This Privacy Policy describes how PlaySafe Gaming S.R.L. (“PlaySafe”, “we”, “us”, or “our”) collects, uses, stores, discloses, transfers, and otherwise processes personal data relating to affiliates and prospective affiliates worldwide in connection with the CallMeBet affiliate program (the “Affiliate Program”).
This Privacy Policy is intended to comply with applicable data protection laws, including the laws of Costa Rica and, where and to the extent applicable, Regulation (EU) 2016/679 (“GDPR”), as well as other applicable data protection laws in the jurisdictions where affiliates are located or where the relevant processing activities take place.
By applying to join, accessing, participating in, or otherwise using the Affiliate Program, you acknowledge that you have read and understood this Privacy Policy.
1. DATA CONTROLLER
The data controller responsible for the processing of personal data described in this Privacy Policy is:
PlaySafe Gaming S.R.L.
Company Registration No. 3102909520
Registered address: Montes de Oca, Distrito San Pedro, San José, Costa Rica
For the purposes of applicable data protection laws, PlaySafe Gaming S.R.L. acts as the sole controller in respect of the processing of personal data relating to affiliates and prospective affiliates under this Privacy Policy.
2. DATA PROTECTION CONTACT
Any questions, requests, or concerns relating to this Privacy Policy or the processing of personal data may be addressed to: affiliates@callmebet.com
Where required under Article 27 GDPR, PlaySafe Gaming S.R.L. has appointed the following representative in the European Union:
Node70 Ltd
Avlonos, 1, Maria House, 1075, Nicosia, Cyprus
Email: office@node70.com
3. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to the processing of personal data relating to:
- Individuals applying to become affiliates;
- Approved affiliates;
- Representatives, beneficial owners, contact persons, and other individuals associated with affiliate accounts, where relevant; and
- Other persons whose personal data is provided to us in connection with the Affiliate Program.
This Privacy Policy applies to personal data collected directly from you, automatically through your use of our websites, dashboards, tracking tools, and systems, and from third parties where permitted by applicable law.
4. CATEGORIES OF PERSONAL DATA WE MAY PROCESS
We may collect and process the following categories of personal data, to the extent relevant for the purposes set out in this Privacy Policy:
4.1 Identification Data
Including:
- First name and last name;
- Date of birth;
- Gender, where voluntarily provided or otherwise lawfully obtained;
- Nationality, country of residence, or similar identity-related information;
- Account identifiers and affiliate IDs.
4.2 Contact Data
Including:
- Email address;
- Telephone number;
- Messaging or communication identifiers, including messenger usernames or IDs where used for business communications;
- Postal or residential address.
4.3 Verification and Compliance Data
Including:
- Identification document details;
- Copies of identity documents, where required;
- Residency verification information;
- Tax-related information;
- Information required for know-your-customer, anti-fraud, anti-money laundering, counter-terrorism financing, sanctions, payout, or other legal or compliance checks.
4.4 Account and Relationship Management Data
Including:
- Account registration details;
- Affiliate profile information;
- Communication preferences;
- Support requests and correspondence;
- Records relating to the creation, administration, suspension, restriction, or termination of affiliate accounts.
4.5 Transactional and Performance Data
Including:
- Transaction and conversion data;
- Order or status synchronization data;
- Attribution data;
- Payout and commission data;
- Refund, return, chargeback, and dispute data;
- Server-to-server postback data;
- Performance and campaign metrics.
4.6 Technical and Usage Data
Including:
- IP address;
- Browser type and version;
- Device identifiers and device characteristics;
- Operating system and version;
- Cookie and similar technology data;
- Language settings;
- Time zone;
- Access dates and times;
- Requested URLs and page interaction data;
- Log files, diagnostics, and security-related event data.
4.7 Localization and Preference Data
Including:
- Country;
- Locale;
- Preferred language;
- Interface settings;
- Time zone;
- Region-related preferences.
4.8 Marketing and Communication Data
Including:
- Subscription and opt-in/opt-out status;
- Records of communications sent;
- Engagement with newsletters or promotional communications;
- Preferences relevant to business communications or marketing.
5. SOURCES OF PERSONAL DATA
We may obtain personal data from the following sources:
- Directly from you;
- From your applications, forms, communications, and submissions;
- From your use of our websites, tracking systems, dashboards, and affiliate tools;
- From cookies and similar technologies;
- From service providers acting on our behalf;
- From payment, verification, compliance, fraud prevention, analytics, and technical partners;
- From public sources, registers, sanctions lists, or other lawful third-party sources, where relevant and permitted by law;
- From other persons associated with your affiliate business or account.
6. PURPOSES OF PROCESSING
We may process personal data for the following purposes:
6.1 Affiliate Onboarding and Account Administration
To:
- Assess applications to join the Affiliate Program;
- Create and administer affiliate accounts;
- Verify identity and eligibility;
- Establish and manage the affiliate relationship.
6.2 Performance of the Affiliate Relationship
To:
- Enter into, perform, administer, and enforce the affiliate agreement;
- Track referrals, conversions, campaigns, and related activity;
- Calculate, validate, and process commissions, payouts, and adjustments;
- Provide account functionality, reporting, and related services.
6.3 Communications and Support
To:
- Communicate with affiliates and applicants;
- Provide customer and operational support;
- Send service messages, notices, alerts, and account-related information;
- Respond to questions, complaints, or requests.
6.4 Fraud Prevention, Security, and Integrity
To:
- Detect, prevent, investigate, and respond to fraud, abuse, duplicate accounts, suspicious transactions, unlawful conduct, policy violations, and security incidents;
- Preserve platform integrity;
- Protect our rights, business, systems, users, and partners.
6.5 Compliance and Legal Obligations
To:
- Comply with applicable legal, tax, accounting, reporting, sanctions, anti-money laundering, counter-terrorism financing, and other regulatory obligations;
- Conduct audits;
- Respond to lawful requests from courts, regulators, law enforcement authorities, or other competent bodies.
6.6 Analytics, Operations, and Service Improvement
To:
- Operate, maintain, monitor, test, troubleshoot, and improve our websites, systems, tools, and services;
- Conduct internal reporting and analytics;
- Enhance usability, security, efficiency, and business operations.
6.7 Marketing and Business Communications
To:
- Send newsletters, promotional updates, or other business communications, where permitted by applicable law;
- Personalize communications and content;
- Maintain records of preferences and consent choices.
6.8 Legal Claims and Business Protection
To:
- Establish, exercise, or defend legal claims;
- Manage disputes and complaints;
- Protect our legitimate commercial interests and legal position.
7. LEGAL BASES FOR PROCESSING
Where required by applicable law, including the GDPR where applicable, we rely on one or more of the following legal bases for processing personal data:
7.1 Performance of a Contract
Processing is necessary to take steps at your request prior to entering into the affiliate relationship and to perform the affiliate agreement and related arrangements.
7.2 Compliance with Legal Obligations
Processing is necessary for compliance with legal or regulatory obligations to which we are subject, including obligations relating to accounting, tax, fraud prevention, sanctions, anti-money laundering, reporting, and lawful disclosure.
7.3 Legitimate Interests
Processing is necessary for the purposes of our legitimate interests or those of relevant third parties, including:
- Administering and operating the Affiliate Program;
- Ensuring accurate tracking, attribution, and reporting;
- Securing our systems, services, and business operations;
- Detecting and preventing fraud and abuse;
- Improving products, services, and operations;
- Managing business communications;
- Protecting and enforcing legal rights.
Where required by law, we will carry out an appropriate balancing assessment before relying on legitimate interests.
7.4 Consent
Where required by applicable law, we will rely on your consent, including, where relevant, for certain marketing communications, optional technologies, or other processing activities for which consent is the appropriate legal basis.
Where processing is based on consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out prior to such withdrawal.
8. REQUIREMENT TO PROVIDE PERSONAL DATA
The provision of certain personal data is necessary in order for us to:
- Assess your application;
- Establish and administer the affiliate relationship;
- Perform contractual obligations;
- Validate affiliate activity and payouts;
- Comply with legal and regulatory requirements.
If you fail to provide personal data required for these purposes, or if you request the erasure of data necessary for the continuation of the affiliate relationship, we may be unable to onboard you, maintain your account, provide the relevant services, accurately track performance, or process commissions and payouts.
9. PROCESSING METHODS
We may process personal data by automated means, non-automated means, or a combination of both.
Processing operations may include:
- Collection;
- Recording;
- Organization;
- Structuring;
- Storage;
- Adaptation or alteration;
- Retrieval;
- Consultation;
- Use;
- Disclosure by transmission;
- Alignment or combination;
- Restriction;
- Erasure;
- Destruction.
10. DISCLOSURE OF PERSONAL DATA
We may disclose personal data where necessary and subject to applicable law to the following categories of recipients:
10.1 Service Providers
Third-party vendors, contractors, and providers engaged to perform services on our behalf, including in relation to:
- Hosting and infrastructure;
- Cloud and data storage;
- Technical support;
- Communications;
- Customer support;
- Analytics;
- Fraud prevention;
- Compliance and verification;
- Finance and payment administration;
- Professional services.
10.2 Professional Advisors
Auditors, accountants, lawyers, consultants, notaries, and other professional advisers, where disclosure is necessary for legitimate business, compliance, or legal purposes.
10.3 Authorities and Public Bodies
Courts, regulators, supervisory authorities, tax authorities, law enforcement agencies, or other competent public bodies where disclosure is required by law or is otherwise legally justified.
10.4 Corporate and Transactional Recipients
Actual or potential acquirers, investors, lenders, assignees, successors, or counterparties in connection with a merger, acquisition, restructuring, financing, or transfer of assets or business, subject to appropriate confidentiality arrangements and lawful basis.
10.5 Other Lawful Recipients
Any other recipient where disclosure is necessary to establish, exercise, or defend legal claims, or otherwise permitted or required by applicable law.
11. SERVICE PROVIDERS AND HOSTING
We may engage third-party service providers to process personal data on our behalf and under our documented instructions, subject to appropriate contractual, confidentiality, and security obligations. Such service providers may include providers of hosting, cloud infrastructure, analytics, communications, compliance, fraud prevention, payment administration, and technical support services. We may replace, supplement, or update such service providers from time to time in the ordinary course of our business operations.
12. INTERNATIONAL DATA TRANSFERS
PlaySafe Gaming S.R.L. is established in Costa Rica and works with affiliates, service providers, partners, and systems located in multiple jurisdictions. Accordingly, personal data may be accessed, processed, stored, or transferred internationally, including to countries that may not provide the same level of legal protection as the country in which the data was originally collected.
Where required by applicable law, including the GDPR where applicable, international transfers will be carried out subject to appropriate safeguards and lawful transfer mechanisms.
Such safeguards may include, where relevant:
- Adequacy decisions;
- Standard contractual clauses or equivalent transfer instruments;
- Intra-group arrangements;
- Derogations or other mechanisms permitted by applicable law.
13. DATA RETENTION
We retain personal data only for as long as is necessary for the purposes for which it was collected and processed, including for contractual, legal, regulatory, tax, accounting, operational, fraud prevention, dispute resolution, and legal claim purposes.
Unless a different retention period is required or permitted by applicable law, or is necessary in view of the specific circumstances of the processing, the following general retention periods shall apply:
- where the affiliate is an EU/EEA data subject, or the relevant processing activity is subject to the GDPR, personal data will generally be retained for five (5) years following termination of the affiliate relationship, save where a longer retention period of up to seven (7) years is required by law, regulation, competent authority request, or for the establishment, exercise, or defense of legal claims;
- for other affiliates, personal data will generally be retained for ten (10) years following termination of the affiliate relationship, unless a longer retention period is required or justified by applicable law, regulatory requirements, fraud prevention needs, audit requirements, or the establishment, exercise, or defense of legal claims.
At the end of the applicable retention period, personal data may be deleted, anonymized, or irreversibly destroyed, unless further retention is permitted or required by law.
14. DATA SECURITY
We implement appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing.
Such measures may include, as appropriate:
- Access controls;
- Role-based permissions;
- Authentication controls;
- Logging and monitoring;
- Encryption or pseudonymization where appropriate;
- Contractual confidentiality obligations;
- Vendor due diligence;
- Incident response procedures;
- Internal policies and training.
No system can be guaranteed to be completely secure. Accordingly, while we take commercially reasonable and legally appropriate measures to protect personal data, we cannot guarantee absolute security.
15. COOKIES AND SIMILAR TECHNOLOGIES
We may use cookies, pixels, local storage, server-side tracking, and similar technologies for purposes including:
- Ensuring the operation and security of websites and systems;
- Remembering preferences and settings;
- Measuring and analyzing performance;
- Facilitating affiliate attribution and conversion tracking;
- Preventing fraud and abuse;
- Supporting communications and service functionality.
Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies.
Additional information regarding such technologies may be provided through a separate cookie notice or consent management interface, where applicable.
16. MARKETING COMMUNICATIONS
We may send affiliates and prospective affiliates marketing or promotional communications to the extent permitted by applicable law.
Where required by law, such communications will be sent only on the basis of valid consent or another lawful basis recognized by applicable law.
You may opt out of marketing communications at any time by:
- using the unsubscribe mechanism included in the communication, where available; or
- contacting us at affiliates@callmebet.com
Opting out of marketing communications will not prevent us from sending non-promotional communications necessary for the administration of the Affiliate Program, your account, contractual matters, security matters, or legal compliance.
17. DATA SUBJECT RIGHTS
Where applicable under the laws governing the relevant processing activity, you may have one or more of the following rights in relation to your personal data:
- The right to obtain confirmation as to whether personal data concerning you is being processed;
- The right to access personal data and related information;
- The right to request rectification of inaccurate or incomplete personal data;
- The right to request erasure of personal data;
- The right to request restriction of processing;
- The right to object to processing, including processing based on legitimate interests and, where applicable, direct marketing;
- The right to data portability;
- The right to withdraw consent, where processing is based on consent;
- The right not to be subject to certain forms of automated decision-making, where applicable;
- The right to lodge a complaint with a competent supervisory or regulatory authority.
These rights are not absolute and may be subject to legal conditions, limitations, exemptions, identity verification requirements, and the rights of others.
Requests relating to personal data rights may be submitted to: affiliates@callmebet.com
We may require reasonable information to verify your identity before acting on your request.
18. CHILDREN AND MINORS
The Affiliate Program is not intended for minors. We do not knowingly collect or process personal data from individuals who are under the age of majority applicable to them, or who otherwise lack legal capacity to enter into the affiliate relationship, unless permitted by applicable law and subject to appropriate authorization.
If we become aware that personal data has been collected in breach of this section, we may take appropriate steps to delete such data and terminate or restrict the relevant account.
19. THIRD-PARTY LINKS AND SERVICES
Our websites, dashboards, systems, or communications may contain links to third-party websites, services, or platforms. We are not responsible for the privacy, security, or data handling practices of third parties, except to the extent required by applicable law.
You should review the privacy notices and terms of any third-party services you use or access.
20. CHANGES TO THIS PRIVACY POLICY
We reserve the right to amend, update, revise, or replace this Privacy Policy at any time in order to reflect changes in legal requirements, regulatory expectations, business practices, technical developments, or the Affiliate Program.
Where required by applicable law, or where changes are material, we may provide notice by appropriate means, including by email, through the affiliate dashboard, on the website, or otherwise.
The updated version of this Privacy Policy shall become effective from the date indicated in the revised version, unless otherwise stated.
21. GOVERNING APPROACH TO APPLICABLE PRIVACY LAWS
This Privacy Policy is drafted as a global privacy notice. The rights, obligations, restrictions, and safeguards described herein shall apply subject to the data protection laws applicable to the relevant processing activity, the location of the data subject, the location of the processing, and any other relevant jurisdictional connecting factors.
Nothing in this Privacy Policy shall be interpreted as limiting any non-waivable right that a data subject may have under applicable law, nor as expanding rights beyond those required under the laws applicable to the relevant processing activity, except where we expressly decide to grant broader protections.
22. CONTACT
For any questions, notices, requests, or complaints concerning this Privacy Policy or the processing of personal data, please contact:
PlaySafe Gaming S.R.L.
Registered address: Montes de Oca, Distrito San Pedro, San José, Costa Rica
Email: affiliates@callmebet.com
Last revision: April 21, 2026