AFFILIATES PRIVACY NOTICE FOR DOGGO CASINO

1. Introduction

Doggo takes Your privacy very seriously. We know that when you share Your personal data with Us We need to keep it secure and use it in a transparent, fair and lawful manner. The aim of this Affiliates Privacy Notice is to give You a thorough understanding of how We collect, store and use Your personal data when You register as an Affiliate with Doggo, as well as to inform You about Your rights and how to exercise them.
Unless otherwise defined within this Affiliates Privacy Notice, capitalised terms contained herein shall have the same meaning as set out in the Affiliates Terms & Conditions.
This Affiliate Privacy Notice is supplementary to any other privacy notices We may provide You with from time to time and is not intended to override them. This Affiliate Privacy Notice must be read in conjunction with such notices.
We undertake to protect Your personal data and to always respect Your privacy in accordance with the best business practices and applicable laws. You are responsible to provide Us with personal data that is correct and inform Us of any changes occurring in Your personal data in writing, so that We may take all reasonable measures to keep Our records correct and up to date.

2. Data Controller

When you engage with the Doggo Affiliate Program, the data controller of Your personal data is R&B Innovations N.V., a company registered and established under the laws of Curaçao, with registration number 156744, having its registered address at Heelsumstraat 51, E-Commerce Park, Willemstad, Curaçao (“Doggo”, “Company”, “"We", "Us", "Our", interchangeably).

Contact details:
Email: affiliates@doubleup.partners
Data Protection Officer: dpo@doubleup.partners

3. Personal Data and Privacy Principles

Under the EU’s General Data Protection Regulation (GDPR), “personal data” is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. In short, You, as an Affiliate, and provided that You are a natural person, are the “data subject” in relation to this Affiliate Privacy Notice, and therefore Your personal data is protected under data protection law. However, “personal data” does not include “anonymous data”, meaning those data which are considered de-identified since each and every direct or indirect identifiers linking such data to individual subject’s identities have been removed.
Whenever We process personal data, We always follow the GDPR principles:
Lawfulness, fairness and transparency
Purpose limitation
Data minimisation
Accuracy
Storage limitation
Integrity and confidentiality
Accountability

4. Your Personal Data

In this paragraph We will explain the following:
- WHAT kind of personal data We collect, use, store and transfer;
- HOW We collect Your personal data;
- WHY/for what purposes We collect personal data;
- what LEGAL BASES for processing we rely on.
In order for data processing to be legal, data controllers must identify a lawful basis for each processing activity. We could rely on the following legal bases:
1. consent – when We rely on Your consent to process Your personal data, We only process Your personal data in such a manner and for as long as We have Your consent to do so. You can withdraw Your consent at any point in time. However, this will not affect any processing of personal data that We carried out with Your consent before Your consent was withdrawn. You can find more information on how You can withdraw Your consent in paragraph 9 further below;
2. performance of contract – we rely on this legal basis when the processing of Your personal data is necessary for the performance of Our contractual obligations pursuant to the Affiliate Agreement;
3. legitimate interest – we rely on this legal basis when Your personal data are processed in the interest of conducting and managing Our business to ultimately provide You the best service and experience We possibly could. We do not rely on this legal basis if Your interests or fundamental rights and freedoms as a data subject override our interests to process Your personal data;
4. legal requirement – we rely on this legal basis when the processing of Your personal data is necessary for compliance with a legal obligation to which We are subject;

WHAT	HOW	WHY	LEGAL BASES
Identification data – personal data provided in the Affiliate Application Form, including but not limited to name, surname, date of birth and username of choice, as well as any other personal data provided in the course of the contractual relationship between You and Us (including, but not limited to, any information contained in Your identity documents, proof of address, bank statements).	Requested upon registration and/or, if necessary, requested throughout the duration of the Agreement	1. To identify You and verify Your identity, and to create Your Affiliate account 2. To verify Your identity when contact is made 3. To ensure that You are at least 18 years of age (or such other higher minimum legal age in Your country)	1. Performance of contract And Legal requirement 2. Performance of contract And Legitimate interest 3.Performance of contract And Legal requirement
Contact details – including email address, physical address, telephone number, Skype username.	Requested upon registration and/or, if necessary, requested throughout the duration of the Agreement	To identify You and verify Your identity, and to create Your Affiliate account To contact You for support purposes To pass on the Doggo Marketing Material to be used by You as agreed under the Affiliate Agreement	Performance of contract
Financial data – including bank details necessary to carry out the payment of the Commission to You, as well as any preferred Minimum Threshold You may set. These details may also include Your tax details for invoicing purposes.	Collected upon Your voluntary input of necessary details in Your Affiliate account	Required to carry out transfer of Commission to You pursuant to the Affiliate Agreement	Performance of contract
Transaction data – including details relating to payments of Commissions made to You.	Automatically generated when payments of Commission are made to You	Required according to the terms of the Affiliate Agreement	Performance of contract
Data relating to Your communications with Us	Email and Skype correspondence is collected automatically upon contact being made	Required for discussions relating to Our ongoing business relationship	Performance of contract
Technical data – Including Your registration internet protocol (IP) address, Your login data (last login date) etc.	Automatically collected through Your use of the Company Websites	Your registration IP address is collected by Us as a security measure, to detect and prevent unauthorised access of Your Affiliate account Your last login date is used by us to monitor your account activity	Legitimate interest

Moreover, where We have Your consent, We will also use Your personal data to send You our weekly/monthly newsletter to keep you up to date with Our promotions and offers, and to inform You about any compliance updates We think You should be aware of. You can withdraw Your consent regarding Our newsletter at any time, and We will stop sending it to You.

Your personal data will not be processed for purposes other than those it was collected for, and We will only ask You for the minimum amount of information We need to provide You with Our services. In case further processing is required, we will inform You of any additional purposes and We will provide You with all the necessary information.

5. Data security measures

We always strive to ensure that Your personal data is safe, both in Our hands and in the hands of any third-party to whom We may disclose Your personal data. Internally, We have put in place a number of security measures, both from a technical and organisational aspect, to ensure that Your personal data is not accidentally lost, used, accessed in an unauthorised manner, altered, or disclosed. We also ensure that access to Your personal data is determined on a ‘need-to-know’ basis, meaning that only the persons who have a direct need to access Your personal data will have access to it. Furthermore, anyone having access to Your personal data is subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected or actual personal data breaches. We will notify both You as an affected data subject and the supervisory authority concerned of any such data breach whenever We are legally required to do so, and We shall maintain a log of any such breaches.

6. Who We share Your personal data with

In certain circumstances, We need to share Your personal data with third parties in order to provide Our services. We may pass Your personal data to other entities within Our group of companies and to Our business partners. These companies include Our subsidiaries, Our parent companies, their parent companies and all of the subsidiaries of these respective companies, as well as other companies with whom We carry out business and hold necessary agreements. Data processing of Your personal data may be undertaken by the Company or by another entity in Our group of companies, which may use a third party to fulfil such data processing needs.
When We share Your personal data with third parties We always ensure that there is an appropriate contract in place, that the information being shared is transferred in a secure way and that We only share the minimal amount of Your personal data that we need to. We will never sell Your personal data to any other parties.

Cellxpert Ltd will have access to Your personal data.

Cellxpert Ltd will process (collect, store and use) the personal data You provide in a manner compatible with the GDPR. It will endeavour to keep Your personal data accurate and up to date, and not keep it for longer than is necessary. Cellxpert Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs. Cellxpert Ltd may also use Your data for machine learning and automation features to make Your work faster and more accurate.
Occasionally, We may receive a request for disclosure of Your personal data from law enforcement, regulators and supervisory authorities. We will always ensure that the organisation requesting the information has a legal basis to do so, and We will only share the minimum amount of information required in a secure way. We will also share Your personal data with law enforcement, regulators and supervisory authorities where We believe a criminal act has been or may be committed.

7. How long do We keep Your personal data

We only retain Your personal data for as long as necessary. When determining the appropriate retention period applicable to Your personal data, We take several factors into consideration, including but not limited to the purposes for which We collect and process such data, their nature and sensitivity, the risks surrounding any unauthorised use or disclosure of such data, and the applicable laws and/or regulatory requirements We must comply with. After the closure of Your Affiliate account, We will retain all data relating to Our business relationship for 10 years, in order to meet Our legal obligations regarding fraud, taxation and AML/CFT. Your personal data will be kept securely until the retention period is over, and then We will securely destroy Your personal data.

8. Your rights under the GDPR

Pursuant to the GDPR, You have a number of rights relating to Your personal data. These rights include:

Having access to Your personal data - You have the right to request Us (free of charge) a copy of the personal data that We hold about You.

Being able to rectify the personal data We have about You that is incorrect – if any of Your personal data is incomplete or incorrect, You have the right to request Us to correct it, provided that You furnish Us with adequate evidence and documentation to support Your request.

In very limited circumstances, having Your personal data deleted – You have the right to request Us to erase Your personal data, provided that We no longer have a legitimate reason to continue processing it or retaining it. Be aware that We will not be able to satisfy Your request where we have a legal obligation to retain Your personal data, or where the retention of Your personal data may be necessary for Us to defend Ourselves in a legal dispute.

In some circumstances, objecting to the processing of Your personal data or having the use of Your personal data restricted – You have the right to object to the processing of Your personal data in case We rely on Our legitimate interests (or those of a third party) and You feel that Our processing of Your personal data negatively impacts Your fundamental rights and freedom. However, in some cases We may be able to demonstrate that We have a compelling legitimate ground to process Your personal data which may override Your rights and freedoms. You also have the right to request Us to suspend the processing of Your personal data in one of the following cases: (i) where You want Us to establish the accuracy of Your personal data, (b) where Our use of Your personal data is unlawful, but You do not wish for Us to delete it, (c) where You need Us to retain Your personal data even when We no longer need it in order for You to establish, exercise, or defend legal claims, or (d) where You have objected the use of Your personal data but We need to verify whether We have overriding legitimate grounds to use it.

Having Your personal data provided to You in a digital format, and where possible transferred to another organisation – You have the right to request Us to transfer Your personal data to a third party (“data portability”).
You can exercise any of Your rights explained above by sending an email at affiliates@doubleup.partners including:
Your name
Contact details
Full details of your request

In some circumstances We may request that You provide Us with ID, so that We can verify Your identity. This is a security measure to ensure that the person to whom We disclose Your personal data is really You. Some of these rights only apply in certain circumstances, so if We are unable to action Your request We will explain to You why. Moreover, these rights also only apply to personal data (information about You as an individual) and not business data.
We will do Our utmost to respond to all legitimate requests within one month from their submission. However, if Your request is particularly complex, or if You have made multiple requests in a certain time period, it may take Us a little longer. In such case, We will notify You of such extension.
You also have the right to file a complaint with a supervisory authority.

9. Withdrawing your consent

Where We rely on Your consent to process Your information You always have the option to withdraw Your consent at any time.
We rely on Your consent to send You our affiliates newsletter. We only ever send marketing messages to You if You have given Us Your consent to receive these messages, which We collect as part of the registration process. You can opt-out of receiving these messages at any time either, by clicking the “unsubscribe” link in every email, or by sending an email at affiliates@doubleup.partners.
You should be aware that even if You do not consent to marketing messages, You may still receive the occasional service email from Doggo. These messages are so that we can inform You of changes to the Affiliates Terms & Conditions and this Affiliate Privacy Notice, as well as anything else that may impact the service We are able to provide to You.
Withdrawing Your consent will not affect the lawfulness of the data processing carried out by Us up until the time You withdrew Your consent.

10. Automated decision making and profiling

We are required to take a number of steps to meet the rules around Anti-Money Laundering (AML), Counter Terrorist Financing (CTF), fraud and other illegal activities. To this end, We employ programmes that monitor suspicious or fraudulent transactions and activity. Where relevant transactions are flagged, We escalate them to the necessary regulators and enforcement bodies, and Affiliate accounts may be blocked.

11. Cookie Policies

Our website uses cookies to enhance the quality of services We provide. Cookies are small text files (composed of letters or numbers), which may include a unique identifier. Cookies are sent to Your browser from a website and are stored on Your computer's hard drive. We use "cookies" to analyze the information. Cookies cannot damage any files or jeopardize the safety of Your computer or mobile device, and they are nonintrusive. Cookies are meant to collect unidentifiable data about Your activity on the website. You can ask Your browser to reject all cookies or to indicate when a cookie has been sent.

12. Changes to this privacy notice

We may update this Affiliate Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If We make material changes to this Affiliate Privacy Notice, We may notify You either by prominently posting a notice of such changes or by directly sending You a notification. We encourage You to review this Affiliate Privacy Notice frequently to be informed of how We are protecting Your personal data.