Privacy Policy

Last updated 01.04.2025

Introduction

This Privacy Policy outlines how we collect, use, store, and protect your personal data in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and, where applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR"). It applies to users of our websites glosspartners.com, including its subpages ("Website"), and to individuals participating in our Affiliate Program as defined in our Terms and Conditions ("T&C") or interacting with us otherwise.

For the purposes of this Privacy Policy, "we," "us," or "our" refers to the Affiliate Program or the Company as they are defined in the T&C, and "you" refers to the visitor, user, or affiliate of our Website as defined in the T&C.

If you use any websites promoted via Websites for online gambling, please note that separate privacy policies apply to those activities at such websites.

If you have any questions regarding your personal data or wish to understand why we need certain information, please contact our Data Protection Officer (DPO) at affiliates@glosspartners.com.

Scope of This Privacy Policy

This Privacy Policy applies to:

  • Affiliates: Individuals and entities participating in our Affiliate Program as they are defined in the T&C.

  • Website Visitors: Individuals who visit and interact with our Website.

For users based in the European Union (EU) / European Economic Area (EEA), we ensure that your personal data is processed in compliance with GDPR, including adherence to data subject rights and international data transfer safeguards.

Personal Data We Collect

We may collect the following types of personal data:

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Source

Collected Data

Reason

Retention

Affiliate Application

Name, contact details, gender, birthdate, address, phone number, occupation, payment details (credit card, e-wallet, or bank account details)

To establish and manage your Affiliate Account, process payments, and maintain our relationship with you.

As long as required to manage the relationship.

Cookies

Technical data (device, browser type, operating system, language preference, screen resolution, access time, referral source), analytics (page views, browsing behavior, time spent, geo-location)

To improve website performance, conduct analytics, and provide a better user experience.

As long as required to fulfill the purposes (see "Cookies" section).

Email, Skype

Correspondence records, voluntarily provided data

To communicate, provide updates, and market our services.

For the duration of the relationship.

In addition to the above, your personal data may also be used to:

  • Improve our services based on user needs and behavior.

  • Provide access to website features.

  • Prevent fraudulent, illegal, or unauthorized activities.

  • Comply with legal obligations such as Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.

  • Handle disputes and respond to court orders or government authorities.

  • Offer promotions, events, and special offers via email, live chat, or support tickets.

Legal Bases for Processing (GDPR)

For users in the EU, we process personal data based on the following legal grounds:

  • Consent: Where you have given us explicit consent to process your data (e.g., for marketing).

  • Contractual Necessity: Where data processing is necessary for the performance of a contract (e.g., processing your payment).

  • Legal Obligation: Where we are required to process data to comply with legal obligations (e.g., tax or regulatory requirements).

  • Legitimate Interests: Where processing is necessary for our legitimate business interests (e.g., improving services, preventing fraud).

By providing your personal data, you acknowledge that our processing of such information complies with PDPO and other applicable data protection laws.

If you decide that you don’t want to receive any advertising and/or marketing materials that we send, you can always opt out. You are encouraged to contact us at affiliates@glosspartners.com.

Cookies Policy

Cookies are small text files stored on your device to enhance your browsing experience. We use cookies to remember your preferences and improve website functionality. Most cookies are temporary and expire when you close your browser. Some cookies help us understand how visitors use our website through tracking software, but they do not store personal data. We use anonymous session cookies (the ones that are deleted when you close your browser) to guide you and assist you in navigating through the website and to help you get the most out of our features.

When you log into your Affiliate Account, your session cookie will contain your Affiliate ID. This will allow us to check which services and features you are authorized to use.

You can manage cookie preferences through your browser settings to block or delete cookies if desired.

Sharing of Information

We may share your personal data with the following categories of recipients for the purposes listed below:

  • Third-party affiliate platform providers that we work with (e.g., Income Access).

  • Third-party service providers related to the administration and promotion of the respective Group’s brands (e.g., email program providers, internet service providers).

  • Companies within the Company’s business and corporate structure and other affiliated associations.

  • iGaming software providers.

  • Payment solution providers, payment processors, and banking institutions.

  • Any third parties that organize offline events or tournaments on behalf of or along with any companies within the frame of Gloss Partners.

  • Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations.

We also share Personal Information to:

  • Store such data on our behalf, using cloud computing service providers.

  • Assist with business operations (e.g., payment deposits).

  • Detect and prevent fraudulent or illegal activities.

  • Conduct research, technical diagnostics, or analytics.

  • Communicate targeted advertising and promotional materials.
International Transfers

We may transfer your personal data to countries outside of your location (including the EU and Hong Kong), which may not have the same data protection laws as your country of residence. In such cases, we ensure that:

  • Adequate Safeguards are in place to protect your personal data, such as using Standard Contractual Clauses (SCC) for EU transfers or ensuring the third country has an adequate level of data protection according to the Hong Kong PDPO.

  • Consent: Where required, we will seek your explicit consent for cross-border data transfers.

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. This may include:

  • Contractual Necessity: For as long as necessary to fulfill our contractual obligations.

  • Legal Obligations: For periods required by applicable laws (e.g., tax, financial).

  • Business Needs: For legitimate business purposes (e.g., to maintain records for business analysis).

Your Rights

As a data subject, you have the following rights regarding your personal data:

  • Access: You can request a copy of the personal data we hold about you.

  • Correction: You can request corrections to any inaccurate or incomplete personal data.

  • Deletion: You can request the deletion of your personal data when it is no longer needed or if you withdraw consent.

  • Restriction: You can request the restriction of processing under certain circumstances.

  • Portability: You can request the transfer of your personal data to another organization or to you.

  • Objection: You can object to the processing of your personal data for certain purposes (e.g., marketing).

To exercise your rights, contact us at affiliates@glosspartners.com.

We may use your personal data to send you marketing materials, such as updates on our services, special offers, or news. You can opt-out of receiving marketing communications at any time by:

  • Clicking the "unsubscribe" link in any email.

  • Contacting us directly at 

Protection of Minors

We do not knowingly collect or solicit personal data from anyone under the legal age of 18. If we learn that we have collected personal information from a minor, we will delete that information as soon as possible.

Security of Your Data

We are committed to protecting your personal data. We use physical, technical, and organizational measures to ensure the security of your data, in compliance with industry standards. These include:

  • Encryption: We use encryption to protect personal data during transmission.

  • Access Controls: We implement access restrictions to ensure only authorized personnel can access your personal data.

  • Regular Audits: We conduct regular security audits to identify and mitigate potential vulnerabilities.

Despite our best efforts to secure your data, no security system is completely foolproof. We cannot guarantee the prevention of unauthorized access or misuse by third parties.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We will notify you of any substantial changes through our website. The amendments will take effect as of the “last updated” date.

Get in Touch

If you have any questions or concerns regarding this Privacy Policy, please contact us at affiliates@glosspartners.com.

If you are not satisfied with our response, you may raise your issue with the relevant data protection supervisory authority.

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