It is important that You read and understand these terms and conditions (the “Affiliate Agreement”, “Agreement”). This Agreement along with Your Affiliate Application Form, Insertion Order and any other guidelines or additional terms We provide You with via email or on Our Website (together the “Affiliate Agreement”) represent the complete terms and conditions that apply to You in relation to Your participation in the Spinko Partners affiliate program (the “Affiliate Program”). In the event that the provisions of the Affiliate Application Form conflict with the provisions of this Agreement, the provisions of this Agreement prevail. In the event that the provisions of the Insertion Order conflict with the provisions of this Agreement, the provisions of the Insertion Order prevail.

References in this Agreement to: (a) “You”, “Your” and/or “Affiliate” mean the individual or entity that registered as an affiliate via the Affiliate Application Form as submitted through the Website (the “Affiliate Application Form”), (b) “We”, “Our”, “Us”, the “Company” refer to Spinko Partners, operated by ALEXYAN VENTURES Ltd, a company incorporated under the Laws of Bulgaria and bearing company registration number BG208331755 and currently having its registered office 65 Veslets Str, 1202, Sofia , Bulgaria – where the context applies – also any of its shareholders, officers, directors, employees, advisors, consultants and any of its associated and/or affiliated legal and natural persons, and (c) “Operator” means any online gambling operator which uses the Affiliate Program. If You have any questions or concerns about these Affiliate Terms or the Program Terms and Conditions or the Affiliate Program itself, please email Us at info@spinko.partners

1. THE GOAL OF COOPERATION

• The goal of cooperation under these Terms and Conditions is the promotion of the websites directly indicated by the Company (the “Websites”) to be performed by the Affiliate.
• The amount of remuneration payable to the Affiliate should be calculated in a way determined in these Terms and Conditions.

2. ONBOARDING PROCESS

• The potential Affiliate shall read these Terms and Conditions carefully and apply for the Affiliate Program only if he/she agrees with any and all provisions set forth therein.
• The Company assesses the application and then notifies the potential Affiliate about its decision.
• The answer of the Company will be provided in the written form (an email sent to the email address provided by the potential Affiliate).
• Company reserves the right to reject the application without giving any explanations.
• Only one account can be registered by the Affiliate using one IP-address, unless other explicitly agreed with the Company in written.
• Registering more than one account by one Affiliate without prior written consent of the Company will be considered as a fraudulent activity and entails the termination of the cooperation.

3. CONDITIONS

• • Only person over 18 years can apply for the Affiliate Program.
  • Affiliate shall possess the documents, permissions and licenses that are necessary to conduct promotion of the Websites using Company’s advertising materials.
  • Person who enter into agreements with the Company shall be competent and authorized representative of the Affiliate organizations.
  • Upon successful registration into Spinko Partners, the Affiliate will be given access to the Spinko Partners brands banners, texts and images, along with other promotional material. Marketing material may be placed on the Affiliate’s site and which can be utilized via email and/or direct marketing to promote the Brand. The Approved Marketing Materials may not be altered by the Affiliate without our prior written consent.
  • The Affiliate is not permitted to use advertising or create websites or domains containing the Company and/or Brand name(s). The Affiliate shall not purchase keywords, sponsored advertising, or other search services and content that is identical or similar to the Company’s trademarks or other Company Brands with a primary focus to acquire branded traffic from search engines. The result of identification of such sources of traffic will result in the closure of the Affiliate’s account and earnings cancelled.
  • In the event of inactivity and the failure to refer any First Time Depositors (FTDs), we reserve the right to reduce the Affiliate’s commission to a flat rate of 25% until the Affiliate introduce 5 FTDs within a 6-month period. Upon the referral of the 5 FTDs, the Affiliate’s commission will revert back to the standard Revenue Share deal.
  • We reserve the right to terminate any Affiliate account if the Affiliate does not log in or respond to the Company within 180 days after notification by email from us that you have become an Inactive Affiliate.
  • Any player deemed fraudulent or a bonus abuser by the Company, who will self-exclude, voluntarily close their account or who is a duplicate of an existing account, will not be considered for the Cost Per Acquisition (CPA) payment.
  • Where a Chargeback is received against a customer or issuance of credit to a customer takes place; the Affiliate will not be eligible for the CPA payment in respect of the discounted player.
  • We reserve the right to change the commission payment schedule and methods of payment at any time.
  • We reserve the right to refuse New Customers (or to close their accounts) if necessary to comply with any requirements we may periodically establish.
  • Upon termination of the Affiliate Agreement for any reason, all Commission relating to any New Customers directed to Company during the term shall not be payable to the Affiliate as from the date of termination.
  • High-Roller Policy
    If in any given month a Referred Player referred by You generates a negative Net Revenue of at least €5,000, this Referred Player will be deemed to be a “High-Roller”. If the aggregate commissionable Net Revenue in that given month for You is negative then the negative net revenue generated by the High-Roller will be carried forward and offset against future net revenue generated by that High-Roller. The negative balance carried forward cannot be set-off against other Referred Players’ net revenue. The negative balance of a High-Roller will be reduced by future positive net revenue that they generate in subsequent months. A negative balance will not be increased by future negative Net Revenue unless the High-Roller meets the above-mentioned qualifying criteria in subsequent months. You will be able to view all adjustments in order to track the High-Roller’s net break-even point. Adjustments will be made at the end of each calendar month based on the cumulative revenue for the month.
  • A negative balance on one brand can affect the balance on another brand as they are bundled together and payments are not made for each brand separately.
  • Brand bidding: Unless explicitly authorised by us (Spinko Partners), it is formally prohibited for the publisher to bid on any brand keywords related to the name of the Brand of the Advertiser on any “pay per click” platform.
    Failure to respect these methods may result in the exclusion of the Publisher from the involed program and pending payment might be suspended as well as any “on hold” commission from your account.

4. RESPONSIBILITIES OF THE COMPANY

The Company shall:

• provide the Affiliate with all the information and marketing data needed for advertising and promoting the Websites;
• control the trafficking, keep a record of the net revenue, as well as of the total amount of remuneration for which data should be made available to the Affiliate;
• pay the remuneration to the Affiliate, in the amount based on the traffic generated and size of all revenues deriving from the players introduced by the Affiliate.

5. RESPONSIBILITIES OF THE AFFILIATE

The Affiliate shall:

• make all the efforts and use all the possibilities for advertising, marketing and promotion of the Websites indicated by the Company to introduce new players to the Websites;
• comply with any and all applicable laws in regulations in the course of the advertising activity;
• perform marketing activities using the link(s) provided by the Company.
• Any data, that is not directly provided by the Company, should be used for marketing purposes only after receiving a prior written permission from the Company.
• The Affiliate shall provide the Company with the reliable information about the identity of the Affiliate, including contact details, payment history, and address.
• The Affiliate shall compensate damages and costs resulting from any violations of any applicable rules or conditions committed by the Affiliate.

6. RESTRICTIONS AND LIMITATIONS

The Affiliate shall not:

• carry out illegal actions in the development of own websites, or to fill them with sexual, pornographic and obscene materials;
  attract players under 18 years old to the Websites;
• sign up as a player or make deposits directly or indirectly to any account by using own tracking links for personal use and/or use of his/her relatives, friends, employees or third parties, or in any other way attempt to artificially increase the amount of remuneration or defraud the Company;
• use of any kind of fraud to increase Affiliate`s own profit;
• send spam or post fake meta tags in the websites;
• use the promotional brochure without the prior consent of the Company;
• create own websites similar to the Websites indicated by the Company, imitate the design of the Websites to mislead the potential players and use such copy websites for marketing purposes;
  use domain names containing wholly or in any part the trademarks contained in the promotional materials provided by the Company;
  bid on keywords or search terms related to our brands without our prior consent
• have access to any Personal Data of Company’s customers.
• used domain names containing wholly or in any part the name of any of the Websites;
• offer any cash-back / value-back or similar programs, other than such programs as are offered on the Operator Websites.
  offer refunds and promotions.
• Affiliates are strictly prohibited to open personal accounts on the Websites. If such a fact is detected, the company operating the appropriate Website will immediately block personal accounts of the Affiliate and of the players he has introduced, and the funds from all those accounts will be written off in favor of the company operating the appropriate Website. Family members of the Affiliate and people who are close to him/her are also falling within the scope of this rule. The violation of this provision will be considered as a fraud.

7. PAYMENTS

• The number of the players introduced affects the Affiliate’s remuneration. Potential players who have registered on the Website by clicking the Affiliate`s link and became players of one of the Websites indicated by the Company shall be deemed as the players introduced by the Affiliate.
• The amount of total income affecting the amount of Affiliate`s remuneration is the net revenue generated by the player without refunds or winnings, promotions or special offers.
• Payments to the Affiliate are made until the last day of every month for the previous. The payment shall be done if the minimum goal of EUR 200 (two hundred euros) has been reached. In a case if the last day of the month is not a business day – the payment can be postponed to the next business day.
• If there are less than EUR 200 on the account of the Affiliate, the payment shall be postponed to the next month and will be credited to Affiliate`s account when the minimum goal will be reached.
• An Affiliate needs to have at least 3 FTDs brought in the respective calendar month to qualify for a payment.
• The Affiliate can choose the payment method himself during registration.
• If the Affiliate finds any errors in the calculation of the remuneration, the Affiliate has the right to request a recalculation. In the case of wrong calculation, the remaining funds will be deposited as soon as it would be reasonably possible. If the Affiliate has questions about the number of payments, he/she can contact the Company by sending an email to info@spinko,partners, specifying the cause of the issue. The letter should be sent after the accrual of remuneration, and not later than 30 calendar days after the accrual date.
• If the Company needs to verify the conformity of all the operations, the Company has a right to delay payments up to 180 days.
• Funds that were received by using any fraudulent actions should be returned to the Company.
• To get a payment for a specified period, the Affiliate shall introduce at least 5 (five) active players for the last three months.
  Zero or negative balances shall not be transferred.

8. TERMINATION

• The notification of termination of cooperation shall be sent by email. Upon termination, the Affiliate shall remove all the related contacts and links.
• All understanding existing between the Affiliate and the Company shall be automatically canceled upon termination.
• If the cooperation is terminated by the Company due to the violations of these Terms and Condition committed by the Affiliate, the Company has the right to hold the funds.
• The Company has the right to refuse to work with any Affiliate without giving explanations.

9. WARRANTIES

• The Company does not guarantee the continuous performance of the Websites or their availability at any time or in any place.
• The Company shall not be liable for any damages resulting from interruptions, failures or delays in the Website’s performance.

10. FORCE MAJEURE

• In case it is impossible to fulfill obligations hereunder as a result of any emergency or inevitable events under the given conditions (force majeure circumstances, circumstances of insuperable force) which objectively prevent the fulfillment of obligations under the Agreement, the Parties shall be released from liability for partial or complete non-fulfillment of such obligations provided the Parties comply with the following provisions of the Agreement. Such circumstances (hereinafter referred to as the “Force Majeure Circumstances”) may include, but are not limited to: military actions, declared and undeclared war, armed conflicts, acts of terrorism, revolution, blockade, strike, accident, fire, explosion, prohibition (restriction) of export/import, epidemic, hurricane, flood, earthquake, other natural disasters, etc.
• If a Party fails to fulfill its obligations in time under the Force Majeure Circumstances, such Party shall send to the other Party a written notice of partial or complete non-fulfillment of its obligations under the Agreement, together with the  indication of the specific circumstances of Force Majeure that prevent that Party from fulfilling its obligations as well as the cause-effect relationship between such circumstances and the impossibility of proper fulfillment of obligations. Such notice must be sent as soon as possible (but no later than in 5 (five) working days since the date it becomes objectively possible).
• In case of occurrence of the above-mentioned circumstances, the period of performance of contractual obligations shall be postponed in proportion to the time during which these circumstances or their consequences will be valid, but not more than 60 calendar days. A sufficient confirmation of the occurrence and validity of the above-mentioned circumstances will be a certificate issued by the appropriate authority.

11. MISCELLANEOUS

• Тhe Company reserves the right to amend any of the provisions stated herein without the prior notice. The Affiliate shall check the Terms and Conditions page from time to time to familiarize himself with the changes and amendments thereto. In case the you disagree with any of the changes, you shall immediately notify the Company in writing by sending the appropriate notice to the info@spinko,partners, otherwise you will be deemed agreed with any and all changes to the Terms and Conditions.
• The Company is entitled to process the personal data of the Affiliate, including but not limited to email addresses, transaction details, IP addresses, name and surname.

12. CONFIDENTIALITY

• In the course of cooperation, the Affiliate may receive the information regarding the Company that shall be considered as confidential information.
• Confidential information shall include, inter alia, any information about the Company that is not publicly available, including the information about its organization structure, employees, affiliated companies, partners, business activity and marketing plans, as well as any other information that should be deemed confidential in accordance with the applicable rules and regulations.
• The Affiliate shall not disclose any confidential information without the prior written consent of the Company except the cases of forced disclosure required in accordance with the applicable legislation. In case of forced disclosure, the Affiliate shall immediately notify the Company about the fact of the disclose and the scope of the confidential information subject to disclosure.

Introduction

“We”, “our”, and “us” means Spinko Partners which provides marketing services to a number of brands operated by its Group, or the relevant company in the Spinko Partners Group, as the case may be. “You”, and “your” means the individual or entity that has agreed to promote us in return for commission payable in respect of the players who are referred to us in accordance with an Spinko Partners Programme Agreement.

We have provided this privacy policy to help you understand how we collect, use and safeguard your information and those of the players referred by you to us for the purpose of operating our online casino and poker services. You should read this notice in conjunction with our terms and conditions for use of this site or any other sites operated by us.

Personal information

We collect personal information when you and/or your referred players, as applicable, use our online gambling services, join our affiliate program, make customer inquiries, register for information or other services, or when you respond to us. Selected third parties, to whom you and /or your referred players, as applicable, have chosen to disclose personal information, may also provide us with personal information. The types of personal information we may collect could include, for example, your name and e-mail address, home address, telephone number, debit/credit card data and lifestyle and other information collected on registration or through online surveys or questionnaires.

We may publicize any major winnings earned by your players by simply giving their username, country of origin, amount of winning and associated game – whereby you agree to this limited use of their details for this sole purpose, unless you otherwise contact us to demonstrate that your players wish to revoke such implied consent, where we will then follow up with them.

How your and/or your referred player’s information is processed

Your and/or your referred player’s information may be disclosed for processing to:

any other companies within Spinko Partners and their employees,
any third party service providers who use your and/or your referred player’s personal information to provide services to us – such as: payment settlement service providers, marketing service providers, data verifiers and financial institutions, to the extent necessary for the completion of payments, joint marketing campaigns, to facilitate the opening of new accounts, and fraud prevention for services provided through our website
any auditors or contractors or other advisers auditing any of Spinko Partners’ business processes or
potential purchasers or investors in any company within Spinko Partners
Any processing performed by any recipients will be governed by a data processing agreement in the form and substance required by applicable law, thereby preserving your and/or your referred player’s rights under applicable data protection laws.

Your responsibility towards your referred players

If you yourself receive and process personal information from players that you subsequently refer to us then you shall ensure that: (i) the players have been informed of the purposes for which their personal information will be processed by us (as set out in this Privacy Policy) and have given their express consent to such transfer to and processing by us; and (ii) this personal information is processed and transferred by you to us in accordance with relevant laws but in any event under terms no less stringent that those set out herein. You agree to indemnify us against all claims and associated costs brought against and suffered by us due to your breach of this clause.

To whom your and/or your referred player’s information is disclosed (“recipients”)

We ensure that your and/or you referred player’s information will not be disclosed to government institutions or authorities unless:

we have your and/or your referred player’s written consent to share such personally identifiable information with third parties,
we require your and/or your referred players personally identifiable information to provide the services that you have requested (if any)
necessary to enable us to respond to subpoenas, court orders or legal processes or
we find that your and/or your referred player’s actions on our websites violate our terms of service, or any of our usage guidelines for specific services.
In addition, we reserve the right to disclose and transfer your and/or your referred player’s personal data to our respective payment settlement service providers and financial institutions to the extent necessary for the completion of payments for services provided through our website.

Security

Keeping your and/or your referred player’s data safe is our paramount concern.

Internal access to all data is limited and strictly monitored. We have implemented suitable security policies, rules and technical measures to protect and safeguard the personal data under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.

All our employees and data processors or handlers who have access to, and are associated with the processing of your and/or your referred player’s personal information, are obliged to respect the confidential nature of your and/or you referred player’s information pursuant to applicable data protection and privacy laws.

You acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorized third party.

Cookies

We may send you and/or your referred players a permanent cookie when you or they register with us. A cookie is a small file that can be placed on your and/or your referred player’s computer hard disk for record-keeping purposes. Cookies can help us to recognize you and/or your referred players when you or they next visit our website, note the advertisements you or they click on and the other sites you or they enter via a link from our website. This allows us to tailor the service we provide to your or their preferences.

We may also use the data generated from cookies to compile statistical data on your and/or your referred players use of our website. You and/or your referred players are not obliged to accept a cookie from us or from any other website. You and/or your referred players can modify your browsers so that it will not accept cookies. Please consult the “Help” section of your and/or you referred player’s browser for instructions on how to do so correctly. However, please note that, for legitimate security reasons, we may refuse access to specific website content unless you and/or you referred players accept the use of a cookie or similar device.

Protection of Minors

The services provided on this website are not intended for or directed to minors or persons under the age of legal consent. Any person who provides their information to us represents to us that they are 18 years of age or over the age of legal consent in their jurisdiction. We reserve the right to access and verify any personal information submitted by or collected from your referred players. If we become aware that a minor has attempted to or has submitted personal information via this website, we may not accept this information and may take steps to remove such information from our records.

Transfer outside the European Union

It may be necessary to transfer your and/or your referred player’s personal information to other companies within Spinko Partners located in countries outside the European Union. This may happen if any of our servers or members of Spinko Partners are located or based outside the European Union, if you and/or your referred players use our services and products while visiting countries outside the European Union or if we transfer your or their personal information to such companies for purposes in respect of which you or they will receive advance notice.

The data protection, privacy and other laws of these non-European Union countries may not be as comprehensive and in these instances we will always take steps to ensure that a similar level of protection is given to your and/or your referred player’s information and that it is kept secure. By submitting your and/or your referred player’s personally identifiable information to us, you consent (and shall ensure that your referred player’s consent) to the use of that information as set out in this Privacy Policy.

Updates to Privacy Policy

We reserve the right to amend or modify this Privacy Policy at any time, including in response to changes in applicable data protection and privacy legislation applicable to the Group. If we change our Privacy Policy we will post the changes on this page, and may place notices on other pages of the website, so that you may be aware of, and inform your referred players of, the information we collect and how we use it at all times. Your continued use of this website and the service, following the posting of changes to this Privacy Policy, will mean you accept these changes and have ensured that your referred players accept any such changes, so please check this page regularly.

Contact us

You may request details of your and/or your referred player’s personal information kept by us by following the contact information set out below. Once we receive such a request we will ask you and/or your referred players to verify you or their identity by providing relevant information or documentation. We will then request pre-payment of an administration fee of £10 per request and upon receipt of this we will process your and/or your referred player’s request within 40 days.

If you have any inquiry about our data protection and Privacy Policy or practices, or wish to decline receiving e-mail offers from us or from any other companies within Spinko Partners please contact affiliates support by email – info@spinko.partners

This privacy policy was last revised on 05th February 2026.