Privacy Policy

Who operates the Affiliate Program / Who is the controller?

The Affiliate Program is jointly operated by Futuro Corp Limited, a company registered in the Autonomous Island of Anjouan, Union of Comoros (company no. 15654; registered office: Hamchako, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros) (“Futuro”), and Horizonix Corp N.V., a company incorporated under the laws of Curaçao (company no. 166811; registered office: Hanchi Snoa 19, Trias Building, Willemstad, Curaçao) (“Horizonix”) (together, the “Company Group,” and each a “Company”).

Futuro is the owner/operator of the “Toxi” and “ToxiCasino” brands, their websites and associated channels; Horizonix is the owner/operator of the “Gravira” brand, its websites and associated channels.

For data protection purposes, Futuro acts as independent data controller for processing activities related to the Toxi/ToxiCasino brands, websites and brand-specific Affiliate operations; Horizonix acts as independent data controller for processing activities related to the Gravira brand, websites and brand-specific Affiliate operations. Where certain Affiliate Program functions are operated centrally (e.g., the Affiliate portal or consolidated fraud/security monitoring), the participating Companies may act as joint controllers for those specific functions, as described in this Privacy Policy.

Where Program functions are provided centrally (e.g., shared Affiliate portal, consolidated fraud/ security monitoring), each relevant Company acts as an independent controller for its respective processing; if we expressly state that a function is operated jointly, the participating Company Entities act as joint controllers for that function.

In this Privacy Policy (“Policy”), “Company,” “we,” “us,” or “our” refers to the relevant Company (or, where applicable, both Companies) acting as controller for the processing described. “You” or “your” refers to the individual Affiliate or prospective Affiliate (including contact persons of corporate Affiliates) whose personal data we collect and process in connection with the Affiliate Program.

Relationship to the Affiliate Agreement and Defined Terms

Capitalised terms used but not defined in this Privacy Policy have the meanings given to them in the Affiliate Agreement (including Affiliate, Affiliate Account, Commission, Commission Structure, Company Websites, Marks, etc.). This Privacy Policy forms an integral part of, and is incorporated by reference into, the Affiliate Agreement and applies throughout your use of the Website and participation in the Affiliate Program.

General Provisions

We aim to operate the Affiliate Program to a high standard. To do so, we maintain straightforward but accurate identification and communication procedures and give you meaningful choices about how your personal data is used.

For EU data protection purposes, Futuro Corp Limited and Horizonix Corp N.V. act as controllers (each for its respective brand operations, as described in this Policy and the Affiliate Agreement). A “controller” is the person or entity that determines the purposes and means of processing your Personal Data under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable national laws.

We respect your privacy and are committed to protecting the personal data you provide in connection with your Affiliate Account and participation in the Affiliate Program. Please read this Policy carefully, it explains how we collect, use, store, share, and protect your personal data, and how you can exercise your rights.

If you have any questions about this Policy or our processing of your personal data, please contact us at [email protected]

Processing of the Personal Data of a Child

The Affiliate Program is intended only for individuals aged eighteen (18) or over (or the higher age of majority where applicable) and is not targeted to children. Persons under 18 may not apply for or maintain an Affiliate Account, act as an Affiliate, or otherwise participate in the Affiliate Program. For GDPR purposes, we do not knowingly collect Personal Data from anyone under eighteen (18). If we become aware that personal data of a minor has been provided, we will delete it without undue delay. 

If you believe a minor has supplied personal data, please contact: [email protected]

What Information We Collect About You and How

We collect, store and process your personal data based on different legal grounds (i.e. “legal basis” for the purposes of GDPR) which depends on the purpose for which this data is processed. If we have a contract with you, we use your personal data for performance of such contract. Also, your personal data may be processed on the basis of our legitimate interest, your consent or in order for us to fulfil certain legal obligations. In any case such legal basis is dependent on certain purposes of processing your personal data which is described below. Please note that in case your consent is required, we will separately ask for it.

1. Whether you are an Affiliate, the personal data we may collect from you for the performance of a contract with you may include:

-Contact details: such as your name, your email address, your telephone number and addresses associated with your Affiliate Account.

-Affiliate Account information: such as your contact details (as above) and other any information you share when creating an Affiliate Account.

-Payment and transaction information: we will keep the payment method you use for the transaction with us.

We require this information to operate the Affiliate Program, including to verify your identity (KYC/AML), set up and administer your Affiliate Account, pay Commission, and maintain records of your interactions and payments. We primarily collect this information directly from you, but may also receive limited data from KYC/AML providers, payment processors, and fraud-prevention services.

2. We also have a legitimate interest for processing of certain your personal data which may include:

– Login information: your log-in (email) and password. You may also choose to sign in to your Affiliate Account through third-party services (e.g., Facebook, Google etc). As always, you will be asked whether you want that third-party provide us with information about you. If you choose to do this we will receive your login details and profile information such as your log-in, user name and photo and other information from that service as permitted by you and that service.

We may need this information to protect the security of your AffiliateAccount and provide you with alternative methods to sign in to your Affiliate Account.

-Personal data which we collect when and for the purposes of communicating with you for the purposes related to our Affiliate Program:

your contact details (email address, telephone number);
certain information about you which you may provide when you interact with our customer support;
to improve our Affiliate Program and service support we may also record your conversations with our support representatives.

We may use this information from you to communicate with you about our Affiliate Program (including to inform you about any changes made to our Affiliate Program) and to provide you with quality service support.

-Certain analytical data which we may receive about you from third-party providers like Google Analytics and similar services. 

We utilize trusted third-party vendors like Google to track your activity on our Website, track site usage using Google Analytics, and show ads about the Website around the Internet. If you have chosen to enable Google to associate your web and/or app browsing history with your Google account, and to use information from your Google account to personalize ads, Google will use your data from your Google account together with our Google Analytics data to build audience lists for cross-device remarketing purposes. This means that by using signed-in user data, ads can be shown to you across any device which is linked to your Google account.

In order to support this feature, two things will happen:

-first, for users on our Website, Google Analytics will collect Google-authenticated identifiers associated with users’ Google accounts (and therefore, personal information);
-second, Google Analytics will temporarily join these identifiers to our Google Analytics data in order to support our audiences.

Please note, that we do not collect or store any personal information from our Website visitors as part of our remarketing program. Please, read Google’s Privacy Policy and Analytics Help pages for more information. You can control your ads experience (or opt out of personalized ads altogether) at your Google account.

We only use remarketing to provide you with additional information and promotions that align with past behavior on our Website.

3. With your prior opt-in consent we may process the following information for the following purposes:

-your contact details (email address, telephone number) which we may process for direct marketing purposes, including sending you marketing information about our Affiliate Program and/or services or products of our partners which may be of interest to you. We will inform you (before collecting your data) and seek your consent if we intend to use your data for direct marketing purposes.

We use this information to provide you with information about our and/or third parties’ products, services, promotions and special offers that may be of interest to you.

-if you reside in the European Union (“EU”)/ European Economic Area (“EEA”) or any other jurisdiction that may demand from us to obtain your prior consent to use cookies (and/or other similar technologies) on our Website, we will provide you with an opportunity to manage your cookie preferences on the Website. Using cookies and other similar technologies we may collect from you:

information about how you use and connect to our Website.

how you use the Website such as the pages and links you access, the time you access the Website and duration you are on it, the website you come from or go to after leaving the Website and selections and choices you make when using the Website.

information about the computer or other electronic devices you use to connect to the Website such as details about the type of device (it may include identification of unique number of the device), its operating system, browser and applications connected to the Website through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

Typically, the information we collect about how you use or connect to the Website is associated with your device and not you as a named individual. Yet, in case you are logged into a registered account, then this information may also be associated directly with you.

-Information about your location: other than information you choose to provide to us, we never collect any information of where you are located. Your device’s IP address on your electronic device may help us determine only your approximate location but this will be no more precise than the city, state or country you are using your device in.

We require this information to ensure that content from our Website is presented in the most effective manner for you and for your computer (device), and to help us analyze how you and other visitors use our Website. You may read more about cookies we use on our Website from our Cookies Policy.

You mostly submit all the information personally. But we may get information on our own with your consent.

Information can be submitted once you:

-fill any questionnaires or any forms;

-communicate with us in any way;

-identify your personality.

We may also get information by means of:

-observing your activities and interactions on our Website;

-tracking your transactions on this Website;

-using cookies or any similar technologies.

We never get information which concerns or reveals your:

-political views;

-ethnic or racial origin;

-philosophical, religious or any other beliefs of the similar kind;

– sex life;

– mental or physical condition or health;

How Long We Can Keep Your Information

We will keep your information only as long as your Account is considered to be active and so long as we need to keep it for the purposes described in this Privacy Policy. This also includes anyone whom we share your data with and who carries out services on our behalf. If we no longer need to process and keep your data and there is no requirement for us to keep it in order to comply with our legal and/or regulatory obligations, we’ll either remove it or depersonalize it so we can’t identify you.

Information about You We Share with Third Parties

We may disclose your personal data to third parties, including in the following circumstances:

-Service Providers. We use a variety of third parties to provide services to us or to carry out a certain type of activities on our behalf involving the processing of your personal data. These third-party providers have access to your personal data on a “need-to-know” basis only, solely for the purposes to perform these tasks and to the extent necessary to provide their services.

-Our affiliates. To operate and support the Affiliate Program, we may share your personal data within the Company Group (i.e., between Futuro and Horizonix) for brand-specific operations and central program administration.

-Third parties (in case of change of control). We may sell, disclose, or transfer information about you as part of a corporate business transaction, such as an acquisition or a merger, financing, corporate reorganization, joint venture, including sale of company assets, or in the unlikely event of bankruptcy, receivership or insolvency, in which such information could be disclosed to any third-parties as a business asset in the transaction.

-Third parties (in case of protecting our rights). We may disclose your personal data if we consider this is necessary in order to protect our legitimate rights and interests.

-Courts, law enforcement agencies and governmental authorities. We may pass your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (including in connection with a court order).

-Partners. We may share non-personal aggregate statistics (group) data about visitors to our Website, sales and traffic patterns with our partners and other parties.

-Other third parties. We may disclose personal information about you to third parties with your consent. We may obtain your consent in writing; online, through “click-through” agreements; when you accept the terms of disclosures for certain services; orally, when you interact with our Customer Support Representatives.

Where Your Personal Information Can Be Processed

We may transfer the personal data we gather about you to third parties located in countries other than the one you are located for the purposes for which they have been collected. This also includes countries which are not regarded as part of the EEA and which may not offer the same safeguards to personal data protection as within the EEA.

Any such transfer will only occur in cases where, at least: 

1. The third-party recipient is located in a country which, according to the European Commission, provides an adequate level of protection for your personal information; and/or
2.Under an agreement which satisfies EU requirements for the transfer of personal data to data processors or data controllers outside the EEA, such as standard contractual clauses approved by the European Commission.

Cookies

The usage of cookies on our Website is aimed at making your user experience better. Find more information about cookies in our Cookie Policy.

Your Privacy Rights

If you are a natural person (individual), you have the following rights under the GDPR in respect of any of your personal data we keep on you:

– A right to access the personal data we have on you. Please note that your right to access your personal data may be restricted by certain legislation restrictions, protection of another person’s privacy.

-A right to request correction of incorrect and/or incomplete data. If the data you provided are incorrect and/or incomplete, you are entitled to request us to correct, change, update and/or rectify your personal data. Before making such request please note that some of your data can be updated through your account.

-A right to request erasure (“a right to be forgotten”). You have the right to ask us to delete some or all of your data in case;

the personal data are no longer necessary in relation to the purposes for which it was collected and/or processed
you withdraw your consent to the processing and there is no other legitimate reason for processing;
you object to the processing and there are no overriding legitimate grounds for the processing;
you object to processing for direct marketing,
your personal data have been unlawfully processed, or children personal data have been processed.

We may, however, retain some of your personal data for legal compliance purposes, or where we have a legitimate interest in doing so.

-A right to restrict processing of your personal data. You have the right to restrict the processing of your data in certain circumstances (for example, you have the right to limit us in processing of your data for a period of enabling us to verify the accuracy of your personal data in case you are contesting the accuracy of your personal data)

-A right to object to processing of your personal data which is based on our legitimate interest. You can at any time object to the processing of your personal data for direct marketing which includes profiling to the extent that it is related to such direct marketing.

-A right to data portability. If your personal data was processed on the consent basis and by automated means, you have a right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format. If technically feasible your data can be transmitted to another data controller. 

In all cases, you can make your request by sending us an email at [email protected]

Your Consent

For some purposes and in certain situations, we may require your consent to process your personal data. Examples of such situations are processing of your data for marketing purposes. If you have previously given us your consent to the processing of your personal data you can freely withdraw such consent at any time by emailing us at [email protected]

If you withdraw your consent, and if we do not have another legal ground for processing, then we will stop processing your personal data.

Please note that if we need to process your personal data in order to operate the Website and/or provide our Services, and you object or do not consent to us processing your personal data, the Website and/or those Services may not be available to you.

YOU HAVE THE RIGHT AT ANY TIME TO ASK US TO STOP PROCESSING YOUR INFORMATION FOR DIRECT MARKETING PURPOSES.

If you wish to exercise this right, you should contact us by sending an email to [email protected] or through the unsubscribe link at the bottom of our marketing emails.

Complaints

If you have any concerns about how we collect or process your data you have the right to file a complaint with a relevant supervisory personal data protection authority.

Final provisions

We will take reasonable efforts to ensure your safety and prevent third-party access to the personal information collected. We shall keep our employees duly trained and instructed to maintain your information safe.

This Privacy Policy creates a full understanding between us and you. Unless information is expressly set out in this Privacy Policy, neither party, meaning you and us, shall rely on any written or oral information.

Reports and notices under this document shall be considered as read within 1 day since the moment the notice or report has been sent.

This document may be altered, modified or amended at our sole and absolute discretion without issuing any warning or notices.

Contacting Us

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to [email protected]

This Privacy Policy agreement is concluded in the electronic form, which has the same legal force as if it were signed in ink.