Last updated: May 16, 2024

In order to cooperate and fulfill the obligation under the Affiliate program (the “Affiliate program”) P.H. PRIMARY OÜ, a company incorporated under the laws of the Republic of Estonia, registration number: 16046808 (the “Operator”) authorized the agency (the “Company”, “we,” “our,” or “us”) to collect, record, and process the personal data of individuals and legal entities, participating in the Affiliate Program (the “you”) pursuant to the agency agreement and on Operator’s behalf. This Privacy Policy explains how the Company collects, uses, and discloses your personal data. We invite you to read this Privacy Policy of the Affiliate program (the “Privacy Policy”) to avoid inconveniences.

By participating in the Affiliate Program, you signify that you have read, understood, and agreed to our collection, storage, use, and disclosure of the Personal data (as defined below) according to this Privacy Policy.

If terms are not defined in this Privacy Policy, then they are used in the meaning outlined in the Terms and Conditions of the Affiliate program.


When registering for the Affiliate program, you willingly provide the Company with consent to collect, utilize, and store your Personal data.

The Company collects information that may be used for your verification and identification (the “Personal data”). The Personal data collected by the Company may include the following information:

  • Your full name (first and last name);
  • Contact information (email, messenger, and phone number);
  • Traffic resource, link to the traffic resource;
  • Geo of the traffic resource;
  • Address (county, region, city);
  • Your age;
  • Gender;
  • Login information (login, inner user ID, password);
  • Date of registration on the Affiliate program (date of the first visit);
  • Cookies;
  • Other information voluntarily provided by you to the Company.

Kindly notify us of any changes to your Personal data within the duration of the Affiliate program.


The Company collects the Personal data for one of the following purposes:

  • to provide you with the access to the account on the Affiliate program;
  • to process payments of the Commission to you;
  • to provide you with the support during the Affiliate program;
  • to provide the Personal data to the electronic services provider for making transactions;
  • to make your security review;
  • to administrate a contest, promotion, survey, or other Affiliate program feature;
  • to provide you with promotional offers and information about the Affiliate program and/or the Company’s partners’ products or services.

Your Personal data may be utilized or disclosed with your consent, such as when you opt-in to receive specific communications as required by applicable law. If we are using your Personal data on this basis, you retain the right to withdraw your consent at any time by contacting us through the provided contact information.

Besides your consent, we may collect, utilize, and store your Personal data based on one of the following legal bases:

  • Agreement (to fulfill our obligation outlined in the specific agreement concluding with you);
  • Legal obligations (for compliance with our legal obligation);
  • Vital interests (to protect the vital interests of you or/and other individuals);
  • Public interest (for the performance of a task carried out in the public interest or the exercise of our official authority);
  • Legitimate interest (for the performance of our or/and third parties' legitimate interests, if your interests, rights, and freedoms do not override this legitimate interest).


The Company receives the Personal data via your registration in the Affiliate program and you may provide the Personal data via communication with the Company’s managers.

The Company may also receive the Personal data from online vendors, service providers, and customer/affiliate lists obtained legally from third-party suppliers.

Furthermore, we may engage third-party service providers for technical support you in online transactions and to manage the Affiliate account.

The Company utilizes and/or discloses the Personal data in accordance with the terms outlined in this Privacy Policy.


We share the Personal data with third parties that help us operate, provide, improve, integrate, customize, support, and market the Affiliate program.

We refrain from disclosing your Personal data with any third party unaffiliated with the Affiliate program.

However, if you explicitly grant consent to the Company for disclosing their Personal data with a third party unaffiliated with either the Affiliate program or the Company, only then the Company has the right to disclose the Personal data to such a third party.

We may disclose your Personal data if required to do so by applicable law, or if we believe in good faith that such actions are necessary to:

  • comply with any legal issue or process that concerns us, the Affiliate program or in circumstances where we are essentially bound by legal obligation;
  • protect our rights or property;
  • protect you or other partners ;
  • If, in our opinion and sole determination, you are found to have deceived us or attempted to deceive us in any way including but not limited to, game tampering, or payment fraud.

The Company carries out all appropriate measures to combat money laundering and international terrorism (AML Policy). If we have grounds to suspect you of payment fraud, we retain the right to withhold your commission and disclose such information with your Personal data with banks, appropriate regulatory agencies, and law enforcement authorities.


To be in control of your Personal data and in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679), you retain the following rights:

  • the Right to Access under GDPR Article 15, granting you the ability to request a copy of the Personal data we are currently processing concerning you.
  • the Right to Rectification under GDPR Article 16, empowering you to request the correction of any incomplete or inaccurate Personal data that we process regarding you.
  • the Right to be Forgotten under GDPR Article 17, which grants you the authority to request the deletion of Personal data processed by us concerning you. However, please note that we may not be obligated to fulfill such a request if retaining such data is necessary to comply with legal obligations or to establish, exercise, or defend legal claims.
  • the Right to Restriction of Processing under GDPR Article 18, entitles you to limit our processing of your Personal data under certain circumstances, such as when you believe the data is inaccurate, our processing is unlawful, or if we no longer require the data for its original purpose. However, please note that we may not be able to fulfill this request if retaining the data is mandated by law or other obligations, or if you expressly wish for it not to be deleted.
  • the Right to Portability under GDPR Article 20, granting you the authority to receive the Personal data we hold about you in a structured, electronic format and to transmit this data to another data controller.
  • the Right to Objection under GDPR Article 21, if the legal basis for processing your Personal data is our legitimate interest, you have the right to object to such processing based on reasons related to your specific circumstances. We will comply with your objection unless we have compelling legitimate grounds for the processing that supersede your interests and rights, or if it is necessary to continue processing the data for establishing, exercising, or defending a legal claim.

You can exercise these rights by contacting us at Please note that there are exceptions to the various rights listed above. As an example, in certain circumstances, we may have a legal obligation to retain some of your Personal data.


The website of the Affiliate program uses a cookie to identify your activities on this website. This information is referred to as ‘Cookies’, which are small text files containing letters and numbers for recording your preferences.

By default, we collect only the strictly necessary Cookies (required to enable the basic features of the website of the Affiliate program, such as providing secure log-in or adjusting your consent preferences).

You can personalize your preferences by enabling or disabling specific types of Cookies:

  • Functional: these Cookies aid in performing various functionalities such as sharing website content on social media platforms, gathering feedback, and incorporating other third-party features.
  • Analytics: these Cookies facilitate the understanding of visitor interactions with the website, providing insights into metrics like visitor count, bounce rate, traffic sources, etc.
  • Advertisement: these Cookies are designed to deliver tailored advertisements to visitors based on their previous page visits and to assess the effectiveness of advertising campaigns.


We retain your information only for the duration necessary to fulfill the purposes outlined in this Privacy Policy. Once the need for your Personal data has concluded, or if your Affiliate account is deleted, and there are no remaining legal or regulatory obligations requiring its retention, we will either delete it from our systems entirely or anonymize it to prevent identification.


The Company understands the importance of providing security and the methods needed to secure the confidentiality, integrity, and accessibility of Personal data.

We take all appropriate technical and organizational measures to ensure that the processing of Personal data takes place under the General Data Protection Regulation (Regulation (EU) 2016/679).

We also take measures to ensure the safety of your Personal data when you place an order or enter, submit, or access your Personal data.

However, we strive to maintain security measures, it's important to acknowledge that transmitting information over the internet inherently carries some level of risk. Despite our best efforts, we cannot provide a guarantee of the security of your Personal data. PLEASE NOTE, ANY DATA, WHICH YOU SEND, IS SENT AT YOUR OWN RISK.


The Affiliate program is e not intended for individuals under the age of 21 (twenty-one) or the lawful age in their respective jurisdiction.

Any person who provides their Personal data to us through any part of the Affiliate program confirms to us that they are 21 (twenty-one) years of age (or the lawful age in their respective jurisdiction) or older.

If we become aware that a minor has attempted to or has submitted Personal data via the Affiliate program, we will not accept such data and will take all steps to delete it from our records.


We may transfer the Personal data to countries other than the country in which the Personal data was originally collected in order to facilitate the Affiliate program and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards in accordance with General Data Protection Regulation (GDPR) requirements.


This Privacy Policy applies only to the Affiliate program. We cannot ensure the protection of any information that you provide to a third-party website through the links on the website of the Affiliate program.e, Since these third-party online services and websites are not owned/ operated by us and any information collected by these third parties is governed by the privacy policy of such party.


Due to the complex and ever-changing nature of our technologies and business, we provide comprehensive, but we do not guarantee an error-free, operation regarding the confidentiality of your personal information when you visit other websites using links located on our website. Websites that are beyond our control, and especially not covered by this Privacy Policy, should provide you with an opportunity to familiarize yourself with their security policies. If you visit other websites, you should be aware that the operators of these websites can collect your personal information, which they will use in accordance with their privacy policy, which will differ from ours.

We are also not responsible for any direct or indirect damage arising from the unlawful use or theft of your Personal data.


We reserve the right to amend our Privacy Policy at any time. We will post any changes to this Privacy Policy with their effective dates. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and to be aware of any amendments. If you continue using the Affiliates program after any amendments, your action will constitute your acknowledgment of the amendment Privacy Policy and your agreement to be bound by it.


To exercise your rights outlined in this Privacy Policy, please feel free to reach out to us via email with any inquiries regarding your data privacy.