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Terms And Conditions

Privacy Policy

Terms And Conditions

Affiliate Program Terms & Conditions

Bet267 Botswana — Hybrid CPA + Net Gaming Revenue (NGR) Share

These Affiliate Program Terms & Conditions (the “Agreement”) govern participation in the Bet267 affiliate Program (the “Program”). By applying to join, clicking “Accept”, signing a Commercial Terms schedule, or continuing to promote Bet267 using tracking links or approved marketing materials on or after the effective date, you (“Affiliate”, “you”, “your”) agree to be legally bound by this Agreement. This renewed Agreement replaces all prior versions.

1.  Definitions

1.1  "Account" means your affiliate account and profile created within the Program portal or otherwise approved by Bet267.

1.2  "Affiliate Site(s)" means any website, app, social media account or page, messaging channel, email list, media placement, or other traffic source you use to promote Bet267.

1.3  "Approved Marketing Materials" means creatives, links, landing pages, text, banners, logos, promo codes, and any other materials provided or expressly approved in writing by Bet267.

1.4  "Bet267", "Company", "we", "us", or "our" means the licensed operator trading as Bet267 in Botswana under licence PIL2467.

1.5  "Commercial Terms" means the schedule of commercial parameters (including commission rates, the Revenue Share Window, affiliate tier, renewal performance thresholds, support entitlements and payout details) confirmed by Bet267 in writing or set out in Schedule 1, as updated from time to time.

1.6  "Confidential Information" means all non-public information disclosed by Bet267 (including commission terms, reports, conversion data, player metrics, technical documentation, tracking logic, compliance notes, commercial terms, and business plans), whether marked confidential or not, that a reasonable person would understand to be confidential.

1.7  "CPA" means a one-off Cost Per Acquisition commission payable for a Qualified Player meeting the CPA Qualification Criteria in clause 8.3.

1.8  "Duplicate Player" means a person who already has (or previously had) a Bet267 account or is otherwise identified by Bet267 systems as an existing user, regardless of whether they register again using different details.

1.9  "FTD" means First Time Deposit: the first successful deposit made by a new registered player into a Bet267 wallet or account using a valid payment method and accepted by Bet267 (excluding reversed, refunded, charged-back, or fraudulent deposits).

1.10  "Fraud" / "Fraudulent Activity" includes (without limitation) fake registrations, identity manipulation, bonus abuse, collusion, chip-dumping, arbitrage abuse, use of bots, stolen payment methods, chargeback abuse, money-laundering indicators, incentivised sign-ups (unless expressly approved), or any activity Bet267 reasonably suspects is not genuine or is intended to improperly obtain commissions.

1.11  "Gross Gaming Revenue (GGR)" means, in respect of Referred Players, the total value of settled stakes or wagers minus winnings paid out, as recorded by Bet267.

1.12  "Net Gaming Revenue (NGR)" means, for Revenue Share purposes, GGR less the allowable deductions and adjustments set out in clause 8.4.

1.13  "Initial Term" means the two (2) year period referred to in clause 11.1.

1.14  "Renewal Term" means each successive twelve (12) month period for which the Agreement is renewed under clause 11.2.

1.15  "Performance Review" means Bet267’s assessment of an Affiliate against the renewal criteria in clause 11 and the thresholds in the Commercial Terms.

1.16  "Quality Score" means Bet267’s composite 0–100 measure of affiliate performance (combining player value, retention, hold percentage and genuine new-depositor flow), as defined in the Commercial Terms.

1.17  "Affiliate Tier" means the management tier assigned to you by Bet267 (for example Standard, Growth, High Performer, or VIP/Strategic) as recorded in your Account or Commercial Terms.

1.18  "VIP / Strategic Affiliate" means an Affiliate designated by Bet267 for dedicated relationship management and enhanced support under clause 9.

1.19  "Qualified Player" means a Referred Player who satisfies the CPA Qualification Criteria in clause 8.3.

1.20  "Referred Player" means a person who accesses Bet267 through your Tracking Link and registers an account in accordance with Bet267 onboarding rules.

1.21  "Revenue Share Window" means the period defined in clause 8.5 during which Revenue Share accrues on a Referred Player’s NGR.

1.22  "Tracking Link" means a unique URL or tracking method assigned to you by Bet267 to attribute Referred Players and activity.

1.23  "Territory" means the Republic of Botswana only, unless Bet267 confirms in writing that you may target additional jurisdictions.

1.24  "Applicable Law" means all laws, regulations, directives, licence conditions, and codes applicable to gambling, advertising, consumer protection, privacy, and financial-crime compliance in the Territory.

2.  Order of Precedence & Commercial Terms

2.1  This Agreement is read together with the Commercial Terms applicable to you. The Commercial Terms record the specific commercial parameters of your participation, including rates, the Revenue Share Window, your Affiliate Tier, renewal thresholds, support entitlements, and payout details.

2.2  If there is any conflict between this Agreement and the Commercial Terms on a commercial parameter, the Commercial Terms prevail to the extent of that conflict. On all other matters, this Agreement prevails.

2.3  Bet267 may update the Commercial Terms from time to time in accordance with clause 21, and the current Commercial Terms (including Schedule 1) form part of this Agreement.

3.  Regulatory & Licensing Compliance (Botswana)

3.1  Bet267 is licensed to conduct gambling operations in Botswana and must comply with Applicable Law and its licence conditions, including the requirements of the Botswana Gambling Authority (BGA).

3.2  You must comply with all Applicable Law and all Bet267 compliance requirements communicated to you from time to time, including advertising and promotion restrictions, responsible-gambling messaging, and the prohibition on targeting persons under 21.

3.3  Gambling advertising in Botswana is permitted only within legal boundaries. Your promotion must not be false or misleading, must not target or attract minors, must include responsible-gambling messaging as required, and must not be placed at or near sensitive facilities (for example schools, hospitals, or places of worship). Bet267 may require you to amend or remove any content to ensure compliance.

3.4  Bet267 may suspend, withhold, or terminate your participation immediately where required for regulatory or licensing reasons.

4.  Eligibility, Application & Affiliate KYC

4.1  To participate, you must:

(a) be at least 21 years old;

(b) have legal capacity to enter into this Agreement;

(c) provide accurate, complete, and up-to-date information; and

(d) be approved by Bet267 at its sole discretion.

4.2  Affiliate KYC and due diligence: you agree to provide documentation Bet267 reasonably requests for compliance and risk management, which may include:

(a) national ID or passport, selfie/liveness checks (if required), and proof of address;

(b) company registration documents (if you are an entity), director/shareholder details, and authorised-signatory proof;

(c) bank account or mobile-money verification details for payouts;

(d) tax identification details (where applicable); and

(e) source/traffic descriptions and marketing-method disclosures.

4.3  Bet267 may reject any application or require additional checks without giving reasons, and may re-verify your details periodically.

5.  Relationship of the Parties

5.1  You act as an independent contractor. Nothing in this Agreement creates a partnership, joint venture, agency, or employment relationship.

5.2  You have no authority to bind Bet267, make representations on its behalf, or offer guarantees to players.

6.  Marketing Rules

6.1  General conduct: you must market Bet267 in a legal, honest, and responsible manner, and must not harm Bet267’s reputation.

6.2  Prohibited conduct (non-exhaustive):

(a) targeting or attracting minors (under 21) or vulnerable persons;

(b) misleading claims (for example “guaranteed wins”, “risk-free”, “free money”);

(c) encouraging excessive gambling or presenting gambling as a solution to financial problems;

(d) spam (unsolicited bulk messaging or emailing) or unlawful data collection;

(e) impersonating Bet267 or creating confusion that your site or page is Bet267-owned;

(f) using copyrighted material you do not have rights to use;

(g) promoting Bet267 outside the Territory without written approval; and

(h) incentivised traffic (paying users to sign up, sharing commissions with players, cashback-for-sign-up schemes) unless Bet267 approves in writing.

6.3  Mandatory disclosures and responsible gambling: you must display responsible-gambling and age-restriction messaging as Bet267 provides or requires, including any specific wording, placement, or format.

6.4  Pre-approval and takedown: Bet267 may require pre-approval of any campaign or content and may require immediate modification or removal of any content at any time.

7.  Referred Players & Qualified Players

7.1  A person becomes a Referred Player when they register a new Bet267 account through a valid Tracking Link and are not a Duplicate Player.

7.2  A Referred Player becomes a Qualified Player for CPA purposes only when they meet the CPA Qualification Criteria in clause 8.3, including KYC completion, cumulative deposits, and minimum wagering on settled bets.

7.3  Bet267’s systems are the final authority for attribution and for determining whether a player is a Referred Player or a Qualified Player, including where Bet267 reasonably suspects abuse.

8.  Commissions (Hybrid Model: CPA + NGR Revenue Share)

8.1  Commission model. You may earn (i) a one-off CPA payment for each Qualified Player, and (ii) an ongoing Revenue Share based on the NGR generated by your Referred Players, as set out below and subject to the Commercial Terms confirmed by Bet267 in writing.

CPA — One-Off Payment

8.2  CPA amount. Bet267 will pay a one-off CPA of BWP 20 (twenty pula) for each Qualified Player attributed to you, unless a different amount is stated in your Commercial Terms.

8.3  CPA Qualification Criteria. A Referred Player is a Qualified Player for CPA purposes only if all of the following are satisfied:

(a) the player registers a new Bet267 account using a valid Tracking Link and is not a Duplicate Player;

(b) the player successfully completes Bet267 KYC/identity verification to Bet267’s satisfaction;

(c) the player makes cumulative deposits of at least BWP 100 (net of any failed, reversed, refunded, or charged-back deposits);

(d) the player places cumulative settled wagers of at least BWP 50 (voided, cancelled, or cashed-out bets may be excluded at Bet267’s discretion); and

(e) the player’s activity is not flagged as Fraudulent Activity, abuse, or any other breach of this Agreement or Applicable Law.

8.4  No “deposit-and-withdraw” qualification. A Referred Player will not be treated as a Qualified Player (and CPA will not be payable) where Bet267 reasonably determines the activity is not genuine or is intended to generate commission without bona fide gameplay, including where the player withdraws 80% or more of cumulative deposits within 48 hours, fails to meet the settled-wager requirement using deposited funds, or engages in rapid deposit/withdrawal cycling, wallet parking, payment-method testing, or collusion. In such cases Bet267 may decline, reverse, or claw back CPA and related commission, including by set-off.

8.5  CPA payment timing. CPA becomes payable only after the player satisfies the full Qualified Player criteria and after completion of Bet267’s standard risk and compliance checks. Bet267 may delay CPA while verification or investigation is in progress.

Revenue Share on NGR

8.6  NGR definition. For Revenue Share purposes, NGR means GGR attributable to your Referred Players less, to the extent attributable to such players or activity and as recorded in Bet267’s systems: (a) bonuses, free bets, cashback, free spins, promotional credits and other player-incentive costs; (b) payment-processing, collection, gateway and transaction fees; (c) chargebacks, refunds, reversals, fraudulent activity and other disqualified activity; and (d) gaming taxes, duties, levies, or similar statutory charges. NGR is calculated before deduction of affiliate commission.

8.7  Revenue Share rates (tiered, monthly). You earn Revenue Share on NGR attributable to your Referred Players at the following tiered rates, calculated monthly on the number of Qualified Players generated in that month (unless your Commercial Terms state otherwise):

(a) Tier 1 — 1 to 25 Qualified Players/month — 12% of NGR;

(b) Tier 2 — 26 to 75 Qualified Players/month — 13% of NGR;

(c) Tier 3 — 76 to 200 Qualified Players/month — 15% of NGR; and

(d) Tier 4 — 201+ Qualified Players/month — 17% of NGR.

8.8  Revenue Share Window (24 months). Revenue Share is payable on a Referred Player’s NGR for a maximum lifetime window of twenty-four (24) months from the date the player first registers a Bet267 account (or such other start date Bet267 confirms in writing). After the 24-month window ends, no further Revenue Share accrues for that player. This window replaces the previous twelve (12) month window.

8.9  Final authority. Bet267’s tracking systems and internal records are the final authority for attribution, NGR calculation, and commission determination, subject to Applicable Law.

Negative Carryover

8.10  Standard policy: Bet267 applies no negative carryover at the affiliate-account level. If your aggregate NGR for a month is negative, it is treated as zero for that month and does not roll forward.

8.11  High-roller exception: Bet267 may apply player-level negative carryover only for high-roller players identified using objective internal criteria, offsetting that player’s negative NGR only against that same player’s future positive NGR (never against other players), with notice to you where applied.

Settlement

8.12  Monthly settlement. All commissions (CPA and Revenue Share) are calculated and settled monthly, following month-end reconciliation, verification, and standard risk and compliance checks. Bet267 is committed to timely, predictable payouts in line with the Commercial Terms.

8.13  Payment holds / set-off. Bet267 may withhold, delay, reverse, claw back, or set off commission where fraud checks, chargebacks, refunds, disputes, regulatory requirements, or breaches are reasonably suspected or confirmed, including by set-off against future amounts payable.

9.  Affiliate Tiers & Program Support

9.1  Affiliate Tiers. Bet267 operates a tiered Program (for example Standard, Growth, High Performer, and VIP/Strategic). Your Tier is recorded in your Account or Commercial Terms and may change at a Performance Review based on your performance and Quality Score.

9.2  Program support. Bet267 supports affiliates with Approved Marketing Materials, campaign guidance, and a clear progression path. The relationship is intended to be balanced: Bet267 provides visibility and tools; you deliver genuine players and responsible promotion.

9.3  VIP / Strategic support. Enhanced support — which may include dedicated relationship management, branded merchandise, event access and hosting, co-marketing, and bespoke commercial arrangements — is reserved for VIP/Strategic Affiliates as set out in their Commercial Terms. Bet267 monitors the concentration of Revenue Share across affiliates and may manage exposure accordingly.

10.  Term, Renewal & Performance Review

10.1  Initial Term. Unless terminated earlier under this Agreement, your participation runs for an Initial Term of two (2) years from the date Bet267 approves you (for existing affiliates, from the migration date notified by Bet267). The Initial Term gives qualifying affiliates a committed multi-year relationship.

10.2  Annual renewal. After the Initial Term, this Agreement renews automatically for successive Renewal Terms of twelve (12) months each, provided you meet the renewal criteria below at the relevant Performance Review. Renewal is granted one year at a time.

10.3  Renewal criteria. Renewal of each Renewal Term is subject to your satisfying Bet267’s performance criteria, being (in summary): (a) your Referred Players are net-positive to Bet267 (positive net revenue); (b) a clean payout profile (withdrawals not exceeding deposits and no abusive patterns); (c) a sustained Quality Score and player retention at or above the threshold in the Commercial Terms; and (d) a clean clawback and compliance record. The applicable numeric thresholds are set out in the Commercial Terms.

10.4  Performance Reviews. Bet267 will assess performance against the renewal criteria at least every six (6) months and at each renewal date, and will give you reasonable visibility of your standing.

10.5  Non-renewal. If you do not meet the renewal criteria, your enhanced/longer terms will not renew; you are not penalised, but revert to a standard rolling term (terminable on 7 days’ written notice by either party) with a clear, supported path to requalify at a later Performance Review.

10.6  Migration of existing affiliates. Existing affiliates approved before the effective date are migrated onto this Agreement. Continued participation (including continued promotion or use of Tracking Links) on or after the date notified by Bet267 constitutes acceptance of this Agreement and starts the Initial Term.

10.7  Immediate suspension or termination. Notwithstanding the Initial Term and any Renewal Term, Bet267 may suspend or terminate immediately if you breach this Agreement; Bet267 reasonably suspects Fraud or non-compliance; this is required by law, regulator, or licence conditions; or you engage in conduct that may bring Bet267 into disrepute.

10.8  Effects of termination. On termination you must stop all promotions, remove Approved Marketing Materials and Bet267 marks, cease using Tracking Links, and return or delete Confidential Information where applicable. Legitimate, non-disputed commissions may be paid after final reconciliation, subject to clawback, chargebacks, and compliance verification.

11.  Payments, Thresholds & Taxes

11.1  Payment frequency: monthly, following month-end reconciliation.

11.2  Minimum payout threshold: BWP 100 (or such other threshold shown in your Account or Commercial Terms).

11.3  Payment methods: bank transfer and/or approved mobile-money methods, subject to successful Affiliate KYC and verified payout details.

11.4  Taxes: you are responsible for your own taxes, duties, or reporting obligations arising from commissions paid to you.

11.5  Withholding / delays: Bet267 may delay or withhold payment while investigating suspected Fraud, compliance breaches, chargebacks, or regulatory issues.

12.  Tracking, Attribution & Disclaimers

12.1  Tracking basis: unless stated otherwise, attribution is on a last-click basis using Tracking Links and cookie/device attribution logic implemented by Bet267.

12.2  Cookie window: unless stated otherwise in your Account, the standard referral window is 30 days from the initial click; Bet267 may adjust windows for specific campaigns.

12.3  Cross-device / cross-channel: tracking may not always function across devices, browsers, deleted cookies, ad blockers, private browsing, or network restrictions. Bet267 does not guarantee uninterrupted or error-free tracking.

12.4  Final authority: Bet267’s tracking and internal records are the final authority for attribution and commissions, subject to good faith and Applicable Law.

13.  Fraud, Investigations, Audit Rights & Clawbacks

13.1  Bet267 may investigate any suspected Fraud, abuse, or compliance breach.

13.2  Information requests / audit: you agree to provide prompt cooperation and access to traffic-source information, campaign data, ad accounts (view-only where possible), and any records needed to verify compliance.

13.3  Clawback rights: Bet267 may reverse, deduct, or claw back commissions (including previously paid commissions) where a player is later determined to be non-genuine, fraudulent, a Duplicate Player, or otherwise disqualified; deposits are charged back, refunded, or reversed; you breach this Agreement or Applicable Law; or traffic is incentivised or manipulated without written approval.

13.4  Set-off: Bet267 may set off any clawback amounts against future commissions payable to you.

14.  Anti-Money Laundering, Anti-Bribery & Sanctions

14.1  AML alignment: you must not engage in any activity that facilitates money laundering, terrorist financing, or proceeds of crime, and must immediately notify Bet267 of any suspicious activity related to your traffic or promotions.

14.2  No bribery or corruption: you must not offer, promise, give, request, or accept any improper advantage (including bribes, kickbacks, or facilitation payments) in connection with Bet267 or the Program.

14.3  Sanctions: you must not target sanctioned persons or facilitate activity that would expose Bet267 to sanctions or regulatory risk.

15.  Brand Usage Guidelines (Territory-First)

15.1  Limited licence: Bet267 grants you a limited, revocable, non-exclusive, non-transferable licence to use Approved Marketing Materials solely to promote Bet267 in the Territory during the term.

15.2  No ownership: all Bet267 brand assets and intellectual property remain Bet267’s exclusive property.

15.3  Territory restriction: you may not run campaigns outside Botswana or target users outside Botswana unless Bet267 approves in writing.

15.4  No confusing use: you must not register domains or social handles containing “Bet267” (or confusingly similar variants), create pages that appear official, copy the look and feel of Bet267 properties, or imply you are Bet267 or endorsed beyond the affiliate relationship.

15.5  Search & keywords: you must not bid on Bet267 branded terms or misspellings in paid search, nor use Bet267 marks in ad copy or URLs, unless Bet267 approves in writing.

15.6  Content standards & takedown: your content must be lawful, professional, and not offensive, discriminatory, obscene, or misleading. Bet267 may require immediate changes or removal of any use of brand assets or any campaign.

16.  Confidentiality

16.1  You must keep Confidential Information strictly confidential and use it only to perform under this Agreement.

16.2  You must not disclose Confidential Information to third parties except to professional advisers under confidentiality obligations or as required by law.

16.3  On termination, you must stop using and (where applicable) delete Confidential Information, except where retention is required by law.

17.  Data Protection & Privacy

17.1  You must comply with Applicable Law relating to privacy and electronic marketing.

17.2  You must not collect, store, sell, or share player personal data unless expressly authorised by Bet267 and legally permitted.

17.3  Where you use email, SMS, or WhatsApp marketing, you must maintain lawful consent and opt-out mechanisms where required.

18.  Limitation of Liability & Indemnity

18.1  Limitation: to the fullest extent permitted by law, Bet267 is not liable for indirect or consequential losses, loss of profit, or loss of business.

18.2  Cap: Bet267’s aggregate liability to you under this Agreement will not exceed the commissions actually paid to you in the preceding three (3) months.

18.3  Indemnity: you indemnify Bet267 against claims, losses, fines, or liabilities arising from your marketing activities, breach of this Agreement, or violation of Applicable Law.

19.  Force Majeure

19.1  Neither party is liable for failure or delay caused by events beyond reasonable control, including network failures, platform outages, acts of God, war, civil unrest, labour disputes, governmental actions, or regulatory restrictions. Obligations resume once the event ends.

20.  Governing Law & Dispute Resolution

20.1  This Agreement is governed by the laws of the Republic of Botswana.

20.2  The parties will first attempt to resolve disputes in good faith through written escalation.

20.3  If unresolved, disputes will be submitted to the courts of competent jurisdiction in Botswana, unless the parties agree in writing to an alternative dispute-resolution process.

21.  General

21.1  Amendments: Bet267 may update this Agreement or the Commercial Terms from time to time by publishing an updated version on its website or affiliate portal. Continued participation constitutes acceptance.

21.2  Assignment: you may not assign or transfer your rights or obligations without Bet267’s prior written consent.

21.3  Severability: if any provision is held invalid, the remaining provisions remain in full force.

21.4  Entire agreement: this Agreement together with the Commercial Terms constitutes the entire agreement between the parties on its subject matter and supersedes all prior versions and understandings.

21.5  Notices: Bet267 may give notice via the affiliate portal, email, or other channel on record for you.

22.  Acceptance

By clicking “Accept”, signing the Commercial Terms, or continuing to promote Bet267 on or after the effective date, you confirm that you have read, understood, and agree to be bound by this Agreement and the applicable Commercial Terms.

Schedule 1 — Commercial Terms (Summary)

The following commercial parameters apply to the Program. Bet267 may issue affiliate-specific Commercial Terms that override this summary for a given Affiliate. This Schedule is confidential where it contains affiliate-specific figures.

Parameter

Standard Program terms

CPA (per Qualified Player)

BWP 20

Revenue Share (tiered, monthly on NGR)

12% (1–25) · 13% (26–75) · 15% (76–200) · 17% (201+) Qualified Players/month

Revenue Share Window (per player)

24 months from player registration

Contract structure

2-year Initial Term, then annual (12-month) performance-based renewals

Minimum payout threshold

BWP 50

Settlement

Monthly, after month-end reconciliation and compliance checks

Negative carryover

None at account level; high-roller player-level exception only

Renewal performance thresholds (internal guidance)

Criterion

Threshold for renewal

Profitability

Positive net revenue from the Affiliate’s Referred Players

Payout profile

Withdrawals not exceeding deposits; no abusive patterns

Quality Score

≥ 55 / 100 (player value, retention, hold %, genuine new-depositor flow)

Scale (for higher tiers / 3-year+ standing)

≥ 25 active players and ≥ BWP 5,000 NGR

Compliance

Clean clawback and compliance record in the review period

Review cadence

At least every 6 months and at each renewal date

Thresholds are commercial guidance set and adjusted by Bet267 and are applied reasonably and consistently. They may be tailored in affiliate-specific Commercial Terms.

Privacy Policy

Introduction

Palsar Capital Limited, henceforth referred to as “We” “Our” “Us” provides an affiliate programme to promote our clients on whose behalf We administer and manage the affiliate program. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.

This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.

This privacy policy should be read in conjunction with the Affiliate Programmes Terms and Conditions. By entering into any kind of contract with Palsar Capital Limited, you agree to the contents of this privacy policy. If you do not agree with any section of this privacy policy, you should not attempt to use our service.

Data Controller

The Data Controller is Palsar Capital Limited t/a Raven of Glassworks, 1 Back Turner Street, Manchester, M4 1FR

All queries in regards to this privacy policy should be addressed to the Data Protection Officer at the above address, who can also be contacted directly at compliance@raventrack.com

Personal Information

We collect and process the following data from (and about) you:

  • Your name, company name, address and contact details, including email address and telephone number;
  • Payment details including Electronic transfer address, and payment method owner.
  • A record of any correspondence between You and Us.

Personal information is collected for the following purposes

  • To administer the opening, management, and maintenance of accounts.
  • To enable Palsar Capital Limited to build an accurate profile of our client base and carry out statistical analysis.
  • To contact you for purposes including (but not limited to) sales reports, training, provision of promotional resources, newsletters, and other correspondence.
  • To monitor affiliate activity to ensure your compliance with the terms and conditions of the Active Wins Affiliates Affiliate Programme.
  • To monitor and process payments in relationship to your involvement in this Affiliate Programme.
  • All telephone calls to and from Palsar Capital Limited office(s) may be recorded for training and security purposes.

We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.

Legal Basis for Processing

Our lawful basis for processing personal data include:

  • To fulfil a contract we have with you.
  • When it is our legal duty to do so.
  • When it is in our legitimate interest.
  • When you consent to it.

Who we share your personal information with

We may disclose your personal data to:

  • Palsar Capital Limited employees
  • contractors working with Palsar Capital Limited
  • regulators, and other legal authorities
  • the brands that you are promoting
  • auditors
  • payment providers
  • fraud prevention and compliance services
  • potential purchasers or investors
  • companies that you ask us to share your data with

All processing of information will be governed by the appropriate data protection laws.

Marketing

We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.

The consent requires a positive Opt-In either in electronic format, verbally or in writing. The consent will be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent, and be easily withdrawable.

Data Transfers outside the EEA

We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:

  • The Processor is certified under the EU-U.S. Privacy Shield Framework.
  • The existence of any other specifically approved safeguard for data transfers (as recognised under EU Data Protection Laws) and/or a European Commission finding of adequacy can be demonstrated.

Data Retention

You may request that your Personal Data be anonymised in the following circumstances:

  • Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When you withdraw consent, if consent is being used as the Legal Basis for Processing.
  • If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
  • The Personal Data was unlawfully processed.
  • The Personal Data has to be erased to comply with a legal obligation.

We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.

Subject Access Request (SAR)

You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you. Please note that your identity will need to be confirmed in order to complete a SAR, which may include the disclosure of other personally identifiable documentation in order to prove your identity (such as a passport scan, or valid proof of address) before commencing with the process.

Cookies

By using the Raven website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.

If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.

Automated Decision Making and Profiling

Palsar Capital Limited do not use any automated systems in order to make decisions regarding your account which have any legal effect on You.

Right to Lodge a complaint

Please let us know if you are unhappy with how we have used your personal information in writing to the Data Protection Officer, who will be able to assist further with your complaint or concern. You also have the right to complain to the Information Commissioner’s Office.

Privacy Policy Status

This Privacy Policy is kept under continued review by Palsar Capital Limited and can be amended by Us at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing, as stated in the introduction to this policy.

This version of the Privacy Policy is effective as of September 20th 2018.