Privacy Policy

How AMATO ANGELESKI LTD handles the personal data of affiliates and visitors of the Sturmpartners program. Questions: affiliates@sturmpartners.com

1Who we are

1. 1.1AMATO ANGELESKI LTD, Village Jabokrat 2545, Municipality of Kyustendil, Kyustendil District, Bulgaria, VAT no. BG205550410 ("We", "Us", "Our") runs the Sturmpartners affiliate program at www.sturmpartners.com (the "Site"). We are the controller of the personal data described in this Privacy Policy.
2. 1.2This policy covers affiliates, applicants and their staff, and visitors of the Site. It does not cover players of sturmplay.com, whose data is handled under the Sturmplay player privacy policy.
3. 1.3Questions and requests about your data: affiliates@sturmpartners.com.

2Data we collect

1. 2.1Account and contact data: name, company name, e-mail address, phone or messenger handle, postal address, country, website and traffic sources you tell us about.
2. 2.2Business and tax data: company registration details, VAT or tax number, and, where required, Know Your Business documents such as company extracts and identification of directors or beneficial owners.
3. 2.3Payment data: bank account details or crypto wallet addresses you give us for payouts, invoices and payout history.
4. 2.4Performance data: clicks, registrations, deposits and commission linked to your affiliate ID and tracking links. Player-level data is shown to you only in aggregated or pseudonymised form.
5. 2.5Technical data: IP address, device and browser details, log-in times and cookies when you use the Site or the affiliate dashboard.
6. 2.6Communications: e-mails, messages and notes of calls with our partnerships team.

3Why we use it and on what legal basis

1. 3.1To run the affiliate agreement (contract): reviewing applications, opening and managing your account, tracking referrals, calculating and paying commission, and supporting you.
2. 3.2To meet legal obligations (legal obligation): accounting, tax and VAT records, anti-money-laundering and Know Your Business checks, and requests from authorities.
3. 3.3To protect the program (legitimate interests): detecting and preventing fraud, self-referral, bonus abuse and breaches of the affiliate terms, securing the Site, and handling disputes.
4. 3.4To keep you informed (legitimate interests, or consent where the law requires it): program updates, new offers and creatives. You can opt out of non-essential messages at any time.
5. 3.5Cookies that are not strictly necessary (consent): analytics on the Site. See section 7.

4Who we share it with

1. 4.1Our affiliate tracking platform provider (Cellxpert), which processes performance and account data on our behalf.
2. 4.2The Operator of the Sturmplay brand, to the extent needed to attribute players, calculate commission and investigate fraud.
3. 4.3Banks, payment and crypto payout providers, to pay your commission.
4. 4.4Accountants, auditors and legal advisers, under duties of confidentiality.
5. 4.5Authorities, courts and regulators where the law requires it or to establish, exercise or defend legal claims.
6. 4.6We do not sell your personal data.

5International transfers

1. 5.1Some of these recipients may be located outside the European Economic Area. Where that is the case, we transfer data only to countries with an adequacy decision or under the European Commission's Standard Contractual Clauses or another safeguard recognised by the GDPR.

6How long we keep it

1. 6.1Account, performance and communication data: for the duration of the affiliate agreement and up to 5 years after it ends, to handle claims and fraud reviews.
2. 6.2Invoices, payout records and other accounting documents: as long as tax and accounting law requires, up to 10 years.
3. 6.3Know Your Business and anti-money-laundering records: at least 5 years after the business relationship ends, or longer where the law requires.
4. 6.4Rejected applications: up to 12 months.

7Cookies

1. 7.1The Site and the affiliate dashboard use strictly necessary cookies to keep you logged in and secure. With your consent we also use analytics cookies to understand how the Site is used. You can change your choice at any time in the cookie banner or your browser settings.
2. 7.2Tracking links set cookies on the Sturmplay website to attribute players to affiliates; that processing is covered by the Sturmplay player privacy policy.

8Security

1. 8.1We protect your data with access controls, encrypted connections and confidentiality obligations for everyone who handles it. Keep your dashboard log-in details secret and tell us immediately if you suspect misuse.

9Your rights

1. 9.1Under the GDPR you have the right to access your data, correct it, have it erased, restrict or object to its processing, receive it in a portable format, and withdraw consent at any time without affecting earlier processing.
2. 9.2To use these rights, write to affiliates@sturmpartners.com. We answer within one month. We may ask you to confirm your identity.
3. 9.3You can complain to the Bulgarian Commission for Personal Data Protection (www.cpdp.bg) or to the data protection authority where you live or work.

10Age and changes

1. 10.1The affiliate program is only open to persons aged 18 or over. We do not knowingly collect data of minors.
2. 10.2We may update this policy. The date at the top shows the latest version. Material changes are announced by e-mail or in the affiliate dashboard.