1.1. Your privacy and personal data are important to us. This Privacy Policy explains how Alpha Affiliates collects, uses, discloses, stores and otherwise processes personal data in connection with the Alpha Affiliates website, affiliate programme and related affiliate-management and marketing activities. It also explains the rights available to individuals in relation to their personal data. Please also read the Alpha Affiliates Terms and Conditions governing participation in the affiliate programme. Where information is required for us to enter into or perform the affiliate relationship, make payments, verify an affiliate or provide a requested feature, failure to provide that information may mean that we cannot accept an application, maintain an Affiliate Account, process a payment or provide the relevant service.
1.2. The Alpha Affiliates Program is operated by 3-102-968789 (2026-Oryon), incorporated in Costa Rica and having its registered address at Province 01: San José, Canton 18: Curridabat, Granadilla Sur District. From the Fresh Market in Guayabos, 100 meters north and 25 meters west, cream-colored house with registration number 3-102-968789 (“Oryon”, the “Company”, “we”, “us” or “our”). The Company acts as the controller of the personal data described in this Privacy Policy to the extent that it determines the purposes and means of the relevant processing.
1.3. Alpha Affiliates operates as an affiliate programme and marketing/affiliate-management agency representing and promoting participating online gaming brands. Alpha Affiliates does not itself operate the online casino or betting services promoted through the programme and does not open or administer player gaming accounts.
1.4. This Privacy Policy applies to personal data relating to: (a) individual affiliates; (b) directors, employees, beneficial owners, representatives and contact persons of corporate affiliates; (c) prospective affiliates; (d) visitors to the Alpha Affiliates website; and (e) individuals participating in Alpha Affiliates partner competitions, promotions, events or incentive programmes.
2.1. The categories of personal data we process depend on how you interact with Alpha Affiliates, whether you participate as an individual affiliate or represent a corporate affiliate, and which programme features you use. We will collect only personal data that is reasonably necessary for the purposes described in this Privacy Policy.
2.2. Identity and verification data – such as name, surname, date of birth, nationality/country of residence and, where required for affiliate verification, compliance or payment purposes, identification-document details, tax identification information and information concerning the individual’s authority to act for a corporate affiliate.
2.3. Contact and business relationship data – such as postal or business address, telephone number, email address, messenger/contact details, company name, job title, role, business website and the identity of the organisation you represent.
2.4. Payment, commission and accounting data – such as the payment method selected by the affiliate, bank account or payment-wallet details where applicable, invoices, commission calculations, payment amounts, payment status and payment history.
2.5. Affiliate onboarding and professional data – such as information provided in an affiliate application, the websites, applications, social-media channels or other traffic sources used by the affiliate, target markets, promotional methods, experience, business model and other information reasonably required to assess and administer participation in the Affiliate Programme. We do not intend to collect information about an affiliate’s marital status or family unless exceptionally required and lawfully justified.
2.6. Affiliate Account and programme-use data – such as Affiliate ID, username, account status, account settings, assigned affiliate manager, programme/brand participation, marketing materials requested or used, communications preferences, and information concerning surveys, campaigns, competitions, incentive programmes or events in which you participate.
2.7. Affiliate referral, attribution and performance data. To administer the Affiliate Programme, Alpha Affiliates may receive or have access through affiliate tracking/reporting systems to information used to attribute traffic and activity to a particular Affiliate ID and to calculate or verify affiliate performance and commissions. Depending on the configuration of the relevant brand and affiliate platform, this may include tracking identifiers and affiliate-level or attributed metrics such as clicks, registrations/conversions, first-time-depositor indicators, qualifying activity, revenue/NGR figures and commission data. The precise fields received by Alpha Affiliates must reflect the actual technical data flow. This provision does not mean that Alpha Affiliates receives or controls a player’s full gaming account, KYC documents, payment credentials, deposit/withdrawal history, detailed gameplay history or responsible-gaming records.
2.8. Technical and device data – such as IP address, browser type and version, device type, operating system, language, time zone, approximate location derived from technical data, session identifiers and other technical/log information reasonably generated when you access the Alpha Affiliates website or affiliate platform.
2.9. Communications data – correspondence and communications with affiliate managers, support, legal, finance or other Alpha Affiliates teams, including the content and metadata of emails, support requests or other business communications where necessary to manage the affiliate relationship.
2.10. Website usage data – such as pages visited, date and time of access, referring and exit pages, links clicked, interactions with website features, error/log information and analytics information generated through cookies or similar technologies, subject to applicable consent requirements.
2.11. Competition, promotion and event data – information required to administer affiliate competitions, rankings, incentive campaigns and events, including Affiliate ID, qualifying performance, points, ranking/leaderboard position, eligibility status, winner status and, where relevant, contact, identity, travel or delivery information necessary to provide a prize or arrange participation.
2.12. We do not intentionally collect special-category personal data through the ordinary Affiliate Programme. If such information is exceptionally required, we will process it only where an appropriate legal basis and, where required, an additional condition under applicable data-protection law applies.
3.1. We process personal data only where we have an appropriate legal basis. Depending on the processing activity, this may be: (a) taking steps at your request before entering into a contract or performing the Affiliate Agreement; (b) compliance with a legal obligation; (c) our legitimate interests or those of a third party, provided those interests are not overridden by your interests or fundamental rights and freedoms; or (d) your consent, where consent is required or otherwise relied upon.
3.2.1. Affiliate onboarding and account administration – to review affiliate applications, verify applicant information where necessary, create and administer Affiliate Accounts, provide access to programme functionality and marketing materials, assign account management and maintain the contractual relationship. Legal basis: steps prior to entering into a contract and/or performance of the Affiliate Agreement.
3.2.2. Programme administration and operational communications – to send account, payment, security, compliance and service communications and notices concerning changes to the Affiliate Agreement, Privacy Policy, programme rules, supported brands or material programme functionality. Legal basis: performance of the Affiliate Agreement and/or legitimate interests in administering the programme.
3.2.3. Affiliate marketing and relationship communications – to send newsletters, offers, brand/campaign information, educational or promotional materials, event invitations and other B2B communications relevant to the affiliate relationship. Legal basis: consent where required by applicable law, or legitimate interests where business marketing may lawfully be conducted on that basis. Marketing preferences and opt-outs will be respected.
3.2.4. Verification, compliance, fraud prevention and traffic-quality controls – to verify affiliates where appropriate, assess suspicious or invalid traffic, prevent fraud, abuse or manipulation of the Affiliate Programme, investigate commission discrepancies and comply with legal, sanctions, tax, accounting or other compliance requirements applicable to Alpha Affiliates. Legal basis: legal obligation and/or legitimate interests, depending on the relevant requirement.
3.2.5. Referral attribution, performance reporting and commissions – to attribute referred traffic or qualifying activity to the appropriate Affiliate ID, generate affiliate reports, calculate and reconcile commissions, investigate reporting discrepancies and answer affiliate queries. Legal basis: performance of the Affiliate Agreement and legitimate interests in accurately administering the Affiliate Programme.
3.2.6. Competitions, promotions, rankings and incentives – to determine eligibility, calculate points, rankings and qualification, operate leaderboards, contact participants and winners, verify eligibility and arrange or deliver prizes. Legal basis: performance of the applicable promotion terms and/or legitimate interests in operating partner incentive activities.
3.2.7. Website, platform and security – to authenticate users, maintain and secure the website and affiliate systems, detect misuse, troubleshoot technical issues, analyse performance and improve programme functionality. Legal basis: legitimate interests and, for non-essential cookies or similar technologies, consent where required.
3.2.8. Legal and corporate purposes – to comply with lawful requests from courts, regulators, tax authorities or law-enforcement bodies; maintain records required by law; establish, exercise or defend legal claims; obtain professional advice; and manage corporate transactions or restructuring. Legal basis: legal obligation and/or legitimate interests.
3.3. Where we rely on legitimate interests, the relevant interests may include administering and protecting the Affiliate Programme, maintaining accurate attribution and commission reporting, preventing fraud and abuse, managing business relationships, improving our services and protecting our legal rights. We will consider the impact of the processing on affected individuals and apply appropriate safeguards.
4.1. We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for any compatible legal, accounting, audit, fraud-prevention, dispute-resolution or claims purpose. Retention periods will depend on the category of data, the duration of the affiliate relationship, applicable contractual and statutory limitation periods, tax/accounting requirements, the need to evidence transactions and payments, and the sensitivity and risk associated with the information.
4.2. As a general structure, active Affiliate Account and relationship data will be retained for the duration of the affiliate relationship and thereafter for the period reasonably required to close the account, settle outstanding commissions, address disputes and comply with legal obligations. Payment, invoice and accounting records may need to be retained for the applicable statutory accounting/tax period. Compliance or verification records, where collected, will be retained only for the period justified by the applicable legal or risk-management purpose.
4.3. Marketing contact data will be retained while the relevant business relationship or lawful marketing basis continues. Where you opt out, we may retain limited suppression information (for example, your email address and opt-out status) to ensure that your preference is respected.
4.4. Competition, leaderboard and prize-administration data will be retained for the duration of the relevant activity and thereafter only for the period necessary for prize fulfilment, audit, dispute handling and applicable legal obligations. Public leaderboard or winner information should be limited to what is reasonably necessary for the promotion.
4.5. Technical logs, analytics and cookie-related information will be retained in accordance with the configuration and retention periods of the relevant systems and tools, as disclosed through the cookie notice or consent-management interface where applicable.
4.6. When personal data is no longer required, it will be securely deleted, anonymised or otherwise put beyond use in accordance with our retention procedures, unless continued retention is required or permitted by law.
5.1. Alpha Affiliates and its service providers may process personal data in countries outside the European Economic Area (“EEA”), depending on the locations of our group companies, hosting infrastructure and service providers. Where applicable data-protection law restricts such transfers, we will use an appropriate transfer mechanism.
5.2. Depending on the destination and applicable law, such mechanism may include a European Commission adequacy decision, approved Standard Contractual Clauses, or another lawful safeguard. Where required, we will assess whether supplementary measures are appropriate having regard to the nature of the data and destination.
5.3. You may contact us using the details in Section 13 if you require further information about the safeguards applicable to a particular transfer, subject to any lawful confidentiality limitations.
6.1. Subject to the conditions and limitations of applicable data-protection law, you may have the following rights in relation to personal data processed by us:
6.1.1. You have the right to access and receive upon your written request personal data that is processed by the Company. If such request is excessive as well as repetitive, the Company may refuse to provide you with a copy of your personal data or request a reasonable fee taking into account the administrative costs of preparing such copy.
6.1.2. You have the right to request to correct any information you believe is incomplete or inaccurate.
6.1.3. You have the right to request that the Company restrict the processing of your personal data. Any such request shall be assessed by the Company whether such request does not contradict or could not contradict to other legal grounds of processing to which the Company is obliged.
6.1.4. You have the right to object to the Company processing of your personal data. You can in particular object to automated decision-making in case we decide to apply one.
6.1.5. You have the right to withdraw consent to process your personal data at anytime by contacting us directly.
6.1.6. You have the right to request for personal data to be erased. However, such right does not apply if personal data requested to be erased is being processed on legal grounds, for example based on legal obligations to comply with relevant legal enactments.
6.1.7. You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you. You have the right to receive your personal data in structured, commonly used and machine-readable format, as well as to transmit it to another controller. We are not obliged to protect your personal data that you choose to store or transfer outside our systems.
6.2. All aforementioned rights shall be exercised in good faith and on written request.
6.3. The reasonable time period for handling your request or complaint is 1 month. Taking into account complexity and number of requests, we can extend this time for 2 additional months.
6.4. In case your request is manifestly unfounded or excessive, in particular because of their repetitive character, we may either:
6.4.1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
6.4.2. refuse to act on your request.
6.5. You may lodge a complaint with the data protection supervisory authority competent for your habitual residence, place of work or the place of the alleged infringement. We encourage you to contact us first so that we have an opportunity to address your concern.
7.1. Requests for erasure are handled in accordance with Section 6 and applicable data-protection law. The availability or design of a particular technical deletion function does not determine whether you have a legal right to erasure.
7.2. Where an erasure request is valid, we will take reasonable steps to delete or anonymise the relevant personal data from active systems and, where applicable, instruct processors acting on our behalf to do the same, subject to lawful retention requirements and reasonable backup/archival cycles.
7.3. We may retain personal data notwithstanding an erasure request where and to the extent permitted or required by law, including where necessary for compliance with a legal obligation, the establishment, exercise or defence of legal claims, fraud prevention, accounting/tax requirements or the maintenance of a marketing suppression record necessary to respect an opt-out.
8.1. The Alpha Affiliates website and marketing materials may contain links to participating brands and other third-party websites. Those third parties operate under their own terms and privacy policies. Where a promoted brand/operator independently determines how it processes player personal data, it acts as a separate controller for that processing.
8.2. We do not sell personal data. We disclose personal data only where there is a legitimate business or legal reason to do so and subject to appropriate safeguards where required.
8.3. The Company reserves the right and for specific purposes to transfer your personal data to selected third parties, including:
8.3.1. Group companies and internal support entities – where they provide operational, finance, legal, compliance, IT, management or other support relevant to the Affiliate Programme, subject to appropriate access controls and confidentiality obligations.
8.3.2. Service providers/processors – including, as actually used, affiliate tracking/reporting platforms, hosting/cloud and IT providers, CRM and email providers, support/communications tools, analytics providers, verification/compliance providers, payment/accounting providers, professional advisers, and event or prize-fulfilment providers. Such providers may process personal data only for the relevant contracted purpose and subject to appropriate data-protection and confidentiality terms.
8.3.3. Authorities and legal recipients – courts, regulators, tax authorities, law-enforcement bodies or other recipients where disclosure is required by law, necessary to protect legal rights or made in response to a valid lawful request.
8.3.4. Participating brand operators – where necessary to administer the affiliate relationship, provide or verify referral attribution, investigate traffic quality or reporting discrepancies, calculate or reconcile commissions, manage campaigns, enforce programme terms or otherwise coordinate legitimate affiliate-programme activities. This does not mean that Alpha Affiliates creates or administers player accounts on behalf of the player.
8.3.5. Corporate transaction recipients – prospective or actual purchasers, investors, successors, advisers or counterparties in connection with a merger, acquisition, restructuring, sale, transfer or similar corporate transaction, subject to appropriate confidentiality and data-protection safeguards.
9.1. The Alpha Affiliates website uses cookies and similar technologies for purposes that may include essential website/account functionality, security, preferences, analytics, marketing and affiliate/referral attribution. The technologies actually used, their providers, purposes and retention periods should be reflected in the website’s cookie notice and consent-management interface.
9.2. Strictly necessary cookies. These cookies or similar technologies are required to provide functionality specifically requested by the user, maintain secure sessions, enable account authentication or provide core website functions. Where applicable law treats them as strictly necessary, consent is not required.
9.3. Performance cookies. Where used and permitted, these help us understand how visitors and affiliates use the website or programme, identify technical issues and improve performance. Where consent is required, such technologies will not be activated until the required consent has been obtained. Our performance cookies do not collect information that identifies you personally; however, if you have an account with us, the information collected by us using our performance cookies may be associated with your account.
9.4. Functionality cookies. These cookies are used to remember your choices (such as language preference, country location, or other online settings) and to provide online services to you, or to prevent online services from being offered to you if you previously indicated you did not want to receive such services. If you delete these functionality cookies, any preferences or settings you selected will not be retained for later visits. We do not share information collected using our functionality cookies with our advertisers or other third parties. Our functionality cookies collect anonymous information; however, if you have an account with us, the information collected by us using our functionality cookies may be associated with your account.
9.5. Marketing technologies. Where actually used, and subject to required consent, marketing cookies or similar technologies may be used to measure campaigns, understand interactions with marketing content or support relevant B2B marketing. The cookie interface should identify the relevant third parties and provide the controls required by applicable law.
9.6. Affiliate referral attribution. Affiliate links may contain a unique Affiliate ID or tracking parameter. Cookies or similar identifiers may be used by the relevant tracking platform and/or participating brand to attribute referred traffic, registrations or qualifying activity to the appropriate affiliate and to support commission reporting. The respective roles of Alpha Affiliates, the tracking-platform provider and the relevant brand/operator depend on the actual implementation.
9.7. Authentication/session technologies may be used where the Alpha Affiliates account or platform supports login functionality. Passwords should not be described as being stored in cookies unless the platform team confirms that this is technically accurate; normally session/authentication tokens rather than plain credentials are used.
9.8. Cookies may be session cookies, which expire when the relevant browsing session ends, or persistent cookies, which remain until their configured expiry or deletion. You can manage non-essential cookies through the consent-management interface and, where appropriate, through browser settings. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
9.9. To learn more about cookies, you can visitallaboutcookies.org.
9.10. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device. Please note, that we do not recognize or respond to browser-initiated Do Not Track signals, as the internet industry has not fully developed Do Not Track standards, implementations and solutions. To learn more about Do Not Track signals, you can visit allaboutdnt.com.
10.1. We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data, taking into account the nature, scope, context and purposes of processing and the risks to individuals.
10.2. Measures may include, as appropriate to the relevant system, access controls, authentication, least-privilege permissions, secure transmission/storage measures, logging/monitoring, backup and recovery procedures, vendor security requirements and organisational confidentiality controls. This statement should not be read as a guarantee that security incidents can never occur.
10.3. Affiliates are responsible for keeping their Affiliate Account credentials confidential, using reasonable security measures on devices used to access the programme and notifying Alpha Affiliates promptly if they suspect unauthorised access or compromise.
11.1. Where permitted by applicable law, Alpha Affiliates may send affiliates, prospective affiliates and business contacts communications concerning the Affiliate Programme, participating brands, campaigns, offers, educational materials, competitions, promotions, events and other B2B opportunities relevant to the relationship.
11.2. The legal basis for electronic marketing will depend on the recipient, jurisdiction and manner in which the contact details were obtained. Where consent is required, we will seek consent. Where applicable law permits relevant B2B marketing on the basis of legitimate interests or another lawful basis, we may rely on that basis subject to the recipient’s right to object.
11.3. You can opt out of marketing communications at any time by using the unsubscribe link included in the communication, adjusting available communication preferences or contacting us. An opt-out from marketing does not prevent us from sending non-marketing communications necessary to administer the affiliate relationship, such as Affiliate Account, security, commission/payment, contractual, compliance or policy notices.
11.4. Where our email or CRM tools record delivery, opens, clicks or similar engagement information, we will use that information only where lawful and in accordance with the transparency and consent requirements applicable to the relevant technology.
12.1. Alpha Affiliates may periodically operate competitions, rankings, incentive programmes, promotions or events for affiliates. We may process Affiliate Account and performance data to determine eligibility, calculate qualifying activity, points and rankings, establish leaderboard positions and administer the relevant promotion.
12.2. Where a public or participant-facing leaderboard is used, Alpha Affiliates may display an Affiliate ID, username/nickname or another appropriately limited identifier together with points, position or other competition information. We will seek to avoid publishing an affiliate’s full legal name, contact details or other unnecessary personal information unless this is specifically required for the relevant activity and lawfully disclosed.
12.3. We may contact qualifying participants and winners using the contact details associated with their Affiliate Account or otherwise provided for the promotion. Where necessary to provide a prize, we may request additional information such as delivery address, identity/eligibility evidence, clothing or equipment size, travel information or other details reasonably required for fulfilment.
12.4. Prize-fulfilment providers, travel providers, event organisers or other service providers may receive the minimum information necessary to arrange or deliver the relevant prize or participation. Additional promotion-specific terms or privacy information may be provided where a particular activity requires materially different processing.
12.5. This section is intentionally general and applies to Alpha Affiliates competitions and promotions from time to time; the permanent Privacy Policy does not need to identify any particular campaign by name.
13.1. We may update this Privacy Policy from time to time to reflect changes in the Affiliate Programme, our processing activities, technology, service providers or applicable legal requirements. The current version will be published on the Alpha Affiliates website with an updated revision date. Where appropriate, we may provide additional notice of material changes.
13.2. This Privacy Policy is prepared in English. If a translated version conflicts with the English version, the English version will prevail to the extent permitted by applicable law. This Policy does not govern processing independently carried out by third-party websites or participating brand operators.
14.1. Any questions or comments about this Privacy Policy can be submitted by mail to the address below or by email to legal@alpha-affiliates.com. To ensure the prompt response please type ‘ATTN: DPO’ in the subject line of the email. You can also contact your local Data Protection Authority or another appropriate authority.
14.2. If you have any legal complaints that cannot be or are not resolved by negotiating with us, you have the right to lodge a complaint with the Data Protection Authorities. Such authorities will expect that you have raised your concerns directly with us to try and resolve in a reasonable time period before escalating the matter.