PRIVACY NOTICE

Last Updated 08-10-2025

1. Introduction This Platform is operated by White Hat (Holdings) Limited ("we", "us", "our"). We are committed to protecting and respecting the privacy of our affiliate partners ("you", "your").

This Privacy Notice explains what personal data we collect from you, why we collect it, how we use it, who we share it with, and what your rights are in relation to your personal data. This notice applies to our registered affiliates, individuals applying to become affiliates, and visitors to our website, superflypartners.net.

Please read this notice carefully to understand our practices regarding your personal data.

2. The Data Controller

For the purpose of the General Data Protection Regulation (GDPR) and other applicable data protection laws, the data controller is:

White Hat (Holdings) Limited, registered in Gibraltar with company number 109784 and registered office at 2/3b Horse Barrack Lane, Gibraltar.

Email for data protection enquiries: privacy@whitehatgaming.com.

3. What Personal Data We Collect

We may collect and process the following categories of personal data about you:

• Identity & Contact Data: Includes your full name, username, date of birth, email address, postal address, and telephone number.
• Verification (KYC) Data: To comply with our legal and regulatory obligations (such as Anti-Money Laundering), we may require government-issued identification (e.g., passport, driving licence), proof of address (e.g., utility bill), and photographs for identity verification.
• Financial & Payment Data: Includes your bank account details, e-wallet information (e.g., Skrill, PayPal), VAT or tax identification numbers, and transaction history with us (commission payments).
• Business & Traffic Data: Information about your affiliate websites, traffic sources, marketing methods, and business information if you operate as a company.
• Technical Data: Includes your Internet Protocol (IP) address, browser type and version, time zone setting, device type, and operating system.
• Usage Data: Information about how you use our Platform, including the pages you visit, features you use, and performance statistics (e.g., clicks, impressions, conversions).
• Communications Data: Includes your communication preferences and records of any correspondence or communication we have with you via email, support tickets, or other channels.

4. How and Why We Use Your Personal Data (Legal Basis)

We will only use your personal data when permitted by law. Most commonly, we will use your personal data in the following circumstances. We have outlined our purposes for processing and the legal basis on which we rely in the table below.

Purpose of Processing Type of Data Involved Legal Basis for Processing To register you as a new affiliate and manage your account. Identity, Contact, Business Performance of a contract with you. To verify your identity and conduct due diligence checks (KYC/AML). Identity, Contact, Verification Legal Obligation. To track affiliate performance, calculate commissions, and process payments. Financial, Usage, Technical, Business Performance of a contract with you. To communicate with you regarding your account, platform updates, and support. Identity, Contact, Communications Performance of a contract; Legitimate Interest (to keep you informed and manage our relationship). To improve our Platform, services, and marketing efforts. Technical, Usage Legitimate Interest (to analyse and enhance our business operations). To send you marketing communications about our offers, products, and news. Identity, Contact, Communications Consent (where required) or Legitimate Interest (for existing partners, who can opt out at any time). To prevent fraud, ensure network security, and protect our business interests. Identity, Technical, Usage, Financial Legitimate Interest (to protect our platform and partners from fraudulent activity). To comply with tax, accounting, and other legal or regulatory requirements. Identity, Financial, Verification Legal Obligation.

5. Who We Share Your Data With

We may share your personal data with the following third parties for the purposes set out above:

• Payment Service Providers: To process your commission payments.
• Service Providers: Companies that provide IT, hosting, analytics, CRM, and system administration services on our behalf.
• Professional Advisors: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, and accounting services.
• Regulators and Authorities: Government bodies, regulators (such as the UK Gambling Commission or Malta Gaming Authority), and law enforcement agencies, when we are required to do so by law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International Data Transfers

Some of our external third parties may be based outside the United Kingdom (UK) or European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside these regions. Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• The transfer is to a country that has been deemed to provide an adequate level of protection for personal data.
• We use specific contracts approved for use in the UK and/or EU which give personal data the same protection it has in Europe (such as Standard Contractual Clauses).

7. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorised way. Access to your personal data is limited to those employees, agents, and contractors who have a business need to know.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Typically, we will retain your data for the duration of your partnership with us and for a period of up to 5 years after the termination of our agreement to comply with our legal obligations.

9. Your Data Protection Rights

Under data protection law, you have rights including:

• Right of access: You have the right to ask us for copies of your personal information.2
• Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate.3
• Right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
• Right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to object to processing: You have the right to object to the processing of your personal information where we are relying on a legitimate interest.
• Right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Right to withdraw consent: Where we are relying on consent to process your data, you may withdraw that consent at any time.

To exercise any of these rights, please contact us at privacy@whitehatgaming.com.

If, you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to our Supervisory Authority: the Office of the Information and Data Protection Commissioner (IDPC) that governs our company in relation to data protection issues.

https://idpc.org.mt/en/Pages/contact/complaints.aspx.

10. Cookies

Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our site.

A: Cookies

A 'cookie' is a small text file containing small amounts of information which is downloaded to your device when you visit a website or use applications. The cookie enables the server to collect information from the browser. We may use the following types of cookies:

ESSENTIAL COOKIES: Cookies that are essential to the running of a Website. Without the use of cookies, parts of the Website would not function correctly. For example, when logging in to your account a session is created to allow you to browse the site and play games;

ANALYTICAL COOKIES: We use analytical cookies to monitor our Website performance and to determine how visitors use the site. These cookies provide us with information that helps us create better products for our users and to identify areas that may need maintenance. We currently use Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us to analyse how players use our Website. We also use analytical cookies from additional third-party providers;

PERSISTENT COOKIES: These are saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, so the correct language is presented and to improve our users’ experience of the Website as well as present different marketing messages and advertisements for existing users;

FUNCTIONAL COOKIES: Functional cookies are used to remember your preferences on our Website, enhancing the user experience. This can have a range of functions such as remembering your username or recording that you have read a site message so you don’t need to view it again;

SESSION COOKIES: Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server's pages.

We use a number of different cookies on this Website to help us to recognise you, track your activity and improve your use and experience of the Website. In addition, we use a number of third party service providers, who also set cookies on this Website, in order to deliver the services that they are providing to us. Such services include, but are not limited to, helping us to improve your use and experience of the Website by tracking your activity on the Website, measuring the effectiveness of the Website and the effectiveness of our marketing campaigns.

We and/or third parties may use cookies to collect or receive information from the Website and use that information to advertise to you on other websites. You can view the cookies used for such purposes on this Website and opt out of the collection and use of your information for such targeted advertising here: www.aboutads.info/choices

Some people find the idea of a website storing information on their computer or mobile (or other) device intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless, you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set but you need to be aware that you might lose some functions of that website. Most online browsers automatically accept cookies. However, if you wish to restrict or block cookies you can modify your browser settings.

B: Pixels

We also use pixel-based tracking to track a visit or event on the platform and to track advertisements' impressions. This information is also used by us for remarketing purposes and for tracking conversions that are used to optimize our marketing activities. We may share such information (which is non-personal information) with our advertising and marketing partners. Please see specific information about our marketing practices in section 8. By accessing and using the Website and services, you consent to the placement of cookies and pixels on your device in accordance with this Notice.

11. Changes to This Privacy Notice

We may update this privacy notice from time to time. We will notify you of any significant changes by email or through a notice on our site. We encourage you to review this notice periodically.

12. Contact Us

If you have any questions about this privacy notice or our data protection practices, please contact us at: Email: privacy@whitehatgaming.com