name, or business name containing "Thor", "Thor Trade Copier", "Phoenix Technologies", or any confusingly similar string;
  • Cease all use of Thor brand assets immediately upon termination of your participation in the Program.

All goodwill arising from your use of Thor brand assets inures solely to Thor. Nothing in these Terms grants you any ownership or rights to Thor's trademarks beyond this limited use.

8. Refunds, chargebacks & clawbacks

If a Referred Customer receives a refund, files a chargeback, or has a payment reversed for any reason, the corresponding Commission is automatically reversed. Already-paid Commissions may be deducted from your next scheduled payout; if your future earnings are insufficient to offset the clawback, Thor may invoice you for the outstanding amount.

Thor applies a thirty (30) day review period from the date of each Qualifying Payment before the corresponding Commission becomes part of your Approved Balance, to account for typical refund and chargeback windows.

Fraudulent transactions, payment-method fraud, customer disputes involving suspected affiliate abuse, or any transaction Thor reasonably believes to be illegitimate may be excluded from Commission calculations. If you dispute such an exclusion, the attribution-evidence procedure in Section 3 applies.

9. Tax responsibility

You are solely responsible for reporting and paying all taxes, duties, levies, and social contributions due on Commissions in your jurisdiction. Thor does not withhold income tax on your behalf. You agree to provide any reasonably requested tax or invoicing information (such as a VAT identification number, business registration details, or a certificate of tax residence) before Thor releases any payout.

If Thor is required by law to withhold tax on a payout, the withheld amount will be deducted from your gross Commission and remitted to the relevant authority.

10. Relationship of the parties

You and Thor are independent contractors. Nothing in these Terms creates an employment, agency, partnership, joint venture, or franchise relationship. You have no authority to bind Thor, accept service on Thor's behalf, or make any representation, warranty, or guarantee on Thor's behalf.

11. Confidentiality

You may receive non-public information about the Program (commission reports, customer data, upcoming product or pricing changes, internal dashboards) which constitutes Thor's Confidential Information. You agree to protect it with at least the same care you apply to your own confidential information (no less than reasonable care), not disclose it to any third party, and use it only for the purpose of promoting the Affiliate Link. This obligation survives termination for three (3) years.

Referred Customers' personal data. Your Affiliate dashboard displays certain personal data of your Referred Customers (name, email address, subscription status, trial status, and amounts paid). You may use that data solely to verify the referrals attributed to you and the Commissions due under these Terms. You must keep it confidential and secure, must not use it for marketing, prospecting or any other purpose, must not disclose it to anyone, must not combine it with other data sets, and must delete any copy in your possession when your participation in the Program ends. Any use of that data outside these limits is a material breach of these Terms.

12. Representations & warranties

You represent and warrant that:

  • You have the full right, power, and authority to enter into and perform these Terms;
  • Your marketing activities and any content you publish in connection with the Program will comply with all applicable laws (including consumer-protection, advertising, anti-spam, data-protection, and financial-promotion laws, and, where applicable, loi n° 2023-451 du 9 juin 2023);
  • You will not infringe any third party's intellectual-property, publicity, privacy, or other rights;
  • All information you provide to Thor is accurate, current, and complete.

Thor provides the Program "as is" and "as available" and, to the fullest extent permitted by applicable law, disclaims all other warranties, express or implied. For Non-Professional Affiliates, this disclaimer applies only to the extent permitted by the mandatory rules of French consumer law, which remain unaffected.

13. Indemnification

You agree to indemnify and hold harmless Phoenix Technologies and its officers, directors, employees, and agents from and against third-party claims, damages, liabilities, losses, costs, and expenses (including reasonable attorneys' fees) to the extent they are caused by your breach of these Terms or by your fault, including: (a) your breach of these Terms; (b) unlawful marketing activities or content published by you; or (c) your violation of any law or third-party right.

This indemnity is limited to claims actually caused by your breach or fault. If you are a Non-Professional Affiliate, this Section applies only within the limits permitted by the mandatory rules protecting consumers and non-professionals, and does not deprive you of any statutory right.

14. Limitation of liability

Between professionals: to the maximum extent permitted by applicable law, Thor's total aggregate liability to a Professional Affiliate under or in connection with the Program or these Terms shall not exceed the total Commissions paid (or payable) to that Affiliate during the twelve (12) months immediately preceding the event giving rise to the claim, and Thor shall not be liable to a Professional Affiliate for any indirect or consequential damages, lost profits, lost revenue, or lost goodwill.

Non-Professional Affiliates: the caps and exclusions above do not apply to Affiliates acting as consumers or non-professionals. If you are a Non-Professional Affiliate, you keep all the rights granted to you by mandatory law, and nothing in these Terms limits or excludes Thor's liability in a way that would be unlawful toward you (including liability for gross negligence, wilful misconduct, or personal injury).

15. Term & termination

These Terms remain in effect while you participate in the Program. Either party may terminate:

  • By you: at any time, by deactivating your Affiliate Link in your dashboard or contacting Thor support;
  • By Thor: by notice to the email address on your affiliate profile, effective immediately in the event of fraud or a serious breach of these Terms by you; for any other breach, after a written notice specifying the breach has remained uncured for fourteen (14) days; and otherwise with reasonable notice.

Upon termination:

  • Your Affiliate Link is deactivated and stops tracking new referrals;
  • Termination without Affiliate breach: Commissions already accrued remain payable. Any Approved Balance at or above the payout threshold in Section 5.2 is paid in the normal monthly payout cycle. Any balance below the threshold remains governed by Sections 5.4 and 5.6;
  • Forfeiture is strictly limited: unpaid commissions may be forfeited only where they were caused by fraud on your part or by a material breach of these Terms by you (for example, commissions generated through a practice prohibited by Section 6). Commissions unconnected to the fraud or breach remain payable under the previous bullet;
  • You must immediately cease all use of Thor brand assets and remove your Affiliate Link from all platforms you control.

Sections 4 (accrued commissions), 5 (payout of accrued balances), 8, 9, 11, 13, 14, 17, and 18 survive termination.

16. Modifications to these Terms

Thor may amend these Terms, including the Commission rate, the attribution window, and product eligibility. Any amendment requires at least thirty (30) days' prior notice by email to the address on your affiliate profile before it takes effect, in addition to the posting of the revised version at this page with an updated "Last Updated" date.

  • Changes to the Commission rate apply only to Commissions accruing after the effective date of the change;
  • Commissions already accrued before the effective date remain payable under the terms in force when they accrued;
  • If you do not accept an amendment, you may terminate your participation under Section 15 at any time before the effective date; in that case the amendment will not apply to you, and your accrued Commissions remain payable.

Your continued participation in the Program after the effective date of a revision constitutes acceptance of the revised Terms.

17. Governing law & disputes

These Terms are governed by French law.

Between professionals: any dispute between Thor and a Professional Affiliate arising out of or relating to these Terms is subject to the exclusive jurisdiction of the competent courts of Paris, France, except that Thor may seek injunctive or equivalent protective relief in any court of competent jurisdiction to protect its intellectual property or Confidential Information.

Non-Professional Affiliates: the exclusive-jurisdiction clause above does not apply to you. You keep the statutory forum rules, including, where French consumer law applies, the option under art. R631-3 of the Code de la consommation to bring proceedings before the court of the place where you resided when the contract was concluded or when the harmful event occurred.

Consumer mediation: if you participate in the Program as a consumer, then after a prior written complaint to [email protected] remains unresolved for 1 month (or is rejected), you may refer the dispute free of charge to the médiateur de la consommation (art. L612-1 C. conso). Phoenix Technologies is finalising the designation of its consumer mediator; the mediator's identity and contact details will be published on this page as soon as the designation is complete.

Before filing any formal legal action, Thor and any Professional Affiliate will first attempt to resolve the dispute through good-faith negotiation for at least thirty (30) days from written notice of the dispute. This step is not a precondition for Non-Professional Affiliates: if you are a consumer or non-professional, you may use the consumer mediation described above or bring the matter directly before the competent court at any time.

18. Miscellaneous

  • Entire agreement. These Terms, together with the Thor Terms of Service and Privacy Policy, constitute the entire agreement between you and Thor regarding the Program and supersede any prior understandings.
  • Severability. If any provision is held unenforceable, the remaining provisions continue in full force.
  • No waiver. A failure to enforce any right or provision is not a waiver of future enforcement.
  • Assignment. You may not assign or transfer these Terms without Thor's prior written consent. Thor may assign these Terms, including in connection with a merger, acquisition, or sale of assets, provided the assignment does not diminish the Affiliate's rights or guarantees under these Terms; toward Non-Professional Affiliates, an assignment is enforceable only on that condition (art. R212-2 5° of the French Code de la consommation).
  • Notices. Notices to Thor must be sent to the contact address in Section 20. Notices to you will be sent to the email address on your Affiliate profile.
  • Force majeure. Neither party is liable for failure to perform due to an event beyond its reasonable control meeting the conditions of art. 1218 of the Code civil (including natural disasters, war, civil unrest, governmental action, or internet-infrastructure failure).
  • Language. These Terms exist in English and in French (Conditions du Programme d'Affiliation). For Affiliates residing in France, the French version prevails in case of conflict; for all other Affiliates, the English version controls.

19. Personal data (RGPD)

Controller. The controller of the personal data processed for the Program is PHOENIX TECHNOLOGIES, société par actions simplifiée (SAS) with a share capital of 1,000 euros, RCS Paris 938 548 112, 60 rue François Ier, 75008 Paris, France, contact: [email protected]. This section provides the information required by art. 13 of the RGPD (règlement (UE) 2016/679) for the processing specific to the Program; the Thor Privacy Policy applies in addition.

19.1 Purposes and legal bases

  • Enrollment, issuance of your Affiliate Link, attribution of referrals, calculation of Commissions and execution of PayPal payouts: performance of the contract formed by these Terms (art. 6(1)(b) RGPD);
  • Invoicing, tax withholding and screening against EU, UN and French sanctions regimes: compliance with our legal obligations (art. 6(1)(c) RGPD);
  • Screening against U.S. and UK sanctions regimes: our legitimate interest in avoiding exposure to secondary sanctions and payment-network restrictions (art. 6(1)(f) RGPD);
  • Display of your Referred Customers' records (name, email address, subscription and trial status, amounts paid) in your affiliate dashboard, so you can verify your Commissions: our legitimate interest in providing transparent commission accounting (art. 6(1)(f) RGPD); Referred Customers are informed of this disclosure in the Thor Privacy Policy;
  • Fraud prevention, clawback investigations and handling of attribution disputes: our legitimate interest in protecting the Program against abuse (art. 6(1)(f) RGPD);
  • The thor_aff attribution cookie set on visitors' devices: the visitor's consent, collected through the site's consent banner (art. 6(1)(a) RGPD); see the Cookie Policy.

Providing your identification details, email address, PayPal address and, where requested, tax justifications is a contractual requirement: without them we cannot enroll you in the Program or issue payouts.

19.2 Retention periods

  • Affiliate profile and commission records: for the duration of your participation in the Program, then five (5) years, corresponding to the statutory limitation period for commercial claims;
  • Invoices and accounting records: ten (10) years, as required by French accounting law;
  • Tax justifications (VAT numbers, business registration details, certificates of tax residence, withholding records): six (6) years, as required by French tax law;
  • Attribution click logs: one hundred eighty (180) days from the click (the attribution window), plus the thirty (30) day review period of Section 8 and, where an attribution dispute under Section 3 is open, until its resolution.

19.3 Recipients

Your data is disclosed, strictly for the purposes above, to the following categories of recipients: PayPal (execution of payouts), Stripe (payment processing of Referred Customers' subscriptions), Hetzner Online GmbH, Germany (application and payment hosting), Namecheap, Inc., USA (website hosting), and Cloudflare, Inc., USA (content delivery and protection). Where these providers process data on our behalf, they act as processors bound by contracts meeting the requirements of art. 28 RGPD.

19.4 Transfers outside the European Union

Transfers to providers located in the United States (Namecheap, Cloudflare and, where it intervenes, PayPal Inc.) rely on the EU-US Data Privacy Framework for recipients certified under it and, otherwise, on the standard contractual clauses adopted by the European Commission, in accordance with art. 44 et seq. RGPD. A copy of the applicable safeguards (standard contractual clauses) may be obtained by writing to [email protected]; the Data Privacy Framework certification list is available at https://www.dataprivacyframework.gov.

19.5 Your rights

You have the right to access, rectify and erase your personal data, the right to restriction of processing, the right to object, and the right to data portability (art. 15 to 21 RGPD), as well as the right to define directives on the fate of your data after your death (art. 85 of loi n° 78-17). Where a processing operation is based on consent, you may withdraw that consent at any time, without affecting the lawfulness of the processing carried out before the withdrawal. You can exercise these rights by writing to [email protected]. You also have the right to lodge a complaint with the CNIL (art. 77 RGPD): www.cnil.fr.

20. Contact

Questions, disclosures, or notices regarding these Terms or the Program should be directed to:

Phoenix Technologies, société par actions simplifiée (SAS) with a share capital of 1,000 euros
RCS Paris 938 548 112 · VAT FR31938548112
60 rue François Ier, 75008 Paris, France
Affiliate Program Compliance
Email: [email protected]
Support: [email protected]

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THOR

Server-based trade copier software published by Phoenix Technologies SAS. Thor is a software tool: it is not an investment services provider, is not regulated by the AMF or the ACPR, holds no client funds or financial instruments, provides no investment advice or trading signals, does not copy third-party traders' strategies and executes no orders on its own account; it copies only the user's own trades between the user's own accounts.

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