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GVC Services Limited Privacy Policy

1. PRIVACY

We are GVC Services Limited of Suite 711, Block 7, Europort, Gibraltar, and We are committed to protecting your Personal Information. We have created this Privacy Policy to let you know what information We collect when you participate in the Affiliate Network at the Cozy partners Website (collectively, the 'Affiliate Network'), why We collect this information and how We use the collected information.
Please note that this Privacy Policy will be agreed between you and GVC Services Limited and the GVC Group, being GVC Holdings PLC together with its Group companies as defined in the Standard Affiliate Agreement (Cozy partners', 'We', 'Us' or 'Our', as appropriate).

We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the modified terms on the Cozy partners Website. We recommend that you revisit this Privacy Policy regularly.

2. INFORMATION WE COLLECT

We consider information that may be used to identify an individual, including, but not limited to, first and last name, date of birth, bank account details, home or other physical address, email address, phone number or other contact information to be Personal Information ('Personal Information').

Personal Information you provide to Us

You may be asked to provide Personal Information when you use the Cozy partners Website, open an affiliate account or to use the Affiliate Network. The Personal Information that We collect may include information such as: contact information (including telephone number), shipping information, billing information, transaction history, website usage preferences, and feedback regarding the Affiliate Network. From time-to-time, We may request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary, and, therefore, you have the choice of whether or not to disclose such information. Information requested may include contact information (such as name, correspondence address and telephone number), and demographic information (such as zip or postal code or age).

Personal Information we collect about you

In addition, when you interact with the Affiliate Network, Our servers keep an activity log unique to you that collects certain administrative and traffic information including: source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. This information is essential for the provision and quality of the Affiliate Network.
We reserve the right to conduct a security review at any time to validate your identity, age, the registration data provided by you and to verify your use of the Affiliate Network and your financial transactions for potential breach of Our Standard Affiliate Agreement and of applicable law. Accordingly, We (along with Our staff, agents and suppliers) shall be able to use your Personal Information and disclose your Personal Information to third parties for the purposes of validating the information you provide to Us in the course of using the Affiliate Networks, including, where necessary, the transfer of information outside of your country. Security reviews may include but are not limited to ordering a credit report and/or otherwise verifying the information you provide against third-party databases. We may also receive Personal Information from customer lists lawfully acquired from third-party vendors.

3. HOW WE USE YOUR INFORMATION

We process your Personal Information so that We can perform Our everyday functions.
In particular, We use your information:
• Where We have obtained your consent (and before any withdrawal of your consent – see below “Your Rights”). For example, you may have given your consent to marketing,
• Where it is necessary for the performance of a contract with you. This includes the following:
    o to provide customer support; and
    o to process any of your online transactions.
• Where it is in line with Our legitimate business interests. This includes the following:
    o to undertake necessary security and identify verification checks;
    o to meet certain business requirements;
    o to provide you with promotional offers and information regarding Cozy products and services;
    o in order for the Cozy to better provide a range of products and services and improved customer service; and
    o for any other purpose related to the operation of the Affiliate Network.
Where We have relied on Our legitimate interests to process your Personal Information, you may contact Us to obtain more information, including in relation to Our assessment of the impact on you.

4. HOW LONG WE KEEP YOUR INFORMATION

We only keep your information for as long as is reasonably necessary for the purposes set out in this Privacy Policy and to fulfil Our legal obligations.
In summary, however, We keep:
• your information and correspondence for 6 years post-termination of your account;
• otherwise, we only keep Personal Information for as long as is necessary.
We will securely erase as or anonymise your information in advance of these deadlines if We decide that We no longer need it.

5. YOUR RIGHTS

You have the following rights regarding your information:

Rights What does this mean?
1. Right to be informed You have the right to be provided with clear, transparent and easily understandable information about how We use your information and your rights. This is why We are providing you with the information in this Privacy Policy.
2. Right of access You have the right to obtain access to your information (if We are processing it), and other certain other information (similar to that provided in this Privacy Policy).
3. Right to rectification You are entitled to have your information corrected if it is inaccurate or incomplete.
4. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for Us to keep using it. This is not a general right to erasure; there are exceptions.
5. Right to restrict processing You have rights to ‘block’ or suppress further use of your information. When processing is restricted, We can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. Right to data portability You have the right to obtain and reuse your Personal Information in a structured, commonly used and machine readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
7. Right to withdraw consent If you have given your consent to anything We do with your Personal Information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything We have done with your Personal Information with your consent up to that point is unlawful).

To exercise any of these rights at, any time, you can contact Us using the details set out at the end of this Privacy Policy.

Right to object to processing

In addition to the above rights, you also have the right to object to certain types of processing, in certain circumstances. In particular, the right to object to the processing of your Personal Information based on Our legitimate interests grounds (including processing for direct marketing).

6. DISCLOSURES

We may disclose your Personal Information if required to do so by law, or if We believe in good faith that such action is necessary to: (1) comply with any legal process served on Us, any of Our sites or the Affiliate Network or in circumstances where We are under a substantially similar legal obligation; (2) protect and defend Our rights or property; or (3) act to protect the personal safety of users of the Affiliate Network or the public.
We also share your Personal Information with group companies and with our suppliers. Specifically:
• If, in Our sole determination, you are found to have cheated or attempted to defraud Us, or any other user of the Affiliate Network in any way including but not limited to game manipulation or payment fraud, or if We suspect you of receiving or making fraudulent payments, including use of stolen credit cards, or any other fraudulent activity (including any chargeback or other reversal of a payment) or prohibited transaction (including money laundering), We reserve the right to share this information (together with your identity) with other online gaming sites, banks, credit card companies, and appropriate agencies.
• Further, to take part in the Affiliate Network, you will be required to receive money from Us. We may use third-party electronic payment processors and/or financial institutions ('ESPs') to process such financial transactions. We take steps to ensure that Our arrangements with ESPs protect your privacy.

7. SECURITY

We understand the importance of information security and the techniques needed to secure information. We store all of the Personal Information We receive directly from you in a password-protected database residing within Our secure network behind active state-of-the-art firewall software. The Cozy partners Website and the Affiliate Network support SSL Version 3 with 128-bit encryption. We take steps to ensure Our subsidiaries, agents, affiliates and suppliers also employ adequate levels of security.

8. PROTECTION OF CHILDREN

The Affiliate Network is not intended for or directed at persons under the age of eighteen (18). Any person who provides their information to Us through any part of the Affiliate Network represents to Us that they are eighteen (18) years of age or older. It is Our policy to uncover attempts by minors to access Our Affiliate Networks which may involve Us having to access and verify your Personal Information. If We become aware that a minor has attempted to or has submitted Personal Information via the online site, We will not accept this information and will take steps to remove such information from Our records.

9. INTERNATIONAL TRANSFERS

We store Personal Information on our servers in Gibraltar and Alderney. Personal Information collected on the Affiliate Network mayalso be stored and processed in any country in which We or Our affiliates, suppliers, ESPs or agents maintain facilities. We take steps to ensure that Our agents, affiliates and suppliers comply with Our standards of privacy regardless of their location.

10. THIRD-PARTY PRACTICES

We cannot ensure the protection of any information collected by any third party administering Our Affiliate Network or any other program, since these third-party online sites are owned and operated independently of Us. Any information collected by these third parties is not governed by this Privacy Policy but by the privacy policy, if any, of such third party. If you have questions about a third party's information practices, please read its privacy policy. We assume no responsibility or liability whatsoever for the practices, actions or policies of such third parties, and We are not responsible for the content or privacy practices of such online sites.

11. MERGERS AND OTHER EVENTS REQUIRING TRANSFER

If We should ever file for bankruptcy, or become insolvent, or be acquired by a third party, merge with a third party, sell all or part of Our assets, or transfer substantially all or part of Our relevant assets to a third party, We are entitled to share the Personal Information and all other information you have provided through the Affiliate Network to potential and subsequent business and merger partners.

12. CONTACTING US AND MAKING A COMPLAINT

Please do contact Us if you have any questions or complaints about this Privacy Policy or about how We handle your information by using the following details:

Address: Customer Affiliate Network, GVC Services Limited , Suite 711, Block 7, Europort, Gibraltar

Email: affiliates@cozypartners.com

If you are not satisfied with Our response or you believe Our use of your information does not comply with data protection law, you can make a complaint to the relevant regulator within your jurisdiction in relation to data privacy (in the UK, being the Information Commissioner). See www.ico.org.uk for more information.