Introduction

This policy outlines the different aspects in which your privacy might be concerned using our services. It sets out the requirements and obligations of both you and the website/website owners. Additionally, this document contains details on the way this website deals with, collects and protects your data and information. This policy applies to anyone who uses our website Hispinpartners.com including its subpages ("Website"), anyone who is already a member of our affiliate program (or who applies to become an affiliate) or who interacts with us otherwise. Please be aware that when you use the Hispinpartners.com sites for online gambling, their own privacy policy applies. In this policy we call the Hispinpartners.com “HiSpin Partners” or “us”/“we” and we call you (a visitor/user of our site/affiliate applicant/affiliate etc.) “you”. HiSpin Partners, operated by Silver Ocean Enterprises SRL, a company duly organized and existing under the laws of Costa Rica, incorporated on 25.03.2025, registration number: CE-3-102-929414, registered address: Santa Ana, Pozos, Alto De Las Palomas, Plaza Panorama, Unique Law and Business, San José, Costa Rica. "You," "your" and/or "affiliate" means the person or organization that has agreed to support us in exchange for commission on the players assigned to us in compliance with the HiSpin Partners Terms and Conditions. Should you have any questions regarding your confidential information or want to know why we need it, please contact our Data Protection Officer via email – [email protected]. This document explains how we gather, process and store your personal data. "Personal Data" refers to any information about you that can be used either alone or in combination with other information to identify you as a person. Hispin.com uses the following applications and platforms to provide its services: - This internet website; - Scaleo Affiliate Platform.

Information Collected

‍ Source Affiliate application Collected Data Personal Information and registration details: - specific details about you (first and last name, email address, gender, birth date, physical address, phone number, occupation, etc); - payment details (credit card number, e-wallet account or bank account details). Reason - to maintain our relationship with you; - to set up, manage and update your account; - to provide and operate the Services (such as for payment processing). Retention As long as required to manage the relationship Source ‍ Cookies Collected Data Non-Personal Information: - technical information provided by your device (software and hardware information, type of browser and operating system, language preference, screen resolution, access time and the domain name of the website from which you linked to the Services);- analytics information (e.g. pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, time stamps, alerts,geo-location etc.) Reason - to improve our website, the user experience, troubleshooting errors and bugs; - to conduct analytics, statistical and research purposes; - to provide you with a responsible affiliate marketing environment; Retention As long as required to fulfil the purposes (see section “Cookies”). Source Email, skype Collected Data - collecting information which you provide us voluntarily. For example, records of correspondence we have with you via email or share additional information about yourself through your use of the Services. Reason to communicate with you, to keep you informed of our latest updates; - to market our Services, to serve you advertisements Retention For the duration of the relationship ‍ In addition to all of the above mentioned reasons, your Personal Data might also be used for the purposes listed below: - to help us further build, configure and upgrade our Services on the basis of common customer needs and uses;- to contact you and to manage any of your requests for the exercising of your User Rights; - to give you access to certain features of the Services; - to detect and deter fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect your access to the Services; - to examine and resolve disputes relating to your use of the Services and as required by law or legislation (such as Know The Customer ('KYC') and Anti-Money Laundering regulatory requirements), or as necessary by other government authorities, or to comply with writs or similar legal procedures, or to respond to a court query. We may further use your personal data in order to contact you, to provide you with our services or any events, operations, ventures, schedules, improvements, undertakings and special offers that are made, promoted or funded by HiSpin Partners. You may be contacted by email, live chat, or internal support ticket. When you provide us with your personal information, you accept that, in compliance with this Privacy Policy, you do not find our use of such personal information to be any violation of your rights under GDPR (General Data Protection Regulation). If you decide that you don’t want to receive any advertising and/or marketing materials that we send, you can always opt out. If you want to do so, you are encouraged to contact us.

Cookies Policies

Cookies are small text files created by the websites that are stored on your computer either for the session only or permanently on your hard drive. Cookies are used to register and save preferences, and to collect and save information about your experiences and website use. Cookies are mainly used to “maintain the state” of the browser session. They also allow the website to provide you with a tailor-made experience within the website. We use cookies to keep your personal settings on our Website. By no means do we use cookies to collect information that identifies you personally. Most of our cookies are temporarily stored just for the session, meaning that they are deleted shortly after you leave the page. We use anonymous session cookies (the ones that are deleted when you close your browser) to guide you assist you in navigating through the website and to help you get the most out of our features. When you log into your account, your session cookie will contain your Affiliate ID. This will allow us to check which services and features you are authorized to use. This website uses tracking software which monitors visitors' behavior. that allows us to better understand how visitors use the website. This tracking software stores a cookie on your computer's hard drive that records your activity and engagement on the website but it doesn’t store any personal and confidential information. In case you don’t want this website to use and save cookies on your computer's hard drive, you can go to your browser settings and block all cookies from this website and its external service providers.

Sharing of Information

If it is appropriate to comply with our legal obligations and regulatory requirements or it might be of use to resolve any disputes and/or prevent fraud or violence, we may keep your Personal Information for a longer period. We may also keep confidential versions of your personal information for business analytics purposes where we do not use any automatic decision-making software. HiSpin Partners will manage (collect, archive and use) the data you provide in a way that is consistent with the EU General Data Protection Regulation (GDPR). It will strive to keep your data correct and up-to-date and not to keep it longer than it is required. HiSpin Partners is obliged to keep information needed for income tax and audit purposes in accordance with the law. The period for which certain types of personal data should be kept is also regulated by certain business-sector requirements and agreed practices. Furthermore, personal data may also be kept for individual business needs We share Personal Data with any of the recipients listed below: - Third party affiliate platform provider that we work with (Scaleo); - Third party service providers related to the administration and promotion of the respective Group’s brands (email program providers, internet service providers etc.); - Companies within the frame of HiSpin Partners and other affiliated associations; - iGaming software providers; - Payment solution providers, payment processors and bank institutions; - Any third parties that organize offline events or tournaments on behalf of or along with any companies within the frame of HiSpin Partners; - Accomodation (hotels) and airlines companies (such as for the purpose of offline events and promotions); - Any third parties who investigate, detect or block fraudulent or outlawed activity (e.g. governmental authorities, police, bank institutions and other investigatory bodies); - Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations.We may use your personal data to contact you through various platforms as necessary for the fulfillment of our contractual obligations with you. We may share your Personal Data with third parties as follows: - when you have agreed; as necessary in order to provide you with the services of the Website;as necessary in order to communicate with you; - to execute your instructions; - in the cases when your information is on an anonymous and aggregated basis, meaning you could not be personally identified from it; - as permitted by law or the respective regulation; - in order to comply with any legal requirements, in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of HiSpin Partners (example: third-party gaming regulators); and - in cases when there is a sale of the assets of HiSpin Partners or corporate restructuring, or as a result of a change of the control of HiSpin Partners or one of its group companies, or in preparation of any of these events.We may use your personal data to contact you through various platforms as necessary for the fulfillment of our contractual obligations with you. We share Personal Information with those Recipients for any of the purposes listed below: - To store such data on our behalf, for instance by using cloud computing service providers; - To deal with such information that may assist us with our business operations (e.g. to conduct payments deposits; - To verify your access; to audit our operations; - To detect and prevent fraudulent or outlaw activity; etc.); - To conduct research, technical diagnostics or analytics; - To communicate targeted advertising and promotional materials and information. - On any occasion where we believe in good faith that disclosure is necessary to protect our rights or legal claims, to uphold our rules (including our User Agreement and Privacy Policy), to protect you and others, as well as to prosecute or prevent fraud, for security reasons or to assist us with any other relevant technical issues. Since we do business globally, it may be necessary to transfer your Personal Information to countries outside the European Union. Data protection and other regulations of these countries may not be as detailed as those of the European Union. We make the most of our efforts to ensure that your Personal Information is protected in compliance with our privacy policy, by legal means (such as through the use of contractual clauses authorised by the relevant data transmission regulators) or other ways (such as ensuring that the jurisdiction provides sufficient safeguard for data protection). When you believe that your confidentiality has not been protected in compliance with our policies, or if anyone has attempted to misuse the Services or behaved in an inappropriate manner, please contact our Customer Service directly.

Protection of Minors

Anyone who provides us with their personal information consents to be of the minimum legal age of 18 or over (as per their jurisdiction). The services we provide on this website are not directed to and intended for underaged persons and minors. We have the right to access and confirm any confidential information that is presented by or collected from players you have referred. If we recognise information submitted by a minor via this website, we reserve the right not to accept this information and to take actions to delete it from our records

User Rights

Your rights over your personal information Information access You are entitled to fill in a data subject access request, This means you have the right to demand a copy of your personal data that we keep. You may request updates and modifications in your Personal Data (for instance, if you think that your Personal Information is inaccurate, you may request an update or complete removal). Please note that you may also request that we correct errors in relation to your Personal Information (except in cases where the information is required to be kept in its original format in accordance with any applicable laws and regulations). To be forgotten You can request a complete removal of any of your Personal Data. Please note that this does not clear us from responsibility to fulfill the compulsory retention periods under other laws. To opt-out You have the right to opt out easily by clicking the respective section in the footer of the communication but if you would like to opt out manually, you need to contact the customer support. Data Portability You are entitled to receive personal information in a machine-readable format that you have volunteered. This allows you to obtain and reuse your information in various services for your own purposes. To object In certain cases, you can object to the processing of your personal data, i.e. you have also the right to object to the direct marketing (including profiling) use of your personal information. Furthermore, please be aware that that you can request the right to be forgotten in the following situations: - When your information is no longer of use for the purposes it was initially intended for(as written in our privacy notice); - When you have previously given us permission to use your information, but decide to remove it and we do not have another legal reason to keep it and process it under the data protection law. These rights are not absolute and the requests are subject to any applicable legal requirements, including gambling regulations and other legal and ethical reporting or retention obligations. At any time and at our discretion in accordance with our internal policies, we may also correct, rectify, replenish or remove incomplete or inaccurate information.

Security of Your Data

We are committed to protect your confidential information and we store it securely and process it in the strictest manner. We take all the necessary actions to ensure that the information collected on our website follows this policy and is in line with the strict data protection standards. For our part, we have incorporated all physical and technological security measures to prevent any unauthorized access, to properly use the information you have provided us with, and to safeguard it. These security measures differ in accordance with the sensitivity of the information. We utilize procedures and controls that are standard for the industry. To guarantee the safety of our user’s data we undergo regular information security audits, use encrypted communication and incorporate secure network topology with intrusion prevention and Firewall systems. Despite the fact that we follow all the necessary steps to ensure the safety of your information, we are not accountable for the acts of people who may have unauthorized access or misuse the Services on our website. Therefore, we cannot guarantee that we can prevent such access.

Marketing

The Company uses your Personal Information, such as your name, home address, e-mail address, telephone number, etc.on its own or with our third party subcontractors for the purpose of providing you with promotional materials, relating to the Services as well as products, services, websites and applications related to: (i) other entities within the Group; (ii) or (iii) the Group's business partners and affiliates (collectively: “Marketing Affiliates”). We may also share and reveal Personal Information with our marketing affiliates to provide you with tailor-made promotional offers. Such Personal Data may be used by our Marketing Affiliates for multiple marketing channels, such as personal email, post, SMS and mobile promotional messages. ‍ By contacting HiSpin Partners Affiliate Support at [email protected] or by unsubscribing from receiving marketing materials following the guidelines on our marketing communications (such as clicking on the "unsubscribe" button), you may refuse to receive additional marketing promotions from us or from Marketing Affiliates. Please note that we may continue to send you service-related updates and reminders even if you unsubscribe from our marketing mailing list.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review this section regularly. We will notify you of any substantial changes to this Services Privacy Policy and/or send you an email regarding any such changes to the applicable email address that you have provided to us. All substantial changes shall take place seven (7) days after such notice has been rendered to any of the approaches alluded to above. Therefore, all other amendments to this Privacy Policy will be retrospective as of the specified "last updated" date, and your continued use of the Services after the last modified date would signify approval of, and willingness to be bound by such revisions

Get in Touch

Get in touch Email: [email protected] We try to reach back to you within a reasonable timeframe. Please feel free to contact us at any time. If you are not satisfied with our response, you can raise your issue to the applicable data protection supervisory authority.