The section of the Site is owned and operated by Fairdos Online Services Limited Reg No. C387234, having registered address at Achilleos, 21 Flat/Office B, Agios Dometios 2370, Nicosia, Cyprus

When this policy mentions “we”, “us”, “our”, all of the following terms refer to Fairdos Limited and our associated companies.

The Data Protection Officer is responsible for data protection. You can contact by emailing at [email protected]

We may update, amend or modify this policy from time to time. Any change in this policy will depend on current and future applicable data protection laws, business requirements and any modification to this website including the addition of new features.

This policy was last updated on 27/01/2022

This privacy policy aims to give you information regarding how we collect and processes your personal data through your use of the website, including any data you may provide through this website when you register an account.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions, when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

We process your personal data in line with current applicable legislation

If you are located overseas, your personal data will also be processed in line with the above regulations and regardless of your geographical location.

Under the General Data Protection Regulation, consent should be given in a positive and affirmative way by individuals who share their personal data with organisations. According to the European Data Protection Directive, consent means: “any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed.”

When you submit your personal data on the website to become a Profiliate partner, you must accept the terms and condition agreement. Your data will be retained according to our data retention policy, and it will only be processed for the purposes that we have detailed in section 6 of this policy.

We gather a certain amount of personal data from the website. The data that you submit to us on the “Join” section when you decide to become a Profiliate partner. In order to become a Profiliate partner, we have a business requirement to collect and process the following data:

Account information:

• Website account
• First name
• Last name
• Affiliate / business name
• Email address
• Country dial code
• Contact number
• Skype or other online communication platforms
• Full address
• City
• Zip code
• Country
• Preferred language

Payment Details:

• Payee name
• Payment method
• Bank name
• Swift/BIC
• IBAN

Login details:

• Username
• Password

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Due to our regulatory requirements, we will collect information about criminal convictions and offences as part of our PEP and sanction procedures. We may also refer information to third party companies for the purpose of crime prevention. This information is only shared for the purpose of our regulatory requirements and fraud prevention.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. In this case, we may have to close your account you have with us, but we will notify you if this is the case at the time.

• Contact you with regards to the query you have submitted
• Contact you because you have requested a callback name
• Create a partner account with the data that you have submitted on the “Join” section of the website
• Administer your account and troubleshoot any issues
• Issue you commission payments in line with our agreement
• Contact you with regards to our agreements

The data that you have submitted to us will never be sold to third parties, marketing or analytics companies or used for any other purposes than those listed in this section.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused partnership.

Before we provide services to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information and device identifiers including IP address.

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the partnership.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

Should any of the above purposes change, we will update this section accordingly and indicate the date of the when the update was done in Section 1 of this policy.

We share your personal data with third parties. This may involve transferring some of your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we will ensure personal data has a similar degree of protection that it would have in Europe.

We use the services of various third parties and service providers for our business operations. We have carefully conducted our due diligence to ensure that those third parties are compliant with current applicable data protection legislations and that they have implemented appropriate organisational and technical controls to safeguard your data. Those third parties will only process your data according to our directions that we have provided them as the “data controller”.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We have implemented a number of organisational and technical controls to ensure that the confidentiality, the integrity and the availability of your data is always safeguarded.

Our staff members are aware of the current data protection laws and we ensure that best security practices are always followed. All our systems processing data are protected with antivirus and firewall protection. We have implemented different levels of access for our systems to ensure that access to data is restricted to authorised staff only. All our datasets are regularly backed up to ensure that they are available in the event of a technical issue or disaster recovery. This website has an SSL certificate installed to ensure that network communications are encrypted and to avoid any interception of data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Should you require to exercise any of your legal rights as per above, then you should contact us via email at: [email protected]

Should you wish to make a Subject Access Request you should contact us in writing at: Subject Access Request via email at: [email protected]

You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible. Under the GDPR, we may charge an ‘reasonable fee’ for the administration costs for processing such requests. This administration fee is to cover the cost and time involved with gathering the relevant data and administration services such as photocopying and postage and will be no more than £10.

We may reject requests for disclosure or deletion of your information that are unreasonable or extremely impractical such as it requires a disproportionate human or technical effort or require significant changes to our processes and technology and impact our ability to provide the services.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law to maintain our compliance with AML regulations we are required to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period of at least five years after the relationship with the customer has ended. The date the relationship with the customer ends is the last date on which they visit or use our services.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

A “cookie” is a small text file that is downloaded onto your access device when you visit a Website and that enables the website to obtain certain information from your browser which include your preferences. All Websites and game apps including the game launcher which are operated by In Touch Games use cookies and similar technologies to manage login sessions, provide personalised web pages to tailor advertising and other content to reflect your specific needs and interests. A cookie does not harm your access device nor does it contain any viruses or other malware.

Your browser also generates other information, including which language the website is displayed in, and your Internet Protocol address (“IP address”). An IP address is a set of numbers which is assigned to your computer during a browsing session whenever you log on to the internet via your internet service provider or your network (if you access the internet from, for example a computer at work). Your IP address is automatically logged by our servers and used to collect traffic data about visitors to our website. We also use your IP address to help diagnose problems with our server, and to administer our website.

We also use cookies that obtain information about your device, these include Your IP address, device type, geo-location data and browser information. This information is used to help us identify you for fraud prevention and to detect prohibited practices that might affect your customer experience. Please note we only receive data from your access device when you are logged into your account.