Privacy Policy

1. Introduction

By applying for our affiliate program, you agree to be bound by this Privacy Policy.

This Privacy Policy describes how we collect, use, process, and disclose your information.

The “Data Controller” is the company that determines the purposes and means of the processing of personal data under this Privacy Policy.

Goldwin Ltd acts in its capacity of data controller in terms of the EU Regulation 2016/67, determining the purposes and means of the processing of your personal data.

For the purpose of this policy, the use of “we,” “us,” or “our,” refers to the company that is responsible for your information under this Privacy Policy.

Please see Section 7 for contact details of the Data Controllers.

2. Information we collect

When you sign up to become an Affiliate, we ask for and collect your username, the url of your website, your email address, your Country and your currency.

After you are approved as an Affiliate, we collect your name, address, date of birth, phone number and in some cases your Skype id.

3. How we use information we collect

The information you provide us is necessary for the adequate performance of the contract between you and us, in particular to enforce our Terms & Conditions, including notifying you with any changes of them.

In some cases, we may use your data also to:

  • contact you in relation to promotions, products or services that you may be interested in from time to time, but only where you have consented to receive such marketing communications.
  • carry out certain profiling of you in order to personalise, measure, and improve our marketing and to send you more relevant marketing communications.

In such cases we will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can always opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your interface.

4. Sharing and disclosure

    1. Compliance with law, responding to legal requests, preventing harm and protection of our rights.We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights and proper protection of our business against risks.

    2. Third parties service providersWe may a variety of third party service providers to help us provide services related to the affiliate program. Service providers may be located inside or outside of the European Economic Area (“EEA”).These providers have limited access to your information and are contractually bound to protect and to use it on our behalf only for the purposes for which it was disclosed and consistent with this Privacy Policy.We may share some of your information with such third parties service providers in order to ensure the adequate performance of our contract with you, for our legitimate interest and to comply with our legal obligations. We will require your consent when needed.You can always contact us to receive the full list of our service providers which process your data.

    3. CorporateWe may share your information, including personal information, to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

    4. Business transfersIf we undertake or are involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.