Ice Affiliates Privacy Policy

Last updated 03.06.2026 . This policy applies to everyone using ice-affiliate.com - affiliate partners and casual visitors alike. It covers what data gets collected, why, who sees it, and what anyone can do about it. Worth reading before handing over personal details to any affiliate program, frankly.

What Laws Apply Here

Ice Affiliates operates under two frameworks. The Personal Data (Privacy) Ordinance of Hong Kong (PDPO) applies as the base layer. For anyone in the EU or EEA, GDPR kicks in on top of that - stronger rights, stricter rules. If there's ever a conflict between the two, the one offering more protection to the individual wins. EU affiliates especially should know their GDPR rights are fully honored here.

What Personal Data Gets Collected

When someone applies to join the affiliate program, a fair amount of information comes in. That's just how it works with financial partnerships - identity verification and payment processing require real data.

1. Affiliate Application - Name, contact details, gender, date of birth, home address, phone number, occupation, and full payment details (credit card, e-wallet, or bank account). This is collected to set up and manage the affiliate account and process earnings.
2. Cookies and Technical Data - Device type, browser, operating system, language settings, screen resolution, referral source, page views, time spent on site, browsing behavior, and rough geo-location. Used to improve website performance and run analytics.
3. Email and Skype Communications - Any correspondence records and voluntarily shared information during conversations with the affiliate team. Kept for the duration of the relationship.

Session cookies are worth a specific mention. When an affiliate logs into their account, the session cookie carries their Affiliate ID. That's how the system checks what features and services they can access. These are temporary - they disappear when the browser closes.

Why That Data Gets Used

The policy is upfront about this. Data collected from affiliates gets used for:

• Setting up and running affiliate accounts
• Processing commission payments
• Fraud detection and prevention
• AML and KYC compliance - legal requirements, not optional
• Handling disputes and responding to court orders or regulators if it ever comes to that
• Sending updates, promotions, and offers via email or live chat
• Analytics and service improvement

Marketing emails can be switched off. Any email from Ice Affiliates has an unsubscribe link. Alternatively, contacting [email protected] directly works too. No argument, no friction - just opt out.

Legal Grounds for Processing (EU Affiliates)

For anyone the GDPR applies to, Ice Affiliates bases data processing on four grounds:

1. Consent - For things like marketing, where explicit opt-in is needed
2. Contractual Necessity - Processing required to actually run the affiliate relationship and pay commissions
3. Legal Obligation - Tax records, regulatory compliance, that kind of thing
4. Legitimate Interests - Fraud prevention, improving services, standard business operations

Who Gets to See This Data

Ice Affiliates shares affiliate data with third parties in specific situations. Not randomly, not broadly - but the list is real and worth knowing:

• Affiliate platform providers like Income Access
• Email service providers and internet service providers used in program administration
• Other companies within the Ice Affiliates corporate group
• iGaming software providers connected to promoted casino brands
• Payment processors, banks, and e-wallet providers needed to actually pay affiliates
• Third parties organizing offline events or tournaments connected to group brands
• Licensing authorities and government regulators when legally required
• Cloud computing providers where data gets stored

Data can also be shared to assist with business operations, detect illegal activity, run technical diagnostics, or deliver targeted promotional materials. None of this is unusual for an international affiliate program - but it means data does travel beyond the immediate Ice Affiliates team.

International Data Transfers

Data can move to countries with different - potentially weaker - data protection laws than where an affiliate lives. Ice Affiliates handles this through Standard Contractual Clauses for EU transfers, or by verifying that the destination country meets Hong Kong PDPO standards. Where consent is specifically required for a transfer, it gets asked for. That's the safeguard mechanism. It won't satisfy everyone, but it's the legal standard approach.

How Long Data Gets Kept

No indefinite storage. Data stays as long as it's needed - to fulfill the affiliate relationship, meet legal obligations (tax records, financial compliance), or serve legitimate business record-keeping purposes. When none of those apply anymore, it goes. The Data Processing Annex is more specific: personal data tied to the agreement is retained for the term of the agreement itself.

Affiliate Rights Over Their Own Data

Anyone whose data Ice Affiliates holds has the following rights. These apply under GDPR for EU affiliates; equivalent protections exist under PDPO for others.

• Access - Request a copy of what's held on file
• Correction - Fix anything inaccurate or incomplete
• Deletion - Ask for data to be removed when it's no longer needed, or after withdrawing consent
• Restriction - Limit how data is processed in certain circumstances
• Portability - Request data transferred to another organization or handed directly over
• Objection - Object to processing for specific purposes, including marketing

All of these go through [email protected]. If the response isn't satisfactory, the relevant data protection supervisory authority is the next step - that's a legal right, not just a suggestion buried in fine print.

Data Security

Encryption protects data in transit. Access controls mean only authorized staff can reach personal data. Regular audits check for vulnerabilities. Multi-factor authentication is required for account access. Penetration testing happens on software that handles personal data.

The policy is honest about the ceiling here: no security system is fully foolproof. Unauthorized access by third parties can't be guaranteed against. That's not a dodge - it's a factual statement that applies to every company handling data online.

Minors

Ice Affiliates doesn't accept anyone under 18. If it ever comes to light that a minor's data has been collected, it gets deleted immediately. The affiliate program is for adults operating in the gambling industry - that line doesn't move.

Policy Changes

The policy can be updated. When significant changes happen, the website carries the notice. The "last updated" date at the top of the policy is the effective date for any amendments. Checking back occasionally is sensible for any active affiliate.

Contact

Questions about personal data, the privacy policy, or data rights go to [email protected]. The Data Protection Officer monitors that address. Straightforward enough.