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Terms And Conditions

Privacy Policy

Terms And Conditions

PLAY GAMIFIED LIMITED – TERMS AND CONDITIONS FOR AFFILIATE PROGRAMME

These terms and conditions (these Terms) govern each application to become an affiliate of PGL and the activities of accepted Affiliates. You or the legal entity that you represent agree to be bound by these Terms by doing any of the following:

·       clicking the “I Agree” button below; or

·       making an application to become an Affiliate; or

·       performing any activities of an Affiliate.

If you do not agree to be bound by these Terms you must not undertake any of these activities.

We may amend these Terms from time to time by updating them on our website. We may notify you of such changes via email or through our website. The current version of the Terms can be found at https://partners.pubmedia.co.uk/ 

WHO WE ARE

1.1.We are Play Gamified Limited (PGL, we or us), a limited company incorporated and registered in England and Wales with company number 11615605 whose registered office address is at 44 Station Road, Cheadle Hulme, Cheadle, SK8 7AB.

1.2.Any reference to you or your in these Terms is a reference to the individual, company or other legal entity seeking to become an Affiliate.

2.     DEFINITIONS AND INTERPRETATIONS

2.1.In these Terms, the following definitions and rules of interpretation apply.

Definitions:

Advertising Requirements: means the advertising requirements and guidance set out in the Schedule to these Terms.

Affiliate: any individual, company or other legal entity which is authorised by PGL to market, advertise and promote the PGL Products through Digital Advertising and/or Online Advertising.

Affiliate Application Form: the application form provided by PGL and to be completed by or on behalf of any individual, company or other legal entity which wishes to become an Affiliate.

Confidential Information:all information of a confidential or proprietary information (in whatever form) relating to the business, assets, affairs, pricing, customers, clients, suppliers, or plans, intentions, marketing strategies and campaigns or market opportunities of the Disclosing Party and including (but not limited to):

(a)     all technical or commercial information, know-how, specifications, inventions, operations, techniques, processes, products, product information, initiatives, drawings and designs, trade secrets, software (including source code), information relating to research and/or development work, proposals for services or products and engineering designs and/or development of the Disclosing Party; and

(b)     any other information of a confidential or proprietary nature not generally known to the public, whether of a technical, business, or other type, that is disclosed by the Disclosing Party arising out of or in connection with these Terms and which could reasonably have been understood by the Recipient to be proprietary or confidential to the Disclosing Party (including information marked as “Confidential” by the Disclosing Party).

Data Protection Legislation means all applicable data protection and privacy legislation in force from time to time in the UK including (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR); (ii) the Data Protection Act 2018 (and regulations made thereunder); (iii) the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and (iv) all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data.

Digital Advertising: any digital marketing activity conducted by the Affiliate via the internet, including but not limited to banner ads, social media, email campaigns and websites.

Disclosing Party means the party disclosing Confidential Information.

Intellectual Property Rightsmeans patents, rights to inventions, copyright and neighbouring and related rights, moral rights, trademarks and service marks, business names and domain names, rights in get-up and trade dress, goodwill and the right to sue for passing off or unfair competition, rights in designs, rights in computer software, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how and trade secrets), and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.

Net Cash: the gross revenue received by PGL from the PGL Sites and/or PGL Products from users referred by the Affiliate, minus any and all: (a)      operating costs (including costs relating to third party platform operators, game operators and any other third party service providers and management charges) of the PGL Sites and the PGL Products; (b)      payment and card processing fees; (c)      funds added to the referred users’ accounts with PGL, excluding winnings, to incentivise users to increase their deposits and/or turnover (including bonus money and loyalty schemes); (d)      invalid, fraudulent or disputed card or debit payments, including where a card company or the payment bank has claimed payment back from PGL; (e)      applicable taxes; and (f)      all payments made by and revenues associated with any user referred by the Affiliate that at any time makes an invalid, fraudulent or disputed payment.

Personnel: means the officers, employees, representatives, agents, subcontractors or consultants engaged by a Party.

 PGL Products: the online casinos, sports books, games  and other similar activities provided by PGL.

PGL Sites:the various websites through which PGL provides the PGL Products to end users.

Physical Advertising: any marketing and advertising materials placed by the Affiliate on physical premises, including but not limited to posters, signage and flyers.

Recipient means the party receiving Confidential Information.

2.2.Clause, Schedule and paragraph headings are used for reference only and shall not affect the interpretation of these Terms.

2.3.The Schedule forms part of these Terms and shall have effect as if set out in full in the body of these Terms. Any reference to these Terms includes the Schedule.

2.4.Any reference in these Terms to:

 2.4.1.         a clause or a paragraph is a reference to a clause of these Terms or a paragraph of the Schedule;

2.4.2.         a company shall include any company, corporation or other body corporate, wherever and however incorporated or established;

2.4.3.         a person includes a natural person, corporate or unincorporated body (whether or not having separate legal personality);

2.4.4.         legislation or a legislative provision is a reference to it as amended or re-enacted and includes all subordinate legislation made under that legislation or legislative provision; and

2.4.5.         writing or written includes email.

2.5.Any words following the terms including, include, in particular, for example or any similar expression shall be interpreted as illustrative and shall not limit the sense of the words preceding those terms.

2.6.Any obligation on a party not to do something includes an obligation not to allow that thing to be done.

 3.     APPLICATION PROCESS

3.1.In order to commence the application process to become an Affiliate you will need to complete and submit to PGL an Affiliate Application Form, following the instructions provided by PGL on our website.

3.2.By submitting your application you agree that all information contained in that application will be true, accurate and complete.

3.3.PGL will review your application and may take steps to verify your identity or the identity of the legal entity that you act on behalf of, including by requesting information from you and by obtaining further information from other third party sources and data. You agree to provide PGL with any verification and/or other supporting documents and information which PGL may request from time to time.

3.4.PGL reserves its full rights to reject any application in its sole discretion. PGL will notify you whether your application has been accepted or rejected.

4.     OBLIGATIONS OF AN AFFILIATE

4.1.If you are accepted as an Affiliate:

 4.1.1.         you will be granted the right to advertise and promote the PGL Sites and the PGL Products through Digital Advertising and/or Physical Advertising (as applicable to you), subject to these Terms;

4.1.2.         you shall use your best endeavours to advertise and promote the PGL Sites and the PGL Products with all due care and diligence and in accordance with these Terms and all applicable laws, regulations and codes of practice including, without limitation, the Gambling Act 2005 and the requirements listed in Schedule 1;

4.1.3.         in relation to any Physical Advertising that you undertake, you agree to exclusively advertise and promote the PGL Sites and the PGL Products at your premises or venue (unless PGL, in its total discretion, agrees otherwise in writing). For the avoidance of doubt, this means that you will not promote in a similar way the products or services of any competitor of PGL at your premises or venue (unless PGL agrees otherwise in writing);

4.1.4.         you shall co-operate with PGL in all matters relating to the advertisement and promotion of the PGL Sites and the PGL Products;

4.1.5.         you shall comply with all reasonable and lawful instructions of PGL from time to time concerning the advertisement and promotion of the PGL Sites and the PGL Products;

4.1.6.         you must act in such manner as you think best to promote PGL’s interests and not do anything which could be prejudicial to PGL’s goodwill or commercial interests;

4.1.7.         you must not, directly or indirectly, offer any person or entity any incentive or bonus (including but not limited to money) to sign up to use the PGL Sites and/or the PGL Products.

4.1.8.         you must at all times maintain the accuracy of all information that you have provided to PGL, whether as part of the application process or otherwise. You must promptly update any changes to such information; and

4.1.9.         you must ensure that you do not promote the PGL Sites or the PGL Products in a way that targets individuals under the legal gambling age of 18. 5.     PROMOTIONAL MATERIALS

5.1.PGL shall provide the Affiliate with promotional materials to be used by the Affiliate for Digital Advertising and/or Physical Advertising.

5.2.The Affiliate may, if it wishes to do so, produce its own materials to advertise and promote the PGL Sites and the PGL Products. However, such materials may only be used if the Affiliate first provides the proposed materials to PGL and has obtained PGL’s prior written consent to the use of those materials.

5.3.Please note that PGL does not allow the PGL Sites and PGL Products to be advertised or promoted on adult networks, illegal streaming sites, pop-under or pop-up campaigns or advertorial style marketing or through SMS marketing.

6.     DIGITAL ADVERTISING

6.1.When the Affiliate undertakes Digital Advertising:

6.1.1.         the advertisement must direct users to an additional link where all the terms and conditions of the promotion are stated, which must be no further than one click away from the advertisement itself in cases where there is space and time limitation;

6.1.2.         when anything is advertised as “bonus” or “free” (e.g. free spins, free play etc.), the main terms and conditions and the commitments or requirements for the user to take advantage of such an offer must be stated in the advertisement itself;

6.1.3.         no advertising or other marketing information must appear on any primary web page, screen or micro-site providing advice or information on responsible gambling;

6.1.4.         the Affiliate must use “Age-Gating” wherever the marketing space provides the Affiliate with an option to do so. “Age-Gating” means applying ‘minimum 18’ age restrictions to the marketing content;

6.1.5.         the Affiliate’s website must include an 18+ age disclaimer and a link to a responsible gambling body (e.g. https://www.begambleaware.org/). For Affiliates using social media, the disclaimer and link must be posted in the about/bio section of the Affiliate and in every post that the Affiliate may make to advertise and promote the PGL Sites and the PGL Products;

6.1.6.         the Affiliate’s website must comply with the CAP Code, particularly the gambling section;

6.1.7.         the Affiliate must not promote gambling as a way to get guaranteed profits, generate income or become wealthy; and

6.1.8.         the Affiliate’s website must not offer incentivised traffic.

7.     COMMISSION

7.1.Subject to the Affiliate performing its obligations under these Terms, PGL shall pay to the Affiliate a revenue split percentage of the Net Cash received by PGL each month from end users referred to the PGL Sites and/or PGL Products by the Affiliate, such percentage as agreed with the Account Manager assigned to the Affiliate.

7.2.The Affiliate can log in to the PGL platform at any time to check the number of referrals they have made and the commission due to the Agent for each month.

7.3.PGL shall pay the commission due to the Affiliate under these Terms when the amount of commission exceeds the threshold specified in the PGL platform. Such payments shall be made to the Affiliate’s nominated bank account.

8.     CONFIDENTIAL INFORMATION

8.1.The Recipient undertakes that it shall at all times:

8.1.1.         keep the Confidential Information secret and confidential;

8.1.2.         not use or exploit any Confidential Information for its own benefit or in any way other than the proper performance of its duties under these Terms, unless it has obtained prior written consent from the Disclosing Party to do so;

8.1.3.         not directly or indirectly disclose or make available any Confidential Information in whole or in part to any third party, except as expressly permitted by, and in accordance with, these Terms or with the prior written consent of the Disclosing Party; and

8.1.4.         apply at least the same security measures and degree of care to the Confidential Information as the Recipient applies to its own confidential information, which the Recipient warrants as providing adequate protection from unauthorised disclosure, copying or use. In the event the Recipient becomes aware of, or suspects, any loss or unauthorised disclosure or use of the Confidential Information, it shall promptly notify the Disclosing Party.

8.2.The Recipient may disclose Confidential Information to:

 8.2.1.         its Personnel or advisers who need to know such information for the purposes of exercising the Recipient's rights or carrying out its obligations under or in connection with these Terms, on the basis that it:

8.2.1.1.     informs such Personnel or advisers of the confidential nature of the Confidential Information;

8.2.1.2.     ensures that such Personnel or advisers comply with this clause ‎5; and

8.2.1.3.     ensures that such Personnel or advisers are subject to obligations of confidentiality at least as extensive and binding upon them as the terms of these Terms are upon the Recipient; and

8.2.2.         to the minimum extent required by Applicable Laws, by any governmental or other regulatory authority or by a court or other authority of competent jurisdiction, provided that, to the extent it is legally permitted to do so, it gives the Disclosing Party as much notice of the disclosure as possible and, where notice of disclosure is not prohibited and is given in accordance with this clause ‎

8.2.2, it takes into account the reasonable requests of the Disclosing Party in relation to the content of the disclosure.

8.3.The Recipient shall be liable for the actions or omissions of its Personnel and advisers in relation to the Confidential Information as if they were the actions or omissions of the Recipient.

8.4. Notwithstanding the foregoing, the restrictions of this clause ‎8 shall not apply to information that:

8.4.1.         is or becomes publicly known other than through any act or omission of the Recipient;

8.4.2.         was in the Recipient's lawful possession before the disclosure under these Terms;

8.4.3.         is lawfully disclosed to the Recipient by a third party and is not subject to any obligation of confidentiality restricting disclosure by the third party; or

8.4.4.         is developed by the Recipient independently of and without reference to Confidential Information, which independent development can be shown by written evidence.

8.5. The Recipient shall take all reasonable steps to ensure that the Confidential Information to which it has access is not disclosed or distributed by its Personnel or advisers in violation of the terms of these Terms.

9.     DATA PROTECTION

9.1.For the purposes of this clause ‎9, the terms controller, data subject, personal data, personal data breach, processor and processing, shall have the meaning given to them in the Data Protection Legislation.

9.2.The parties acknowledge and agree that, for the purposes of the Data Protection Legislation, in so far as the processing of personal data is concerned, PGL and the Affiliate are each a controller of personal data in their own right.

9.3.As such, each party shall at all times, comply with its respective obligations under all applicable Data Protection Legislation in relation to all personal data that is processed by it in the course of performing its obligations under these Terms.

10.  INTELLECTUAL PROPERTY RIGHTS

10.1.   The Affiliate acknowledges and agrees that PGL and/or its licensors own all Intellectual Property Rights and any other proprietary rights in the PGL Sites, the PGL Products and all marketing materials provided to the Affiliate by PGL under these Terms. Except as expressly stated herein, these Terms do not grant the Affiliate any rights to, under or in any Intellectually Property Rights, any other proprietary rights or any other rights or licences in respect of the PGL Sites, the PGL Products or marketing materials provided to the Affiliate by PGL under these Terms.

10.2.   PGL grants the Affiliate a revocable and non-exclusive right to use and display the marketing materials provided to it by PGL for the purpose of advertising and promoting the PGL Sites and the PGL Products in accordance with these Terms and for no other reason.

11.  LIABILITY

11.1.   Nothing in these Terms shall limit or exclude any liability of either party which cannot be excluded or limited by applicable law, including but not limited to:

11.1.1.      death or personal injury caused by the negligence of that party; or

11.1.2.      fraud or fraudulent misrepresentation.

11.2.   Subject to clause ‎

11.1, PGL’s aggregate liability in respect of any loss or damage suffered by the Affiliate and arising out of or in connection with these Terms, whether in contract, tort (including negligence) or for breach of statutory duty or in any other way, shall not exceed the amount of commission actually paid to the Affiliate pursuant to these Terms in the 12 months prior to the event giving rise to such liability.

11.3.   Except as expressly provided for in these Terms all conditions, warranties and representations implied by statute, common law or otherwise are excluded to the extent permitted by law.

12.  TERMINATION

12.1.   Without affecting any other right or remedy available to it, either party may terminate the Affiliate arrangements under these Terms at any time by giving 3 months’ written notice to the other party.

12.2.   Without affecting any other right or remedy available to it, PGL may terminate the Affiliate arrangements under these Terms with immediate effect by giving written notice to the Affiliate if the Affiliate:

 12.2.1.   commits a material breach of its material obligations under these Terms and (if such breach is remediable) fails to remedy that breach within 30 days after being notified in writing to do so; or

12.2.2.   becomes insolvent or is unable to pay its debts, proposes a voluntary arrangement, has a receiver, liquidator, administrator or manager appointed over the whole or any part of its business or assets or if any application shall be presented, order shall be made or resolution passed for its winding up (except for the purposes of a bona fide amalgamation or reconstruction), bankruptcy or dissolution or if it shall otherwise propose or enter into any composition or arrangement with its creditors or any class of them, or it ceases to carry on business or if it claims the benefit of any statutory moratorium; or

12.2.3.   the Affiliate does not refer any end users to the PGL Sites or the PGL Products for a period of 3 months.

12.3.   Following termination of the Affiliate arrangements:

12.3.1.      all rights and licences granted to the Affiliate will cease immediately and the Affiliate shall immediately cease to advertise and promote the PGL Sites and the PGL Products;

12.3.2.      the Affiliate shall be entitled to be paid commission for the period up to and including the date on which the Affiliate arrangements cease but will not be entitled to any commission which accrues after that date;

12.3.3.      within a reasonable period, the Affiliate will return to PGL all Confidential Information and any other information or materials which are in the Affiliate’s possession or control.

12.4.   Termination of the Affiliate arrangements shall not affect any rights, remedies, obligations or liabilities of the parties that have accrued up to the date of termination, including the right to claim damages in respect of any breach of these Terms which existed at or before the date of termination.

12.5.   Any provision of these Terms that expressly or by implication is intended to come into or continue in force on or after termination of the Affiliate arrangements shall remain in full force and effect.

13.  FORCE MAJEURE

13.1.   Neither party shall be in breach of these Terms or otherwise liable for any failure or delay in the performance of its obligations if such delay or failure results from events, circumstances or causes beyond its reasonable control.

14.  GENERAL

14.1.   Variation. No variation of these Terms shall be effective unless it is made in writing and signed by the parties (or their authorised representatives).

14.2.   Assignment. The Affiliate shall not, without PGL’s prior written consent, assign, transfer or deal in any other manner with all or any of its rights or obligations under these Terms. PGL may at any time assign, transfer, charge, sub-contract or deal in any other manner with all or any of its rights or obligations under these Terms.

14.3.   Entire Agreement. These Terms constitute the entire agreement between the parties and supersedes and extinguishes all previous agreements, promises, assurances, warranties, representations and understandings between them, whether written or oral, relating to its subject matter. Each party acknowledges that in entering into these Terms it does not rely on, and shall have no remedies in respect of any statement, representation, assurance or warranty (whether made innocently or negligently) that is not set out in these Terms. Each party agrees that it shall have no claim for innocent or negligent misrepresentation based on any statement in these Terms.

14.4.   Waiver. A waiver of any right or remedy under these Terms or by law is only effective if given in writing and shall not be deemed a waiver of any subsequent right or remedy. A delay or failure by a party to exercise any right or remedy provided under these Terms or by law shall not constitute a waiver of that or any other right or remedy, nor shall it prevent or restrict any further exercise of that or any other right or remedy. No single or partial exercise of any right or remedy provided under these Terms or by law shall prevent or restrict the further exercise of that or any

14.5.   Severance. If any provision or part-provision of these Terms is or becomes invalid, illegal or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this clause ‎14.5 shall not affect the validity and enforceability of the rest of these Terms.

14.6.   Third Party Rights. Nothing in these Terms shall be deemed to confer any rights on anyone not a party to these Terms under the Contracts (Rights of Third Parties) Act 1999.

 14.7.   No Partnership.Nothing herein shall be construed to create a partnership, trust obligation, agency, liability or other general relationship between the parties extending beyond the limited scope of these Terms unless otherwise agreed by the parties.

14.8.   Governing Law. These Terms and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and interpreted in accordance with English law. 

14.9.   Jurisdiction. The parties irrevocably agree that the English courts shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms or its subject matter or formation (including non-contractual disputes or claims).

 

  

SCHEDULE: ADVERTISING REQUIREMENTS

1           General Compliance

1.1       The Affiliate must comply with all relevant advertising laws, regulations, and codes of practice that apply in relation to the advertising of gambling in the UK including, without limitation: 1.2.1          The Licence Conditions and Code of Practice (the LCCP) issued by the Gambling Commission (the GC) including, without limitation, Condition 16 (Responsible Placement of Digital Advertising), provision 5.1.6 LCCP (Compliance with Ad Codes) and provision 5.1.7 (Marketing of Offers); 1.2.2          The codes issued by the Advertising Standards Authority’s (ASA) Committee on Advertising Practice (the CAP Code) and its Broadcast Committee on Advertising Practice (the BCAP Code); and 1.2.3          The Industry Group for Responsible Gambling’s (IGRG’s) Code for Socially Responsible Advertising (the IGRG Code), collectively, the UK Codes. 2           Use of Content 2.1       The Affiliate shall not alter or amend promotional material either provided by or approved by PGL. 3           Monitoring and Enforcement 3.1       PGL reserves the right to monitor Affiliate marketing for compliance with these Terms, including the UK Codes, and Affiliate agrees to provide PGL with such reports and information that PGL may reasonably require to do so. 3.2       If the Affiliate breaches these terms, including the UK Codes, PGL may immediately suspend or terminate these Terms. 4           Helpful information 4.1       The Affiliate may find the following links and information useful in relation to its obligations under these Terms:

Gambling Commission:

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/print

ASA:

https://www.asa.org.uk/type/non_broadcast/code_section/16.html

https://www.asa.org.uk/advice-online/affiliate-marketing.html

https://www.asa.org.uk/advice-online/betting-and-gaming-appeal-to-children.html

https://www.asa.org.uk/uploads/assets/uploaded/734c1499-850d-4d2f-88a441ffd1903b50.pdf

 

IGRG Gambling Industry Code for Socially Responsible Advertising

 

Privacy Policy

Introduction

Palsar Capital Limited, henceforth referred to as “We” “Our” “Us” provides an affiliate programme to promote our clients on whose behalf We administer and manage the affiliate program. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.

This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.

This privacy policy should be read in conjunction with the Affiliate Programmes Terms and Conditions. By entering into any kind of contract with Palsar Capital Limited, you agree to the contents of this privacy policy. If you do not agree with any section of this privacy policy, you should not attempt to use our service.

Data Controller

The Data Controller is Palsar Capital Limited t/a Raven of Glassworks, 1 Back Turner Street, Manchester, M4 1FR

All queries in regards to this privacy policy should be addressed to the Data Protection Officer at the above address, who can also be contacted directly at compliance@raventrack.com

Personal Information

We collect and process the following data from (and about) you:

  • Your name, company name, address and contact details, including email address and telephone number;
  • Payment details including Electronic transfer address, and payment method owner.
  • A record of any correspondence between You and Us.

Personal information is collected for the following purposes

  • To administer the opening, management, and maintenance of accounts.
  • To enable Palsar Capital Limited to build an accurate profile of our client base and carry out statistical analysis.
  • To contact you for purposes including (but not limited to) sales reports, training, provision of promotional resources, newsletters, and other correspondence.
  • To monitor affiliate activity to ensure your compliance with the terms and conditions of the Active Wins Affiliates Affiliate Programme.
  • To monitor and process payments in relationship to your involvement in this Affiliate Programme.
  • All telephone calls to and from Palsar Capital Limited office(s) may be recorded for training and security purposes.

We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.

Legal Basis for Processing

Our lawful basis for processing personal data include:

  • To fulfil a contract we have with you.
  • When it is our legal duty to do so.
  • When it is in our legitimate interest.
  • When you consent to it.

Who we share your personal information with

We may disclose your personal data to:

  • Palsar Capital Limited employees
  • contractors working with Palsar Capital Limited
  • regulators, and other legal authorities
  • the brands that you are promoting
  • auditors
  • payment providers
  • fraud prevention and compliance services
  • potential purchasers or investors
  • companies that you ask us to share your data with

All processing of information will be governed by the appropriate data protection laws.

Marketing

We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.

The consent requires a positive Opt-In either in electronic format, verbally or in writing. The consent will be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent, and be easily withdrawable.

Data Transfers outside the EEA

We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:

  • The Processor is certified under the EU-U.S. Privacy Shield Framework.
  • The existence of any other specifically approved safeguard for data transfers (as recognised under EU Data Protection Laws) and/or a European Commission finding of adequacy can be demonstrated.

Data Retention

You may request that your Personal Data be anonymised in the following circumstances:

  • Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When you withdraw consent, if consent is being used as the Legal Basis for Processing.
  • If you object to the Processing and there is no overriding Legitimate Interest or Legal Obligation to continue the Processing.
  • The Personal Data was unlawfully processed.
  • The Personal Data has to be erased to comply with a legal obligation.

We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.

Subject Access Request (SAR)

You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you. Please note that your identity will need to be confirmed in order to complete a SAR, which may include the disclosure of other personally identifiable documentation in order to prove your identity (such as a passport scan, or valid proof of address) before commencing with the process.

Cookies

By using the Raven website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.

If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.

Automated Decision Making and Profiling

Palsar Capital Limited do not use any automated systems in order to make decisions regarding your account which have any legal effect on You.

Right to Lodge a complaint

Please let us know if you are unhappy with how we have used your personal information in writing to the Data Protection Officer, who will be able to assist further with your complaint or concern. You also have the right to complain to the Information Commissioner’s Office.

Privacy Policy Status

This Privacy Policy is kept under continued review by Palsar Capital Limited and can be amended by Us at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing, as stated in the introduction to this policy.

This version of the Privacy Policy is effective as of September 20th 2018.