Version 3 – 01st of October 2023
Data Protection Laws have been put together to protect your privacy and personal data of.
The provision of your personal data in accordance with this Policy and the Agreement is a precondition for us to be able to enter into the Agreement with you as an Affiliate. Failure to provide the personal data requested prevents us from entering into the Agreement for the products and services requested by you.
1. Data Controller
The data controller is Azure Marketing Services BV, whose registered address is at Korporaalweg 10, Willemstad, Curacao (hereinafter (“AMS”/“Azure Affiliates”/“us”/“we”).
“Affiliate Program Site” means the website at https://azure-affiliates.com/.
“Agreement” means the affiliate agreement entered into by yourself with Azure Affiliates.
“AML” mean Anti-Money Laundering.
“CFT” means Combating the Financing of Terrorism.
“Company” means WCG B.V., a company licensed and regulated by the laws of Curaçao under the Master Gaming License 8048/JAZ and with registration number 152285, located at Korporaalweg 10, Willemstad, Curaçao, which is the B2C operator offering online products to end-users via an Internet website that partners with the Affiliate through the Azure Program to promote its brand/s, products and services as available via its Property Site www.lucky8.com.
“Data Protection Laws” refer to the EU General Data Protection Regulation (EU2016/679) (the “GDPR”), the Data Protection Act (Cap 440 of the Laws of Curacao) and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and all applicable laws and regulations relating to the processing of personal data and/or privacy in effect in any relevant territory and as updated from time to time.
“Data subject” means you as an Affiliate participating in the Azure Affiliates affiliate program.
“EEA” means European Economic Area.
“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"Us”/”we”/”our” means Azure Affiliates and its Group Companies.
“You”/”your” means you in your capacity as an Affiliate, and any Sub-Affiliates which you may engage pursuant to the Agreement.
3.1. A reference to a ‘person’ includes any individual, firm, company, corporation, government entity or body corporate (whether or not having separate legal personality and irrespective of the laws of the jurisdiction in or under which it was incorporated or exists).
3.2. A word importing one gender shall (where appropriate) include any other gender and a word importing the singular shall (where appropriate) include the plural and vice versa.
3.3. Any statute or statutory provision includes, except where otherwise stated, the statute or statutory provision as amended, consolidated or re-enacted from time to time before or after the date of this Agreement and includes any subordinate legislation made under the statute or statutory provision (as so amended, consolidated or re-enacted) before or after the date of this Agreement.
3.4. The headings in this Agreement are for convenience only and do not affect its interpretation.
3.5. Unless otherwise defined herein, terms in this Policy shall have the same meaning as the Agreement.
3.6. This Policy shall be considered an integral part of the Agreement and in the case of conflict, the provisions of the Agreement shall prevail.
4. How we use your information
This privacy notice tells you how we will collect and use your personal data.
Upon registration you should provide your personal and financial details. Any data stored here will be provided by you voluntarily and we do not use your contacts for marketing purposes.
The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
5. What personal data is collected?
5.1. Personal data you have provided: We collect information that you provide when submitting your Application and subsequently using use the services offered by Azure Affiliates. We require the following information in order to enter into the Agreement and we are not in a position to approve your Application without the following information:
5.1.1. Contact information:
22.214.171.124. If you are a legal person:
126.96.36.199.1. Company Name;
188.8.131.52.2. Company registration number;
184.108.40.206.3. Company registered address;
220.127.116.11.4. Contact person name;
18.104.22.168.5. Contact person spoken language;
22.214.171.124.6. Contact email address;
126.96.36.199.7. Contact telephone number.
188.8.131.52. If you are an individual:
184.108.40.206.1. Your full name, as appearing on official identification documents;
220.127.116.11.2. Your full residential address;
18.104.22.168.3. Your email address;
22.214.171.124.4. Your telephone number;
126.96.36.199.5. Spoken language
5.1.2. Financial information: we collect your banking details and transactional information for effecting transaction payments. We also collect the following information:
188.8.131.52. VAT number;
184.108.40.206. Bank Branch, Bank Country, Bank City;
220.127.116.11. Neteller Email, Skrill Email;
18.104.22.168. Bitcoin Wallet, Ethereum Wallet.
5.1.3. Due to AML/CFT and other legal requirements (such as KYC), we will at times ask you for supplementary documents such as identification and verification documents regarding your source of wealth, proof of address and others as may be deemed necessary in view of the said legal requirements.
5.2. Information we receive from third parties: We may combine the personal data you provide with information that we receive about you from other sources, such as public databases, providers of demographic information and other third parties, in view of legal and regulatory requirements, such as KYC. Such information is collected only when it is reasonably necessary.
5.3. Information collected automatically: We and our third-party service providers may collect information automatically from your device in a variety of ways, including but not limited to, information collected through your browser or device, such as your IP, device type, language and the Internet browser type you are using when accessing the Affiliate Program Site and use the Tracking Links provided to you by virtue of the Agreement. We use this information to ensure that our services function properly.
6. How do we collect your personal data?
We collect your personal data when you submit your Application and when you enter into the Agreement with Azure Affiliates. We also collect information when you use the Affiliate Program Site and our products and services, including the Tracking Links. Your personal data is also collected when we interact with you for any reason, including when you contact us.
We will only process personal data as set out in this Policy.
7. Storing your personal data
We will only store your personal data for as long as it is needed to fulfil the following objectives:
• As may be necessary for us to fulfil our contractual obligations (in view of the Agreement entered into);
• As may be necessary for us to facilitate product development and to operate, maintain and improve our products and services, including the Affiliate Program Site;
• As required by applicable law, including AML/CFT, fraud, and data retention requirements.
Your personal data will be permanently erased from our systems when we are finish processing your personal data for the purposes stated in this Policy.
8. Legal basis for processing your personal data
Any processing of your personal data will be carried out in accordance with this Policy and the provisions of the Agreement, namely:
• for the performance of or entering into the Agreement;
• for compliance with our legal and regulatory requirements;
• on the basis of your consent to process your personal data, including communicating with you about our services and other marketing;
• for our legitimate interests, including the improvement of our products and services (including the Affiliate Program Site), for our operations, and to provide customer service as needed (including liaising with the Companies whose products and services you promote by virtue of the Agreement). This also extends to the protection against fraud and ensure the physical and IT security of Azure Affiliates, the Affiliate Program Site and that of our partners and Companies, also to ensure the management of any dispute arising between us or with third parties
9. Transferring your personal data
We will not transfer or sell your personal data to a third party without your explicit consent, unless as specified below:
• to Azure Affiliates’ Group Companies, as well as professional consultants and service providers, including accounting firms and legal advisers;
• to employees, agents, subcontractors, business partners, auditors, financial and payment institutions, vendors, suppliers and providers of IT, technology services and analytics tools who assist with our business activities;
• to the Company making use of your services by virtue of and following the acceptance of your Affiliate Application, as per the AMS Azure Affiliates Program Agreement;
• to comply with legal requirements, such as a request from a competent authority.
We assure you that the transfer of personal data is carried out in compliance with legal requirements, including data processor agreements where relevant, to ensure that data is not processed for other purposes than clearly stated and to ensure adequate security measures.
Your personal data may be transferred to and stored at a destination outside the EEA, in which case we will ensure an adequate level of security by transferring to countries approved by the EU Commission as having an adequate level of protection, or by entering into an appropriately-drafted contract (such as the standard data protection clauses adopted by the European Commission) to ensure that the entity receiving the data is compliant with Data Protection Laws.
10. Why do we need process your personal data?
In order for us to provide you with our services and for the fulfilment of the Agreement entered into, we need to collect personal data for the following purposes at any one time:
• to review your Application and approval as an Affiliate with Azure Affiliates;
• to provide you with our products and services in fulfilment of the Agreement you have entered into to enable you to act as an Affiliate;
• to provide customer service, including answering your questions or complaints,
• to communicate with you about changes to our products and services and mutual business aspects, including promotions and other news, in accordance with your marketing consent. We will not use your personal data for direct marketing purposes unless you have specifically consented hereto;
• for financial reasons, including, review of invoices issued and legal obligations regarding financial transactions, as well as liaison with financial and payment institutions;
• to keep track of your performance as an Affiliate;
• to comply with our legal obligations and for establishing, exercising or defending legal rights.
We are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute a breach of Data Protection Laws.
11. Can I find out the personal data that Azure Affiliates holds about me? What are my rights?
At your request, you have the following rights in accordance with Data Protection Laws, although some of the rights may only apply under certain circumstances as described by law:
• the right to be informed about the information that we hold about you and how it is processed;
• the right to obtain a copy of the personal data that we have collected;
• the right to update or amend the personal data we have collected about you if it is inaccurate or incomplete;
• the right to erase, or restrict the processing of, the personal data we have collected about you;
• the right to transmit a copy of your personal data to another data controller, where possible. The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services. This right only applies when the lawful basis for processing this information is consent or contract, or when the information is processed by automated means;
• the right to object to the processing of the personal data we have collected about you, including any processing for direct marketing purposes;
• the right to withdraw any consent you have provided in respect of your personal data.
We only keep your personal data for the periods corresponding to the purpose for which it is collected, in particular in order to provide you with the services associated with your Application and Agreement with Azure Affiliates and to comply with our legal obligations, in particular in terms of AML/CFT, or to assert one of our rights.
We will ensure that appropriate security measures, such as technical and organisational, physical, electronic, and procedural policies and safeguards, are implemented to protect your personal data against unauthorized or unlawful processing and against accidental loss, damage, destruction, alteration or disclosure.
We also limit access to the personal data to employees and third parties on a need to know basis depending on who reasonably needs to process such data in accordance with this Policy and the Azure Affiliates Agreement you have entered into.
In the event of unauthorized use of your credentials, you must immediately notify us.
13.1. Cookies are small pieces of data, stored in text files, that are stored in your browser when you visit websites. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They are essential to keep certain parts of our site running correctly and securely. They are also used to personalise your online experience to make it more relevant to you and also to provide usage data back to us. They can also be used to present you with more tailored advertising content. For them to work as required, some personal information must be used from you when you use our site. You can choose whether to accept or reject some or all types of cookies and control this through your device’s browser settings and we also make you aware of this by showing you our cookie banner when you visit our site.
13.3. By using the Affiliate Program Site without restricting them in your browser, the types of cookies we use are outlined below:
13.3.1. Necessary and Functionality Cookies: These cookies are essential for you to navigate the site correctly and log in to the secure areas. They also enable us to deliver content specific to your device. These cookies allow our websites to remember choices you have made, such as your username or region. They help us keep you logged into your account as you navigate around our website. We also use them to personalise your experience by, for example, showing more relevant onsite content. Without these cookies you may not be able to access your account so they are vital to keep the site functioning as intended.
13.4. Controlling my cookies
• http://www.aboutcookies.org/ (contains information about cookies on a wide variety of desktop browsers.)
• Cookie settings in Internet Explorer/Edge
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS
If you disable cookies, please be aware that some of the features of our services may not function correctly.
14. Policy Updates
Azure Affiliates reserves the right to update this Policy from time to time. You will be notified at least 5 Business Days in advance via email in case of any changes made to this Policy, where appropriate. If you do not accept the changes within the deadline stated in the email, you have the right to terminate your Affiliate Agreement in accordance with the provisions thereof.
15. Contact Details
If you have any questions about this Policy, its implementation, your personal information or the use of the information collected, you may contact us using the following email: [email protected]