Last revised: January 28, 2018
Esports Marketing Technologies Ltd, which includes all of the entities specified below under “The Group” section, including its affiliates (collectively, the “Company”) enables visitors of its website https://www.karambapartners.com/ (“you”, “your” or “Affiliate”) to participate in its affiliate program (the “Services”).
- THE GROUP
- WHAT INFORMATION WE COLLECT?
- CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
- HOW WE USE THE COLLECTED INFORMATION?
- WITH WHOM WE SHARE INFORMATION?
- INTERNATIONAL TRANSFER OF INFORMATION
- THIRD PARTY TRACKING TECHNOLOGIES
- RETENTION OF PERSONAL INFORMATION
- YOUR RIGHTS
- HOW WE KEEP YOUR INFORMATION SECURED
- HOW TO CONTACT US
The Group includes the following companies:
- Esports Marketing Technologies Ltd- 20 World Trade Center, 6 Bayside Road, GX11 1AA Gibraltar
- Aspire Global International LTD- 135, High street, Sliema SLM 1549, Malta
- AG Communications LTD- 135, High street, Sliema SLM 1549, Malta
- AG Software LTD- 135, High street, Sliema SLM 1549, Malta
- Aspire Global plc- Level G, office 1/5086, Quantum House, 75 Abate Rigord Street, Taw Xbiex XBX 1120, Malta
WHAT INFORMATION WE COLLECT?
We collect two types of information from our Affiliates:
The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
Registration details: When you open an affiliate account and register as an Affiliate, you will be asked to provide us certain details about yourself, such as: first and last name, email address, company, physical address, phone number, city and country, ID number, username and password.
- Governmental-issued ID: In certain instances, you will be required to provide a copy of a governmental-issued ID, for identity verification process.
- Payment information – by its nature, your use of our services includes financial transactions, thus requiring us to obtain your financial details, which include, but are not limited to your payment details (such as bank account details and financial transactions performed through our services).
- Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services.
- Feedback, reviews and testimonials: We also collect and display personal testimonials, reviews and feedback of satisfied Affiliates on our website or via other marketing funnels. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at partners@Karamba.com
- Information we collect from third parties: We collect Personal Information from third party service providers, such as information about your credit history from credit agencies and other financial information which is relevant to the provision of the Services, as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.
The second type of information is un-identified and non-identifiable information pertaining to an Affiliate, which may be made available or gathered via the Affiliate’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the Affiliate’s operating system, type of browser, screen resolution, and browser and keyboard language.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
The Services are not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Services of any jurisdiction, whichever is higher (“Legally of Age”). If you are not Legally of Age, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we may discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at partners@Karamba.com.
CONDITIONS FOR PROCESSING OF PERSONAL INFORMATION
We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws.
- Fulfillment of a contract, compliance with a legal obligation
It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for the Affiliate Agreement) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of our gambling licenses and complying with any AML and KYC legislation.
- Legitimate interests
We also process your Personal Information where we deem such processing to be in our (or a third party’s) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate/subsidiary companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network; (iii) safeguarding the integrity of our Services by combatting, reporting and sharing information related to suspicious betting patterns or fraudulent activities; (iv) adhering to regulatory and statutory requirements; (vi) sharing personal information with our advisers and professional services providers (such as auditors) for ensuring our compliance with regulatory requirements and industry best practices.
Our processing of your Personal Information will primarily be necessary for us to provide you with the Services. However, on certain occasions we may ask for your consent to processing Personal Information. In these instances your Personal Information will be processed in accordance with such consent and you will be able to withdraw this consent in writing at any time.
HOW WE USE THE COLLECTED INFORMATION?
We use your Personal Information for the purposes listed below:
- To set up, manage and update your affiliate account;
- To provide and operate the Services);
- To communicate with you and to keep you informed of our latest updates to our Services and special offers;
- To promote our Services by displaying Affiliates’ testimonials of our Services. The testimonials are displayed on our Services as well as on websites operated by our affiliates and partners.
- To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
- For customer relationship management purposes, and to support and troubleshoot the Services and to respond to your queries;
- To enable us to further develop, customize and improve the Services based on Affiliates’ common preferences and uses;
- To identify and authenticate your access to certain features of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
- To investigate violations of our policies and Affiliate Agreement as well as enforce our policies and the Affiliate Agreement;
- To investigate and resolve disputes in connection with your use of the Services; and
- As required by law or regulation (such as Know Your Customer (“KYC”) and Anti-Money Laundering regulatory requirements), or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.
The Group will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Group; (ii) Group’s business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to partners@Karamba.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
WITH WHOM WE SHARE INFORMATION?
We share Personal Information with any of the following recipients:
- Companies within the Group and other affiliated companies;
- Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
- Credit reporting agencies;
- Payment service providers, payment processors and banks;
- To any third parties who provide services in relation to the operation or promotion of our applicable service;
- Auditors, contractors or advisers of any of the Group’s business processes;
- To any third parties in the context of investigating, detecting or preventing fraudulent or illegal activity, or any violations of our policies and Affiliate Agreement (e.g. governmental authorities, police, banks and other investigatory organizations);
- Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
- Storing such information on our behalf, for example by using cloud computing service providers;
- Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
- Performing research, technical diagnostics or analytics;
TRANSFER OF INFORMATION
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.
THIRD PARTY TRACKING TECHNOLOGIES
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies”).
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Affiliates, advertisers, publishers, customers and partners.
RETENTION OF PERSONAL INFORMATION
If you have registered with an account through our Services, the Group will retain your Personal Information during the period your account is active. In addition, the Group will retain your Personal Data for additional periods, to enable the Group to meet its legal obligations under applicable laws or regulations, such as the applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations.
In addition, the Group may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Group’s legitimate interests, such as fraud prevention and record keeping.
You may contact us at any time by email (at: partners@Karamba.com, and request:
- To access or delete any Personal Information relating to you;
- To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
- That we will restrict or cease any further use of your Personal Information;
- That we will provide the Personal Information you volunteered to us in a machine-readable format.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
HOW WE KEEP YOUR INFORMATION SECURED
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
HOW TO CONTACT US
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at partners@Karamba.com, or by sending a letter to:
Attn: Data Protection Officer
135, High street, Sliema SLM 1549, Malta
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.