Version 1 · Last updated 6 October 2026
Privacy Policy
1. Who we are
Battlecat Gaming Ltd is the controller of the personal data described in this Privacy Policy. In this policy, "Battlecat Partners", "we", "us" and "our" mean Battlecat Gaming Ltd.
| Company | Battlecat Gaming Ltd, incorporated in Malta |
| Registration number | 5913-5647-9811-1808 |
| Registered address | 170 Pater House Level 1 (Suite A318), Birkirkara, Malta |
| Programme website | www.battlecatpartners.com (the "Affiliate Site") |
| Privacy contact | info@battlecatpartners.com |
This policy forms part of the Affiliate Agreement. Capitalised terms not defined here have the meaning given in the Battlecat Partners Program Terms and Conditions.
2. Who this policy covers
This policy explains how we handle personal data about people who apply to, take part in, or enquire about the Battlecat Partners Program.
It covers:
- individuals who apply to become, or are, Affiliates;
- directors, owners, employees and other contacts of Affiliates that are companies;
- Sub-Affiliates and prospective affiliates introduced to us; and
- visitors to the Affiliate Site.
It does not cover:
- players who register or play on our Brand Websites. Each Brand Website has its own privacy policy; or
- visitors to an Affiliate's own websites and channels. The Affiliate is responsible for that data (see section 12).
3. Personal data we collect
We collect only the personal data we need to run the Affiliate Program, pay Commission and meet our legal duties.
| Category | Examples |
|---|---|
| Identity | Name, username, date of birth, company name and your role in it |
| Contact | Email address, telephone number, postal address, country, messaging handles |
| Account | Affiliate ID, tracking codes, login details, account settings and preferences |
| Financial and tax | Bank or e-wallet details, chosen payment method, VAT or tax number, invoices, Commission and payment history |
| Verification | Identity documents, proof of address, company documents, ownership details, sanctions screening results |
| Marketing channels | Your website addresses, traffic sources and promotional methods |
| Technical | IP address, device and browser type, log data, cookie identifiers |
| Communications | Emails, chat messages and support requests exchanged with us |
We do not ask for special categories of personal data, such as health data or political opinions. Please do not send them to us.
4. How we collect personal data
Most of the personal data we hold comes directly from you.
- From you: when you submit an Affiliate Application, use your Affiliate Account, choose a payment method or contact us.
- Automatically: when you use the Affiliate Site, through cookies, server logs and similar technology (see section 6).
- From third parties: our affiliate platform provider, payment providers, identity verification and sanctions screening providers, fraud prevention services, and public sources such as company registers and your own websites.
- From other Affiliates: when an Affiliate introduces you to us as a Sub-Affiliate.
If you give us personal data about someone else, such as an employee, you must tell them and show them this policy.
Some data is required to open an Affiliate Account or to pay Commission. If you do not provide it, we may be unable to accept your application or make payments.
5. Why we use personal data and our legal bases
We use personal data only where the GDPR gives us a legal basis to do so. The table sets out each purpose and the basis we rely on.
| Purpose | Data used | Legal basis (GDPR Article 6(1)) |
|---|---|---|
| Assess your Affiliate Application and open and manage your Affiliate Account | Identity, contact, account, marketing channels | Performance of a contract (b). For staff of a corporate Affiliate, legitimate interests (f) |
| Track referrals and calculate and pay Commission | Account, financial and tax | Performance of a contract (b) |
| Verify identity and carry out due diligence, anti-money laundering and sanctions checks | Identity, verification, financial and tax | Legal obligation (c) where the law requires the check. Otherwise legitimate interests (f) in knowing who we pay |
| Keep accounting and tax records | Financial and tax | Legal obligation (c) |
| Monitor compliance with the Affiliate Agreement, prevent fraud and protect our brands | Marketing channels, technical, communications, account | Legitimate interests (f) |
| Send service messages, such as changes to terms, payment notices and security alerts | Contact, account | Performance of a contract (b) |
| Send programme news, offers and promotions | Contact | Legitimate interests (f), or consent (a) where the law requires it |
| Run, secure and improve the Affiliate Site | Technical, account | Legitimate interests (f) |
| Use non-essential cookies, such as analytics | Technical | Consent (a) |
| Establish, exercise or defend legal claims and respond to regulators | Any category that is relevant | Legitimate interests (f) or legal obligation (c) |
Where we rely on legitimate interests, we have weighed them against your rights. You can object at any time (see section 11).
You can opt out of programme news and promotions at any time, using the link in each message or by emailing us. Service messages will still be sent.
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.
6. Cookies and tracking technology
The Affiliate Site uses cookies, and our tracking links use identifiers to attribute referred players to the right Affiliate.
| Type | What it does | Basis |
|---|---|---|
| Strictly necessary cookies | Keep you logged in, remember settings and protect the Affiliate Site | Needed to provide the service. No consent required |
| Analytics cookies | Show us how the Affiliate Site is used so we can improve it | Set only with your consent |
| Referral tracking | Records that a visitor clicked your tracking link, so resulting New Customers are credited to you | Covered by the cookie notice and privacy policy of the relevant Brand Website |
You can change your cookie choices at any time through the cookie banner on the Affiliate Site or your browser settings. Blocking strictly necessary cookies may stop the Affiliate Site from working.
Our Cookie Policy, available on the Affiliate Site, lists the cookies the Affiliate Site sets and explains how to manage them.
The statistics in your Affiliate Account are aggregated or shown against player reference numbers. They do not identify players by name or contact details.
7. Who we share personal data with
We share personal data only with the recipients below, and only as far as each purpose requires. We do not sell personal data.
- Group companies: companies in our group that operate the Brand Websites or support the Affiliate Program.
- Service providers: our affiliate tracking platform, hosting and IT providers, email and communication tools, and identity verification and sanctions screening providers. They act on our instructions under a written contract.
- Payment providers and banks: to pay your Commission.
- Professional advisers: lawyers, auditors, accountants and insurers.
- Authorities: gaming regulators, tax authorities, law enforcement, courts and other public bodies, where the law requires or permits it.
- Buyers and successors: a party acquiring all or part of our business, subject to confidentiality.
- Referring Affiliates: an Affiliate who introduced you as a Sub-Affiliate may see limited information about your account activity, where our Commission Structures provide for it.
8. International transfers
Some of our service providers and group companies may be located outside the European Economic Area (EEA), so personal data may be processed there.
Where we transfer personal data outside the EEA, we rely on one of these safeguards:
- a European Commission decision that the destination country provides adequate protection; or
- the European Commission's standard contractual clauses, with extra safeguards where needed.
You can ask us for a copy of the safeguards that apply to your data.
9. How long we keep personal data
We keep personal data only for as long as the purpose requires, then delete or anonymise it.
| Data | How long we keep it |
|---|---|
| Unsuccessful or withdrawn applications | 12 months after our decision |
| Affiliate Account, contract records and communications | For the term of the Affiliate Agreement and 5 years after it ends |
| Financial, payment and tax records | 10 years from the end of the financial year they relate to |
| Verification and due diligence records | 5 years after the Affiliate Agreement ends, or longer where the law requires |
| Marketing preferences | Until you opt out. We then keep a suppression record so we do not contact you again |
| Technical and security logs | 12 months |
The longer periods reflect the record-keeping and limitation periods that apply to us under Maltese law.
We may keep data for longer where we need it for a dispute, an investigation or a legal claim, including while Commission is withheld under the Affiliate Agreement.
10. How we keep personal data secure
We use technical and organisational measures designed to protect personal data against loss, misuse and unauthorised access.
These include encryption of data in transit, access restricted to staff who need it, confidentiality obligations for staff and providers, and regular review of our systems.
No system is completely secure. If a personal data breach is likely to put your rights at high risk, we will tell you and the regulator as the law requires.
You are responsible for keeping your login details confidential, as set out in the Terms and Conditions. Tell us immediately if you suspect unauthorised use of your Affiliate Account.
11. Your rights
You have the following rights over your personal data under the GDPR. Some apply only in certain circumstances.
| Right | What it means |
|---|---|
| Access | Ask for a copy of the personal data we hold about you |
| Rectification | Ask us to correct inaccurate or incomplete data |
| Erasure | Ask us to delete your data where we no longer have a reason to keep it |
| Restriction | Ask us to limit how we use your data while a query is resolved |
| Portability | Receive the data you gave us in a commonly used, machine-readable format |
| Objection | Object to processing based on legitimate interests, and to direct marketing at any time |
| Withdraw consent | Withdraw any consent you have given. This does not affect earlier processing |
To exercise a right, email info@battlecatpartners.com. We may ask for information to confirm your identity.
We respond within one month. We may extend this by up to two further months for complex or numerous requests, and will tell you if so. Requests are free unless they are manifestly unfounded or excessive.
12. Player and visitor data: your responsibilities as an Affiliate
You are responsible for the personal data you collect through your own websites, email lists and marketing channels. For that data, you and we each act as an independent controller. Neither of us processes it on the other's behalf.
As an Affiliate you must:
- comply with the Applicable data privacy laws, including the GDPR and the national laws implementing the ePrivacy Directive in the countries you operate in or target;
- tell your visitors about the cookies and tracking technology you use, including our tracking links, and obtain their consent where the law requires it;
- send electronic marketing only to recipients who have given valid consent, keep a record of that consent, and honour opt-outs promptly;
- never market to anyone you know to be under 18 or self-excluded from gambling; and
- not send us personal data about your visitors or subscribers unless we have agreed to it in writing.
We do not give Affiliates access to personal data about players, other than the limited reference data shown in your Affiliate Account. You must not try to identify or contact players using that data.
13. Age restriction
The Affiliate Program is open only to people aged 18 or over. We do not knowingly collect personal data from anyone under 18.
If we learn that we hold data about someone under 18, we will close the account and delete the data, unless the law requires us to keep it.
14. Changes to this policy
We may update this policy from time to time. The version number and date at the top show when it was last changed.
We will tell you about material changes by email or by a notice in your Affiliate Account before they take effect, in line with the notice period in the Terms and Conditions.
15. Questions and complaints
If you have a question or concern about how we handle your personal data, please email info@battlecatpartners.com first so we can try to resolve it.
You also have the right to complain to a data protection authority. Our lead authority is the Office of the Information and Data Protection Commissioner (IDPC) in Malta.
| Address | Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta |
| Telephone | +356 2328 7100 |
| idpc.info@idpc.org.mt | |
| Website | idpc.org.mt |
If you live or work in another EEA country, you may instead complain to the data protection authority there.