Partner

Privacy Policy

Date Last Modified: 27.10.2023

Introduction

Fly Partners (operated by Win Pro Games B.V.), hereinafter referred to as “We”, “Our”, “Us”, represents and operates the Fly Partners Affiliate Program which provides marketing services to the Brand(s). The following statement sets out our policy relating to the collection, storage and use of personal data in the course of our business. We take seriously our obligation to safeguard personal data about our Affiliates or New Customers.

This Privacy Policy is an addition to our Terms and Conditions to the Agreement (Terms and Conditions) and should be read in conjunction with Terms and Conditions, including any terms used in this Privacy Policy shall have the same meaning as the terms used in the Terms and Conditions.

By using this website, opening an Affiliate Account or by referring any New Customers, Affiliate agrees to be bound by the terms of this Privacy Policy.

We review our Privacy Policy from time to time and reserve the right, at our discretion, to amend this policy at any time without any notice other than posting the amended Privacy Policy on Our website fly-partners.com.. Amendments to Our Privacy Policy will be effected immediately once posted on Our website fly-partners.com. Your continued use of Our services following the posting of an amended Privacy Policy will be deemed as acceptance of those amendments. It is your responsibility to ensure that you keep up-to-date with the current Privacy Policy.

How and what personal data is collected

We collect your personal data in the course of business when you participate in Our Affiliate Program. The types of personal data we may collect could include, for example, your name, surname and e-mail address, home address, telephone number, debit/credit card data and other information collected upon registration in our Affiliate Program, filling in any surveys or questionnaires and/or contacting Us via sending email or filling in Our Contact us form.The Company for the purpose of identifying the User’s personality has the right to request a scanned copy of their passport.
You are solely responsible for the accuracy, completeness and correctness of the data which You provide.
It may also be necessary to collect Your personal data from third parties, such as identity verification providers. The Brand(s), to whom You refer Potential Customers and disclose personal data, may also provide Us with personal data. The personal data may also be collected by cookies when You use Our website.

Why we collect, hold, use and disclose personal data
    We collect and hold, use and disclose personal data for purposes including the following:
  • to allow You to register in the Affiliate Program;
  • to conduct ordinary business with You;
  • to enable Us to perform Our obligations to You under Terms and Conditions, and to ensure that You perform Your obligations under Terms and Conditions;
  • for communicating with You, including sending You information about our services;
  • for planning, research, promotion and marketing of Our services;
  • to create aggregate data about clients through demographic profiling and statistical analysis of our database to optimize our services and /or allow for more efficient operation of Our business;
  • for the investigation of suspected unlawful, fraudulent or other improper activity connected with the use of Our or the Brand’s products and services;
  • to monitor the dynamics and levels of use of Our website and the quality of Our services;
  • to maintain Your Account and records;
  • to provide answers to Your questions and comments;
  • to determine the interest in Our services;
  • to determine Your experience on Our website fly-partners.com.;
  • to improve the quality of Our services and Our website fly-partners.com.;
  • to notify You about Our special offers and services that may be interesting for You;
  • for the resolution of disputes;
  • for charging fees (if there are appropriate grounds);
  • to conduct matching procedures in order to prevent potential or already existing fraud or illegal actions;
  • to process Your data in accordance with the GDPR (if You are the EU resident);
  • to process Your payments (when applicable);
  • to eliminate problems and errors on Our website;
  • to make sure You have the legal age to receive direct marketing communications or promotions related to Our product and services.
  • to be compliant with the law and regulatory requirements and requests.
How we use Your personal data

We use Your personal data to identify Yours identity when registering on Our website fly-partners.com., to identify You for the correctness of making payments from You to Fly Partners and from Fly Partners to You. We use Your payment details for the purpose of providing You with services on our website fly-partners.com.

Overseas transfer of personal data
    There may be instances where we may be required to send your personal data overseas or collect personal data from overseas, including:
  • where You have asked Us to do so;
  • when We have outsourced a business activity or function to an overseas provider with whom we have a contractual arrangement; or
  • where We are required or authorized by law to do so.
    • We may disclose Your personal data to entities located outside of Your country of residence, including the following:
    • affiliated legal entities;
    • external service providers located.
    • We and the above-mentioned companies may from time to time involve third parties for the processing of Your personal data for the purposes indicated above, provided that such processing will be governed by contractual arrangements in the form as specified above. Your personal data may also be disclosed to the appropriate governmental, regulatory or executive body in case it is prescribed or permitted by law.
Notification for EU residents.

You should note that our business is placed in Curacao, where the legislation on personal data protection is differ to the legislation, which is in force in the European Union. If You consent to this Privacy Policy, You hereby consent Your data to be transferred outside the European Union to Curacao.

We guarantee that Fly Partners and all the recipients of Your personal data are aware of the rules of personal data processing according to the General Data Protection Regulation (Regulation (EU) 2016/679), and comply with the provisions of this regulatory enactment. All the transfers of Your personal data shall be based on proper data transfer agreements. It means that all partners of Fly Partners that process Your personal data, are legally obliged to process, store and use Your data only in compliance with this Privacy Policy and in accordance with the Regulation (EU) 2016/679.

Unsolicited personal data

Where We receive unsolicited personal data, We will determine whether or not it would have been permissible to collect that personal data if it had been solicited. If We determine that collection would not have been permissible, to the extent permitted by law, We will destroy or de-identify that personal data as soon as practicable.

Сollection and processing of personal data
    All Your personal data:
  • are processed legally, honestly, and “transparently” by Us;
  • are stored in a form that allows identification of users no longer than it is necessary for the purposes for which personal data are processed (“limitation of storage”);
  • are processed in a way that provides proper protection of personal data, including protection against unauthorized or illegal processing, as well as against accidental loss, destruction or damage using appropriate technical or organizational measures (“integrity and confidentiality”).
Your rights
    The You has the right to:
  • ask Fly Partners for the correction or erasure of the Your personal data or to provide Us with an objection for such processing;
  • provide Yours personal data being incomplete to Fly Partners (subject to the provision of an additional statement explaining the reasons);
  • request and receive personal data about You (that were provided by You to Fly Partners);
  • be informed whether Fly Partners stores information about You;
  • request from Fly Partners the exact purpose(s) of processing Yours personal data and information about categories of the personal data that are being processed by Fly Partners.
  • request access to the personal data which Fly Partners stores;
  • request the estimated period during which the Your personal data will be stored by Us.
Your obligations
    You shall:
  • provide accurate and correct personal data in full volume, in accordance with the website Terms and Conditions and this Privacy Policy;
  • promptly provide Fly Partners with the updated personal data;
  • promptly notify Fly Partners about the fact of an unauthorized receipt of the personal data by a third party if You became aware of such fact;
  • notify Fly Partners about any disagreements on any of the purposes of data processing or if You wish Fly Partners to terminate the processing of the personal data via sending a corresponding notice on email [email protected]. You are fully aware that sending such a notice with any of the purposes of personal data processing and/or intention to stop processing their personal data being made by Fly Partners shall be the legal ground for the termination of any relationships between the Parties according to the Terms and Conditions placed on this website.
Your rights
    Fly Partners has the right to:
  • terminate any and all contractual relationships (stipulated by the Terms and Conditions posted on the Fly Partners website fly-partners.com) with You in case of non-provision of the consent for processing of Yours personal data by Fly Partners for the purposes specified in this Privacy Policy;
  • amend this Privacy Policy unilaterally without receiving any prior approval for such amendments from You.
Fly Parters’s obligations
    Fly Partners shall:
  • inform You about the recipients of Yours personal data (i.e. third parties), if a relevant request has been received from You;
  • provide You with Yours personal data (being stored by the Fly Partners) in a structured, commonly used format if a relevant request has been filed by You;
  • notify You and a supervisory authority about the Yours personal data breach within reasonable term after becoming aware of such fact.
    • The Parties also have all rights and obligations provided by the General Data Protection Regulation. The time period of storing Yours personal data by Fly Partners extends for the entire period of the duration of relationships between the Parties provided by the Terms and Conditions placed on the Fly Partners’s website as well as for the next three years after the termination of the Parties’ relationships.
Legal protection

Fly Partners must comply with the Law on the Processing of Personal Data (Protection of Individuals) No. 138(I)/2001 of 23 November 2001 as amended; with the General Data Protection Regulation (EU) 2016/679, and the Electronic Communications Privacy Directive (Directive 2002/58/EC) as amended by Directive 2009/136/EC.

If the You wish to view any personal data that Fly Partners stores or if You want to amend personal data or delete them; or if You wish to receive information on how Yours personal data are used by Fly Partners and how Fly Partners ensures the confidentiality of Yours personal data, You may submit a request via email [email protected].

Cookies

Cookies are small pieces of data which are stored by a website through Your browser, to enable an improved experience whilst using or browsing a particular website or to remember Your preferences or navigation history/activity (such as pages You have visited within a particular site or typical activity) at a particular site.

We may use cookies to remember Your preferences when You have visited Our site and pages You like to regularly visit and to ensure that You receive the most up to date information which is relevant to You and Your experience with Us. We also use cookies for internal management purposes and to enable essential activity to ensure that Your account works correctly when accessing Our services.

We will not use these cookies to store information such as account details or transaction history.

You can delete cookies using Your browser's own Clear History function. You can reset Your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

Most web browsers allow some control of cookies through the browser settings. It is important to note however that if You block cookies from our site there are a number of functions that may not work and You will need to reset Your preferences each time You log in.

Third Party cookies

We may use third-parties to serve ads on Our website. These companies may place or recognise cookies, action tags and other technology to measure advertising effectiveness. We may use cookies to remarket to You across the internet. The use of cookies allows Us to inform, optimize, and serve ads based on someone’s past visits to Our website.

Miscellaneous

If you have any general questions about Privacy Policy or the information that We collect about You and/or Your referred players and how We use it, please contact Us via email at [email protected].

Fly Partners reserves the right to charge reasonable fees for duplicate requests, requests for additional copies of the same data, and/or requests which are considered obviously unreasonable or excessive.

Fly Partners can also refuse to provide answers on requests which it considers obviously unreasonable or excessive.