Fair Affiliate Limited (“Fair Affiliate”, “we”, “us”, or “our”) is dedicated to safeguarding and protecting your privacy. In this Privacy Policy, we inform users of the way in which we gather and use personal data and how we protect the rights of individuals. This Privacy Policy also explains when we might reveal that data with others and how we protect it.

We define personal data as any information pertaining to a person that can be identified or is identifiable (“data subject”) that is still not part of the public domain. Fair Affiliate will go through all the data that is provided regardless of how it is collected. That includes data provided through newsletter subscriptions, Fair Affiliate self-regulatory and testing agency services, and data obtained via any other means or data we hold that relates to you as described in this Privacy Policy or as otherwise stated at the moment the data was collected.  

Personal Data We Collect

We are transparent about how and why we collect personal data and the manner in which we process it. Fair Affiliate will only handle and process personal information if at least one of the following applies:

  • the data subject has agreed and given consent that his personal data is processed for one or more particular purposes;
  • processing is required for a contract to be performed when the data subject is a party in that contract or when steps need to be taken at the data subject’s requests before entering into a contract;
  • processing of data is required for the purposes of complying with legal requirements to which Fair Affiliate is subject;
  • processing is fundamental to protecting crucial interests of the data subject or another individual;
  • processing is required for the execution of a task that is in the public interest or in the performance of the authority bestowed in Fair Affiliate; and
  • processing is vital for the legitimate interests that Fair Affiliate pursues or those of a third party, with the exception of interests that are annulled by the interests or elementary rights of the data subject relating to the protection of personal information, especially when the data subject is a child or a minor.

When interacting with Fair Affiliate, Fair Affiliate might collect data that relates to an identifiable individual or identifies an individual.

  • Dispute Resolution Services
  • We gather and handle personal data when filing a dispute to Fair Affiliate. This data might or might not include a user’s name, surname, address of residence, email address, phone number, ID documents, utility bills, statements, and other documents and data crucial to appropriately handling the dispute.
  • Fair Affiliate Newsletters
  • When subscribing for Fair Affiliate news and updates, we collect the name and email address of the subscriber, as well as the subscriber’s function in the industry.
  • Self-Regulatory Services 
  • Testing Agency Services
  • When we perform our testing services, we might analyze or process personal data, including an individual’s first and last name, ID number, email address, phone number, as well as other pieces of information that are essential to completing our testing services adequately.
  • Potential Employees
  • By applying to work for us, we might gather and analyze an individual’s personal data in line with our Human Resources policies and procedures. This personal data might include the individual’s first and last name, address of residence, email address, ID, utility bills, statements, references, and other information essential to our recruitment and contractual requirements with the potential employee.

Purpose for Collection

Fair Affiliate will only gather your personal data for the intention for which it was gathered, except when we get your consent or when required or allowed by existing legislation or professional standards:

  • Dispute Resolution Services
  • Fair Affiliate collects users’ personal data via a range of dispute forms on the Fair Affiliate Gambling Commission license holder or Fair Affiliate authorized seal holder.
  • Fair Affiliate Newsletter
  • Fair Affiliate might deliver press releases, as well as other types of marketing that relate to new Fair Affiliate users, new eGAP seal owners, self-regulatory requirements updates, Fair Affiliate’s accomplishments, accomplishments of Fair Affiliate’s clients when Fair Affiliate was part of those accomplishments, new executive staff, and new Fair Affiliate services. 
  • Fair Affiliate has tried to get informed consent from our stakeholders when it comes to sending marketing information and email press releases, but each exchange of communication will have an easy opt-out option for future correspondence. However, opting out of receiving press releases and marketing information does not exclude the individual from future communication with a Fair Affiliate representative for services we provide that organization. 
  • Self-Regulatory Services
  • Testing Agency Services
  • We might analyze and handle personal data so that we effectively carry out our testing and fulfill our legal and contractual obligations for providing self-regulation and Testing Agency services
  • Potential Employees
  • We only collect and handle personal data of potential employees per our Human Resources policies and procedures and to accomplish requirements related to staffing.

Personal Data Sharing

Fair Affiliate will not sell, distribute, or share your data with third parties. However, we might reveal your data so that we comply with requests from authorities, regulations and legal obligations.

Security of Personal Data

The security of your data is paramount to Fair Affiliate. We utilize industry-standard systems and means to protect digital data, including data encryption, firewalls, monitoring of potential intrusions, and passwords. We also employ forms of physical security, such as round-the-clock video surveillance of our premises and locking equipment. Accessing personal data is restricted and on a need-to-know basis.  

Holding and Storage of Personal Data

Our personal data retention periods are reviewed regularly. We are obliged by the rule of law to retain some personal data so that we execute our legal requirements (e.g. licensing conditions). We will retain some types of personal information on our systems for the duration of the relevant contract we have with you or for as long as it is needed and necessary.

Personal data is kept on servers in South Africa. It is processed and protected under the South African Protection of Personal Information Act (POPI). Personal data is backed up to servers in the Netherlands and Dublin as well.

Data Subject Rights

All data subjects have the rights listed below for as long as Fair Affiliate is in possession or handless your personal data:

  • Freedom of access – you have the freedom to ask for a copy of the data we possess about you;
  • Right of modification – you have a right to rectify incorrect or incomplete information we possess about you;
  • Right your data to be erased – when possible and when there are well-founded grounds for your data to be erased, you can withdraw consent by emailing [email protected];
  • Right to limit data processing – under certain conditions, you ask us to limit the processing of the data we possess about you;
  • Right of transfer of data – you can ask us to transfer the data we possess about you to a different organization;
  • Right to disagree – you have the right to disagree with and oppose some types of data processing (e.g. direct marketing); and
  • Right to oppose automated processing – you can oppose the legal consequences of automated data processing, including profiling.

If Fair Affiliate rejects requests made on rights of access grounds, we will inform you why we did that. You can legally challenge that action.

At your request, Fair Affiliate can provide you with information about the data we hold about you and how we process it.