PRIVACY POLICY

Date: 31.07.2026

1. GENERAL PROVISIONS AND PRIVACY COMMITMENT

1.1. The Company's management team and its employees take the safety of your personal data and general confidentiality very seriously. We are committed to ensuring transparency in how we use, protect, and process the data of our business partners.

1.2. This Privacy Policy sets out our data processing methods and your options concerning how your personal and corporate information is used. This Policy applies exclusively to Affiliates (B2B partners) participating in the Affiliate Program and forms an integral part of the Affiliate Agreement (Terms & Conditions).

1.3. We may periodically make changes to this Privacy Policy and will notify you of these changes by publishing the modified terms on our platforms. We recommend that you review this Privacy Policy regularly.

2. CONSENT TO DATA PROCESSING

2.1. The processing of your data starts only after you have clearly expressed your approval, which establishes a freely given, explicit, informed, and unambiguous expression of your consent.

2.2. Implicative Actions: Consent to the processing of data is granted to the Company by way of implicative actions of the Affiliate (the data subject). This expresses your will to establish a legal and commercial relationship with the Company through your behavior, including, but not limited to: registering on the Affiliate Program website, accessing the Affiliate dashboard, generating tracking links, or receiving Commission payouts.

2.3. The Company does not require additional consent to process data in the following cases:

(a) where processing is necessary to achieve objectives provided for by international treaties or local laws;

(b) where processing is necessary for the administration of justice or the execution of a court decision;

(c) where processing is necessary for the purposes of exercising the rights and legitimate interests of the Company or third parties, particularly regarding fraud prevention and legal compliance.

3. GATHERING AND PROCESSING OF DATA (KYC & KYB)

3.1. We collect and process information that can be used for personal and corporate identification purposes (hereinafter "Information"). As a B2B platform, we require comprehensive data to fulfill our Know Your Customer (KYC) and Know Your Business (KYB) obligations.

3.2. The Information we collect may include:

(a) Contact details (including first name, surname, phone number, and e-mail address).

(b) Corporate information, including company registration documents, details of directors, and information regarding Ultimate Beneficial Owners (UBOs).

(d) Payment information, specifically cryptocurrency wallet addresses and associated transaction histories.

3.3. Technical Data: When you interact with our services, our servers store a unique activity log that collects administrative and traffic information, including: source IP address, access time, date of access, visited web pages, language used, software crash reports, and type of browser used.

3.4. We may also receive Information from online vendors, service providers, and lawfully acquired third-party databases for identity verification purposes.

4. USE OF DATA

4.1. We use the Information that you provide primarily to deliver our Affiliate Program services, provide partner support, and process your financial transactions.

4.2. Additionally, your Information is actively used to:

(a) Conduct rigorous security, identity verification, and compliance checks.

(b) Audit traffic quality and monitor compliance with the Affiliate Agreement.

4.3. We may use third-party service suppliers for technical support of your online transactions and for maintaining your account. We will use the Information in accordance with the provisions of this Privacy Policy and the applicable legislation.

5. INFORMATION DISCLOSURE AND ANTI-FRAUD INITIATIVES

5.1. Generally, we do not disclose your Information to companies, organizations, or individuals not associated with the Company.

5.2. We may disclose your Information if required to do so by applicable law, or if we believe in good faith that such actions are necessary to comply with legal processes, or to protect our rights, property, and the security of our services.

5.3. Anti-Fraud Data Sharing: If, in our sole determination, you are found to have deceived us, attempted to deceive us, or breached the Affiliate Agreement through Fraudulent Traffic, chargeback abuse, or money laundering, we reserve the right to share your Information. This includes your identity, corporate details, IP addresses, and cryptocurrency wallet addresses, which may be shared with:

(a) Other affiliate networks, B2B gaming providers, and online gaming sites to prevent cross-platform fraud.

(b) Banks, credit card companies, and payment processors.

(d) Specialized third-party blockchain analysis and Know Your Transaction (KYT) service providers for the purpose of crypto wallet risk scoring.

5.4. Business Transfers: In the event of a merger, acquisition, corporate restructuring, or sale of all or a portion of our assets, your Information may be shared or transferred as a business asset to the acquiring or successor entity without requiring your explicit additional consent.

6. ACCESS AND DATA SUBJECT RIGHTS

6.1. You may 'opt out' of receiving any promotional communications by choosing to opt out via your Affiliate Account settings, in response to a promotional email, or by writing to our Affiliate Support Team.

6.2. In addition, you may contact us at any time if you:

(a) want to find out what of your personal or corporate Information we collect, process, and store, and from which sources we have obtained it;

(b) want to confirm the accuracy of the Information we have collected about you;

(d) have any complaint regarding our use of your Information.

6.3. We will update any Information you have provided to us, given that you prove the necessity for such changes and verify your identity.

6.4. For the avoidance of doubt, nothing in this Privacy Policy shall allow us to retain your Information if we are required to provide it by law; however, as a financial entity processing cryptocurrency, we are legally obliged to retain certain AML/KYC data for a mandatory period of five (5) years even after the termination of the Affiliate Agreement, to comply with international Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1. When accessing our Affiliate platform or generating tracking links, with your consent we may store information on your device. This information is referred to as 'cookies', which are small text files containing letters and numbers for recording your preferences and tracking referrals.

7.2. We use cookies strictly for monitoring traffic to our site, improving our B2B services, ensuring accurate attribution of New Customers to your Affiliate Account, and increasing your operational efficiency.

7.3. Our servers use three different types of cookies:

(a) Session-based cookies: Allocated to your device only for the duration of your visit to our platform, automatically expiring when you close your browser.

(b) Persistent cookies: Remain on your device for a set period of time to remember your login details and interface preferences.

7.4. You have a choice of whether to accept or decline cookies. However, if you choose to decline all cookies in the browser, you will not be able to use some of the features of the Affiliate Program, and critically, the tracking of your traffic and subsequent Commission calculations may not work correctly.

8. CONSENT TO SECURITY REVIEWS AND AML COMPLIANCE

8.1. We reserve the right to conduct a security review at any time to validate the registration details provided by you, to verify your financial transactions, and to ensure correct use of our services in order to prevent potential breaches of our Affiliate Agreement and applicable laws.

8.2. By agreeing to our terms, you authorize us to use your Information and disclose it to third parties for the purposes of validating your registration and verifying your traffic. Security reviews may include ordering a credit report and verifying the information you provide against third-party databases.

8.3. AML/CFT Policy: The Company carries out all appropriate measures to combat money laundering and international terrorism financing. You confirm that you have no information or any suspicions that the funds or crypto wallets used for transactions are received from any illegal source or related to unlawful activity.

8.4. Automated Decision-Making: We may use automated risk-scoring systems to evaluate the security of cryptocurrency transactions. While decisions to suspend payouts based on these scores may be automated, the Affiliate may request a manual review of such decisions by contacting our compliance team; however, the Company retains the absolute right to uphold the final decision.

8.5. The Company monitors any suspicious activity on the Affiliate's account. The Company has the right to ban the Affiliate at any time if there are grounds for supposing that operations relate to money laundering. In accordance with international law, the Company is not obliged to inform the Affiliate that their suspicious activity has been passed to relevant authorities.

9. THIRD-PARTY ELECTRONIC SERVICE PROVIDERS

9.1. To process Commission payouts, we use third-party electronic payment systems and blockchain networks. By accepting this Privacy Policy, you expressly and voluntarily consent to the transfer of your Information to third parties (including cryptocurrency exchanges or KYT providers) which is necessary for the processing of monetary transactions.

9.2. This includes, when necessary, the transfer of your Information outside of your country of residence.

10. SECURITY OF INFORMATION

10.1. We understand the importance of providing security and the methods needed to secure the confidentiality, integrity, and accessibility of information. We store all Information we receive directly from you in an encrypted and password-protected database stored within our secure network behind active up-to-date firewall software.

10.2. Our Services support robust industry-standard encryption protocols (including SSL). We take measures to ensure our subsidiaries, agents, partners, and suppliers employ adequate security measures.

10.3. However, sending information via the internet is usually not completely secure, and we cannot guarantee the security of your data while it is being sent. ANY DATA, WHICH YOU SEND, IS SENT AT YOUR OWN RISK.

11. PROTECTION OF MINORS (AGE RESTRICTIONS)

11.1. Our B2B Affiliate Program is strictly not intended for persons under the age of eighteen (18) or the lawful age of commercial majority in their respective jurisdiction.

11.2. Any person who provides their information to us through the Affiliate Program confirms to us that they are at least eighteen (18) years of age. If we become aware that a minor has submitted information, we will not accept their application and will purge the information from our records.

12. INTERNATIONAL TRANSFERS

12.1. Information collected by us may be stored and processed in any country in which we or our affiliates, suppliers, partners, or agents operate.

12.2. By using our services, you expressly consent to any transfer of Information outside your country, including to jurisdictions that may not be considered as having adequate privacy laws. Nevertheless, we take steps to ensure that our agents and partners comply with our standards of privacy regardless of their location.

13. LEGAL DISCLAIMER

13.1. We are not responsible for events beyond our direct control. We do not guarantee an error-free operation regarding the confidentiality of your Information when you visit other websites using links located on our website.

13.2. We are not responsible for any direct or indirect damage arising from the unlawful use or theft of your Information.