Privacy Policy

1. Introduction

This Privacy Policy explains how Royal Dogs Partners Affiliate Program ("we", "our", "us") processes personal data in accordance with the EU General Data Protection Regulation (EU GDPR 2016/679) and applicable Cyprus data protection laws, including the Protection of Natural Persons Against the Processing of Personal Data and the Free Movement of Such Data Law (Law 125(I)/2018).

By using our website or affiliate services, you acknowledge and agree to the processing of your personal data as described in this policy.

2. Data Controller

For the purposes of GDPR and Cyprus data protection law, the data controller is:

• DEMOBISCA LTD
• Giannou Kranidioti & Pargas 9, 1st Floor, Flat/Office 102, 1065 Nicosia, Cyprus
• Registration No: HE 464493
• Email: affiliates@royalpartners.io

3. Legal Basis for Processing (GDPR Article 6)

We process personal data under the following legal bases:

• Contractual necessity – to register and manage affiliate accounts
• Legal obligation – compliance with tax, accounting, AML, and regulatory requirements
• Legitimate interest – fraud prevention, analytics, platform optimization, and business operations
• Consent – where required for marketing communications or cookies

4. Information We Collect

We may collect the following categories of data:

4.1 Personal Data

• Full name
• Email address
• Phone number
• Residential or business address
• Payment details (bank accounts, crypto wallets, payment processors)

4.2 Affiliate & Performance Data

• Affiliate IDs and tracking parameters
• Clicks, impressions, conversions
• Traffic sources and campaign performance
• Player registration and activity data (where applicable)

4.3 Technical Data

• IP address
• Device identifiers
• Browser and operating system
• Cookies and tracking technologies

5. Cyprus & EU GDPR Compliance

As a company established in Cyprus and operating within the European Union framework, we comply with:

• EU GDPR (Regulation 2016/679)
• Cyprus Law 125(I)/2018
• Guidance issued by the Office of the Commissioner for Personal Data Protection (Cyprus)

We ensure that:

• Data is processed lawfully, fairly, and transparently
• Data is collected for specified and legitimate purposes only
• Data is limited to what is necessary (data minimization)
• Data is accurate and kept up to date
• Data is stored securely with appropriate safeguards

6. International Data Transfers

As part of our operations, personal data may be transferred to countries outside the European Economic Area (EEA). Where such transfers occur, we ensure appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions (where applicable)
• Additional technical and organizational security measures

7. Your Rights Under GDPR

You have the following rights under EU GDPR and Cyprus law:

• Right of access to your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent at any time (where applicable)
• Right to lodge a complaint with the Cyprus Data Protection Commissioner

8. Right to Lodge a Complaint (Cyprus Authority)

If you believe your data has been processed unlawfully, you have the right to lodge a complaint with:

Office of the Commissioner for Personal Data Protection (Cyprus)

Website: https://www.dataprotection.gov.cy

9. Data Retention

We retain personal data only for as long as necessary for:

• Affiliate account management
• Legal and regulatory obligations (including AML and tax laws)
• Fraud prevention and dispute resolution

After the retention period, data is securely deleted or anonymized.

10. Data Security

We implement appropriate technical and organizational measures in line with GDPR Article 32, including:

• Encrypted communications (SSL/TLS)
• Access control and authentication
• Secure data storage systems
• Monitoring for unauthorized access or misuse

11. Cookies and Tracking

We use cookies and similar technologies to:

• Track affiliate referrals and attribution
• Measure performance and conversions
• Improve platform functionality
• Analyze traffic and user behavior

Where required by law, we obtain consent before setting non-essential cookies.

12. Data Sharing

We may share data with:

• Payment processors and financial institutions
• Hosting and IT infrastructure providers
• Analytics and tracking partners
• Regulatory, tax, or legal authorities when required

We do not sell personal data.

13. Children's Privacy

Our services are strictly intended for individuals aged 18 and above. We do not knowingly collect or process data from minors.

14. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be published on this page with a revised effective date.

15. Contact Information

For any privacy-related questions or requests:

• DEMOBISCA LTD
• Registered Address: Giannou Kranidioti & Pargas 9, 1065 Nicosia, Cyprus
• Email: affiliates@royalpartners.io