Privacy Policy

Version: 2.0

Last update: 2024-06-17

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Introduction

FunID Partners (operated by Sentoka Ltd), is the controller of your personal data, referred below as “Company”, “we”, “our”, “us”), and represents the affiliate marketing program (“Affiliate Program”) of the Sentoka Ltd, which Affiliate Program is used to provide marketing services related to a number of brands operated by us.

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We are dedicated to safeguarding the privacy rights of our marketing affiliate partners ("Affiliate(s)", "you" or "your") and making our practices regarding your personal data transparent and fair. Accordingly, we have put in place this Privacy Policy to help you understand how we collect, store, use, share and protect your personal data, as well as your rights with respect to your personal data.

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Your Personal Data will be processed by us (including any of our agents and/or employees), and (where appropriate) any other company in our company Group and/or our partners and subcontractors, in accordance with this Policy.

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We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree to it. By visiting our affiliate program websites, or by creating a marketing affiliate account, you hereby confirm that you have read and understood all the terms of this Privacy Policy and do not object to the use of your Personal Data in accordance with these terms.

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If you do not agree to the terms of this Privacy Policy, please do not use our websites, and do not use our Affiliate Program. You are not legally required to provide us with any personal data, but without it, we will not be able to provide you with the full range or with the best experience of using our Services.

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We are reserving the right to change this Privacy Policy at any time, including altering the purposes for which it processes your Personal Data. Any changes will be published on our website. We shall provide notice of substantial changes of this Policy on our website and/or we shall send you an email regarding such changes to the e-mail address provided by you. All changes to this Privacy Policy are effective as of the stated "Last update" date, and your continued use of the Affiliate Program after the Last update date will constitute acceptance of, and agreement to be bound by, those changes. We, therefore, recommend that you check the Privacy Policy frequently for possible updates.

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If your participation in the Affiliate Program is governed by a separate written agreement, this Privacy Policy applies to you with the following adjustments: the company contracting you under the abovementioned written agreement shall be the controller of your personal data, Sentoka Ltd shall be the processor of your personal data, the recipients of your personal data disclosed below shall be the sub-processors of your personal data.

What information do we process?

We collect and process Personal Data about you which you provide to us, and which is generated in the course of your participation in the Affiliate Program. Such Personal Data may consist of the following:

Contact data (Full name, Title, Residence/Contact address, Phone number, Email addresses and types, Messenger addresses, Communication log/history, User’s direct marketing preferences);
Service data (Affiliate account ID, Affiliate type, Affiliate status, Signup date, Sub-affiliates, Parent Affiliate ID, Alias, Customer lifetime, Reward plan ID, Reward plan name, Reward plan type, Negative carry-over status, Affiliate group ID, Affiliate group name, Brand ID, Brand name, Comments);
Technical data (User ID, User login, User access credentials, User full name, User’s company, User’s position, User’s manager, Login dates, User type, User group, User status, Language preferences, User’s device, User’s operating system, User registration date, User’s country);
Financial data (Beneficiary name, Beneficiary registration number, Currency, Minimum payout value, Payment method, Payment details, Tax status);
Traffic source data (Marketing source ID, Marketing source name, Marketing source group, Marketing source URL, Cost per media status, Reward plan);
Marketing performance data (Linked customer accounts, FTDs, Deposit amounts, Net revenue, NetCash).

We also collect information which you provide us voluntarily in order to personalize your participation in the Affiliate Program or for a specific function, for example, you can provide your gender, age, interests, as well as other additional information about yourself which you voluntarily provide to us at your discretion for a specific function. In addition, we collect your communication when you respond to communications from us, provide us with feedback, communicate with us via email or share additional information about yourself through your use of the Affiliate Program.

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We sometimes collect and process Personal Data from third party service providers which is relevant to the provision of the Affiliate Program, Personal Data published in media, social media and other open sources, as well as Personal Data which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

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We collect and process information about your use of the Affiliate Program, such as applications' usage, log files, user activity (e.g. pages viewed, user's movements, time spent, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Affiliate Program.

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Our processing of your Personal Information may also involve special categories of personal data (as defined under Article 9 of the GDPR) for the provisions and improvement of our Service. We will only process such information, as well as disclose it to competent authorities (law enforcement bodies), where it is strictly necessary and required for the following purposes (to the extent permissible by applicable law): (i) prevention or detection of an unlawful act; (ii) prevention of dishonesty, malpractice, or other seriously improper conduct, provided that obtaining your consent may prejudice those purposes.

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How does the company collect the Affiliate’s data?

The company collects personal data directly from Affiliates when the Affiliate signs up for the Affiliate program or updates their profile.

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Purposes and legal bases for processing Personal Data

This section outlines the underlying purposes and legal bases for the processing of your Personal Data by us:

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Purpose

Legal basis

Provision of our Affiliate Program, support and affiliate relations. We use your Personal Data to present our Affiliate Program and its content to you, and to maintain your participation in our Affiliate Program. This includes, for example, managing and updating your account, providing and operating the Affiliate Program, responding to your inquiries, as well as your request to exercise your user rights or providing you with the latest updates about our Affiliate Program.

The legal bases for processing this data are the performance of our contractual obligation towards you (Art. 6.1(b) GDPR); your consent (where required) (Art. 6.1(a) GDPR, for example, when you agree to provide Personal Data by accepting our cookies), compliance with our legal obligations (Art. 6.1(c) GDPR); and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Affiliate Program.

Communication. We use your personal data and preferred communication method to communicate with you as regards the performance of duties in the affiliate program.

The legal basis for processing this data is the performance of contractual obligations (Art. 6.1(b) GDPR).

Payments. We collect certain information about your payment instruments for the purpose of connecting your payment instrument to your account on our Affiliate Program, processing payments, and sending statements, invoices, and other financial documentation.

The legal bases for processing this data are the performance of our contractual obligations (Art. 6.1(b) GDPR); and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are payment for the services provided by us and accurate accounting of the fees due.

Improve our Affiliate Program. We collect and analyse information about you and your usage of our Affiliate Program to improve the usability and effectiveness of our Affiliate Program based on your common preferences and uses.

The legal basis for processing this data is our legitimate interest (Art. 6.1(f) GDPR). Our legitimate interests in this case are providing and improving our Affiliate Program.

Marketing, Advertising and Analytics. We use your Personal Data in order to provide you with personalized advertisements, including behavioural advertising when you visit our websites and to personalize your experience. In addition, we may use your Personal Data for certain marketing and promotional activities as well as gather aggregate usage information for analytics, statistical and research purposes.

The legal bases for processing this data are your consent (where required) (Art. 6.1(a) GDPR) and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are providing you with tailored services, Affiliate Program content and advertisements that better fit your interests and promoting our Affiliate Program.

Integrity. We may process certain information about you and your usage of the Affiliate Program in order to keep the integrity and security of the Affiliate Program and its infrastructure.

The legal bases for processing this data are compliance with our legal obligations (Art. 6.1(c) GDPR) and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are keeping the integrity of our Affiliate Program and the safety of our end-users.

Dispute resolution and protection of our legal claims. We collect your Personal Data in order to investigate violation of our policies, enable us to resolve disputes in connection with your use of the Affiliate Program and to establish and defend our legal claims.

The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to establish and defend our legal claims.

Corporate transactions. We may share your Personal Data with a potential purchasers, successors or investors in the Company or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to the Company.

The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to establish negotiate, conclude and perform corporate transactions.

Prevention of fraud or violation of our policies. We may process your Personal Data to detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Affiliate Program, including by identifying risks associated with your activity within our Affiliate Program. We may also investigate any violations of our terms and conditions, agreements and policies, and enforce them.

The legal basis for processing this data is our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to protect our Company and other users against fraud.

Compliance with our legal obligations. We may use your Personal Data to assist us with meeting our regulatory obligations or as required by law or regulation (KYC and AML regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.

Our legal bases for processing such data is compliance with our legal obligations under the EU and national laws (Art. 6.1(c) GDPR), and our legitimate interests (Art. 6.1(f) GDPR). Our legitimate interests in this case are to comply with the laws of countries outside of the EU, as and if applicable to us.

Where you have not consented (or have withdrawn your consent) to the processing of your Personal Data by us, we may continue to process your Personal Data: (a) where processing is required for the performance of the contract (i.e. the Terms of Use) between you and us; and/or (b) where processing is necessary for compliance with a legal obligation to which we are subject; (c) where processing is necessary for the purposes of a legitimate interest of the Company and its affiliates (including for marketing).

With whom we share Personal Data?

We work with other companies who help us run our business (“Service Providers”). These Service Providers help us store information (such as cloud storage companies), deliver user support, process credit card payments, monitor and analyze the performance of our Affiliate Program and websites, manage and contact our existing affiliate partners as well as provide marketing support, provide fraud prevention services, and otherwise operate and improve our Affiliate Program. These Service Providers may only process Personal Data pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.

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We do not rent, sell, or share your Personal Data with Service Providers except as described in this Privacy Policy. The Personal Data will be disclosed to recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

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We may share Personal Data with any of the following recipients:

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Companies within our group and other affiliated companies;
Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, dentity verification and fraud prevention services, and other data verifiers;
Credit reporting agencies;
Payment service providers, payment processors and banks;
To any third parties who provide services in relation to the operation or promotion of the Affiliate Program;
Auditors, contractors or advisers of any of our group's business processes;
To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
Gambling addictions bodies;
Content providers;
Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
Potential purchasers or investors in any of the companies within our group, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the group (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Policy).

In addition to the purposes listed in this Privacy Policy, we share Personal Data with such recipients who we engaged for any of the following purposes:

Storing such information on our behalf, for example by using cloud computing service providers;
Processing such information to assist us with our business operations (e.g. to process payments; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
Performing research, technical diagnostics or analytics;
Communicating targeted advertising, as well as promotional and informational materials; and
Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including terms and conditions of the Affiliate Program), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

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International transfers of Personal Data

Since we operate globally, it may be necessary for the provision of our services and to the extent required for the specific purpose, as stipulated in this Privacy Policy, to transfer your Personal Data to countries outside the European Economic Area ("EEA"). The data protection and other laws of these countries may not be as comprehensive as those in the EEA, in these circumstances we will take reasonable steps to ensure that your Personal Data is protected in accordance with our Privacy Policy through contractual means (such as by using the standard contractual clauses approved by the relevant European Commission for data transfer, as available here) or other means (such as ensuring that the European Commission decisions determined that such jurisdictions offer an adequate level of protection as available here).

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For more information about the international transfer of your Personal Data, our contact details are available under the section below "How to contact us?".

Security

We implement and maintain security measures to protect your information to prevent unauthorized access and unlawful processing, accidental loss, destruction, misuse and damage of your Personal Data. We use state of the art technological security solutions, including encryption when transmitting sensitive information across the Internet. This means that all personal and financial information sent to and from the Website are encrypted in accordance with good industry practice.

In addition, we limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will take reasonable measures so as to notify you and any applicable regulator of a breach where we are legally required to do so.

While we are following best practice, including but not limited to implementing administrative, technical and physical measures to safeguard your Personal Data against loss, theft and misuse, you should also take personal steps to protect the security of your data both, physically and electronically, by following common best practice procedures such as:

Running Anti-Virus software and keeping it up to date.
Applying operating system, web browser and other security updates.
Ensuring your PC or other device is not left unattended whilst logged into our Affiliate Program.
Using strong passwords for all logins, including our Affiliate Program.

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What is your responsibility towards your referred players?

If you yourself receive and process personal information from players that you subsequently refer to us, then you shall ensure that they have given their express consent to such transfer to us, or you have obtained other valid legal grounds of processing, and this personal information is processed and transferred from you to us in accordance with relevant laws.

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If you have entered into a data protection addendum or other agreement with regards to your processing of players’ data, you shall comply with the terms of such agreement. You agree to indemnify us against all claims and associated costs brought against and suffered by us due to your breach of this clause.

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Minors

Our Affiliate Program is designed and directed exclusively to persons who have reached the age of eighteen (18) or such other age as defined by the applicable law as the legal age (persons “Legally of Age”). If you are not Legally of Age, you should not use the Affiliate Program nor provide any Personal Data to us.

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We reserve the right to access and verify any Personal Data collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information unless it is needed to comply with any legal or statutory obligation binding upon us. If you have any reason to believe that a minor has shared any information with us, please contact us (our contact details are available under the "How to contact us" section).

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Retention of Personal Data

We will retain your Personal Data during the period your account with the Affiliate Program is active and our contractual relationship with you continues. In addition, we will retain your Personal Data for additional periods, to enable us to meet our legal obligations under applicable laws or regulations, such as the applicable gambling regulations, KYC and AML regulations.

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In addition, we may retain your Personal Data for longer periods, provided that retaining such information is necessary for our legitimate interests, such as fraud prevention and record keeping. We will keep any relevant Personal Data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as it is necessary. Where Your Personal Data is no longer required by us, we will either securely delete or anonymize the Personal Data in question.

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If for any reason you wish to delete your Personal Data, please send us an e-mail to the address listed in “How to contact us” section below, and we will make reasonable efforts to address your request.

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What are your rights?

You have certain rights regarding the collection and processing of Personal Data. To the extent these rights apply to and concern you, you may exercise them by contacting us via the contact details available under the section "How to contact us?" below and exercise the following rights:

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(1) Rights of access and data portability – You may obtain a copy of the Personal Data held by the Company about you at any time and also the right to request that said data is transferred to a third party;

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(2) Right of rectification – In the event that the data held by the Company is inaccurate, incomplete or outdated, you may request the rectification of said data (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);

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(3) Right of erasure – You may at any time request that the Company erases data held about you by sending an email to the Company as outlined herein. You are, however, advised that with the deletion of your Personal Data, you might not be able to participate in the Affiliate Program anymore and your account might be totally closed;

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(4) Right to restriction of processing, objection to processing and withdrawal of consent – You may at any time request that the Company restricts or ceases to conduct certain data processes provided that there exists no other lawful basis on which the Company is authorized to process said data;

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(5) Right to lodge a complaint – All requests, complaints or queries may be addressed to the Company to the address listed in “How to contact us” section below with the subject ‘Privacy’. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this. You can also file a complaint with the Data Protection Authority should you not be satisfied with the way in which we handle your Personal Data.

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(6) Rights regarding automated individual decision-making, including profiling - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Please note that we do not employ any legally significant decision making based solely on automated means.

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Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions, requests, or complaints through our contact details below.

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We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority.

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How to contact us

If you have any general questions about the Affiliate Program, your Personal Data and/or how we collect and use it, or you want to exercise your rights as a personal data subject, please contact our Data Protection Officer via email at affiliates@funidpartners.com.

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We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.

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