UFL Affiliate Program Privacy Policy

Last updated: 12 August 2026

We care about your privacy and handle your personal data with transparency and care.

We created this UFL Affiliate Program Privacy Policy (“Policy”) to help you understand what personal data we collect, why we collect it, and how we use and protect it when you interact with us in connection with the UFL Affiliate Program (“Program”), information about which is available at https://uflgame.com/affiliates and its related subdomains (“Affiliate Program Website”).

1. WHO ARE WE AND HOW TO CONTACT US?

We, XTEN Limited (“XTEN,” “we,” or “us”), are a company headquartered in Cyprus that operates the Program and acts as the controller of your personal data in relation to it, except where otherwise stated in this Policy. If you have any questions, you can contact us at any time using the details provided below.

OUR CONTACT DETAILS:

Controller: XTEN Limited

Address: Office 701, 169 Archiepiskopou Makariou III, CEDARS OASIS TOWER, 3027, Limassol, Cyprus.

Email address: privacy@strikerz.inc

For questions about this Policy or your personal data, please contact us first. If you are not satisfied with the handling of your request, you may also contact our Data Protection Officer at dpo@strikerz.inc.

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Policy applies to individuals and businesses who apply to, register for, or participate in the Program (“Affiliate”), and to the individuals who interact with our Affiliate Program Website. 

Individuals under the age of 18 are not permitted to participate in the Program, and we do not knowingly collect personal data from anyone under 18 in connection with the Program.

This Policy applies to the following types of Affiliates involved:

(i) Individual Affiliate, where a natural person participates in the Program. In this case, this Policy governs that processing in full; 

(ii) Company Affiliate, where a company or other legal entity participates in the Program. In this case, we process only the personal data of the company’s employees, directors, authorised signatories, appointed representatives, or other individuals associated with the company Affiliate (“Representatives”). Information that relates to the company Affiliate itself is not governed by this Policy.

3. HOW DO WE COLLECT PERSONAL DATA?

HIGHLIGHT: We may collect your personal data in two ways: (i) directly from you, (ii) automatically when you use the Affiliate Program Website.

3.1. Personal Data You Provide.

We collect personal data that you provide directly when you apply for the Program, enter it on the Affiliate Program Website, or include it in emails or other messages you send us. This typically includes your name, date of birth or age group, status (individual, sole proprietor, company Representative status or title), email address, messaging app or social media handles, social media account name, social media account link, and the payout details needed to pay your commissions, as well as any other information you choose to provide to us in connection with your participation in the Program, including through emails, messages, application forms, support requests, or other communications with us.

We may also ask you to verify your identity when you make a privacy request to exercise your rights, to comply with legal requirements and protect your personal data.

3.2. Personal Data Collected Automatically.

We also automatically collect certain data when you access and use the Affiliate Program Website. This includes your approximate location based on your IP address and your device’s region or country, as well as your device type, User Agent, hardware model and settings, device memory, and system activity.

We may use cookies and similar technologies to collect some of this data. You can learn more about our use of cookies in our Cookie Policy, which is available in the footer of each of our websites.

4. HOW DO WE USE YOUR PERSONAL DATA?

HIGHLIGHT: We use your personal data only for specific purposes and only when we have a legal basis to do so: (i) Contractual Obligation, (ii) Legitimate Interest, (iii) Consent, or (iv) Legal Obligation.

We process personal data in compliance with the General Data Protection Regulation 2016/679 (GDPR), the Law 125(I)/2018 of the Republic of Cyprus, and other applicable data protection laws and regulations. We are transparent about our privacy practices and follow the principles of data minimisation, purpose limitation, accuracy, and accountability.

The table below provides a detailed breakdown of the categories of personal data we process, the corresponding legal bases, and the purposes for such processing, in accordance with applicable data protection laws:

Purpose of ProcessingLegal Basis Personal Data
To register and verify Affiliates, administer participation in the ProgramFor individual Affiliates, Contractual Obligation
For company Affiliate Representatives, Legitimate Interest
General Identification Information (e.g., as applicable, name, date of birth or age group, sole proprietor or company Representative status or title, social media account name, social media account link, platform IDs)
Other Information (e.g., information contained in emails, messages, application forms, support requests, and other communications with us in connection with your participation in the Program)
To apply geographic eligibility rulesLegitimate InterestLocation Information (approximate location derived from IP address, region or country)
To communicate with Affiliates about the Program (support, transactional notifications, processing requests)For individual Affiliates, Contractual Obligation
For company Affiliate Representatives, Legitimate Interest
Contact Information (e.g., as applicable, email address, messaging or social media handles provided for communication)
Other Information (e.g., information contained in emails, messages, application forms, support requests, and other communications with us in connection with your participation in the Program)
To send marketing communications about the ProgramConsentContact Information (e.g., as applicable, email address, messaging or social media handles provided for communication)
To measure Affiliate performance, calculate and pay commissionsFor individual Affiliates, Contractual Obligation
For company Affiliate Representatives, Legitimate Interest
Performance Data (e.g., conversion records, attribution events), Payment Details (payout details where the Affiliate is an individual, including a sole trader)
To operate and secure the Affiliate Program WebsiteLegitimate InterestWebsite Interaction Information (e.g., as applicable, IP address, browser and device data, session identifiers, User Agent)
To maintain tax and AML records as required by law, respond to authoritiesLegal ObligationPayment Details, General Identification Information, Transaction History
To establish, exercise or defend legal claimsLegitimate InterestAny relevant data depending on the claim

5. HOW LONG DO WE STORE AND USE YOUR INFORMATION?

HIGHLIGHT: We keep your personal data only as long as needed for the purposes described above, unless the law requires or allows us to keep it longer.

The period for which we process your personal data depends on the type of data and how you engage in the Program. We store your data only for the purposes described in this Policy, such as operating the Program, fulfilling our contracts, protecting our legitimate interests, conducting audits, meeting legal obligations, resolving disputes, and enforcing our agreements.

If you request the deletion of your personal data, we will verify and process your request within the timeframe required by law unless we have a legal right or obligation to retain the data for longer. This may happen if we need to defend against a legal claim or if a government authority requests the data, including for reasons of national security or public interest.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

HIGHLIGHT: We may share some of your personal data with partners who help us run the Program. We cannot provide these services without them, but we ensure your personal data stays protected.

Here are the types of third parties that we may share your personal data with:

(i) Service providers that help us run and provide the Program or analyse how the Affiliate Program Website performs.

Service ProviderTypeRole Data Collected and PurposePrivacy Policy 
Google LLC (USA)IT InfrastructureProcessorAll data for hosting the Affiliate Program Website on the Google Cloud PlatformGoogle Privacy
Google LLC (USA)Email communications toolProcessorAll data contained in the email communicationsGoogle Privacy
Google LLC (USA)Analytical ToolProcessorData concerning Affiliate interactions with the Affiliate Program Website for website maintenance and developmentGoogle Privacy
Usercentrics A.S (Denmark)IT InfrastructureProcessorCookie files choices and settings for the CookieBot management toolCookieBot Privacy Policy
Affise Inc. (USA)Attribution Platform and Payment ProcessorProcessorAffiliate registration data, performance and attribution data, and payment information, processed to operate the Program, attribute conversions, and process commission payoutsAffise Privacy Policy
The Rocket Science Group LLC d/b/a Mailchimp (USA)Email communications toolProcessorAll data contained in the email communicationsMailchimp Privacy Statement

(ii) Governmental or public authorities for the purposes of law enforcement, national security, and other issues of public interest importance.

7. HOW CAN YOU CONTROL YOUR PERSONAL DATA?

HIGHLIGHT: We want you to stay in control of your personal data and can help you exercise your privacy rights.

You have privacy rights related to your personal data when taking part in the Program. To exercise these rights, please contact us at privacy@strikerz.inc. Please note that we may need to verify your identity before fulfilling requests submitted by email.

Here are the privacy rights you have regarding your personal data:

(i) Right of access and portability. You have the right to be informed which personal data about you we process, including the categories of personal data we have, where we receive it from, how and for which purposes we use it, who may have access to this information. You can also request a copy of the personal data we have about you, and we will provide it in a commonly used and machine-readable format.

(ii) Right of rectification. You have the right to have any inaccurate or outdated personal data about you corrected or updated. 

(iii) Right of erasure. You have the right to delete the personal data about you in the Program. 

(iv) Right to restriction of processing. You have the right to restrict our use of your personal data in case you claim that we use inaccurate data or that we use your personal data unlawfully. 

(v) Right to object to processing. You have the right to object to our use of your personal data when we process it on the basis of Legitimate Interest. Please note that in case such personal data is necessary to defend a legal claim, or under any other legally permitted exception, we will be able to continue to use it.

(vi) Right to withdraw your consent. You can withdraw your previously provided consent for our use of your personal data for the particular purposes. However, our processing of your personal data preceding such withdrawal will remain lawful.

(vii) Right to object to automated decision making. You have the right to know, whether we use any automated technologies, including profiling that can have significant impact on you, to object to such use of your personal data and to request a revision by a human. Currently we do not use such technologies.

(viii) Right to lodge a complaint. You can make a complaint against our processing of your personal data by contacting your local supervisory authority for data protection (if there is any in your place of residence). The residents of EEA, UK and Switzerland may find more details about their local supervisory authorities as follows:

EEA list of local authorities

UK: Information Commissioner’s Office

Swiss Federal Data Protection and Information Commissioner

However, we encourage you to contact us directly using the details in the “Our Contact Details” section above so we can address your concerns first.

8. WHAT ARE THE INTERNATIONAL OPERATIONS YOU SHOULD KNOW ABOUT?

HIGHLIGHT: We use providers that operate globally to run the Program, which means your personal data may be processed abroad from your place of residence.

XTEN Limited is based in Cyprus, and we work with trusted providers worldwide to operate and improve the Program. This means your personal data may be processed in countries outside your place of residence, including the EEA, UK, Switzerland, the United States, or elsewhere. When we transfer your personal data internationally, we apply safeguards like the EU Standard Contractual Clauses, the EU-U.S. Data Privacy Framework, the UK International Data Transfer Agreement, the Swiss-U.S. Data Privacy Framework, and other approved mechanisms to ensure your personal data remains protected.

9. WHAT ARE OUR DATA PRACTICES FOR NON-EUROPEAN AFFILIATES?

HIGHLIGHT: We want all Affiliates to know their privacy rights wherever they live. Below is important information for Affiliates around the world as the Program and community expand.

This section contains additional information relevant to residents of certain U.S. states that have their own privacy laws and associated rights. These states currently include California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. Except where otherwise noted, this section applies to residents of all states listed above. 

9.1. Notice at Collection

For a detailed overview of the types of personal data we collect and the purposes for which we use it, please see the section “HOW DO WE USE YOUR PERSONAL DATA?” in this Policy.

9.2. Sources of Personal Data

For the categories of sources from which personal data is collected, see the section “HOW DO WE COLLECT PERSONAL DATA?” in this Policy.

9.3. Disclosure of Personal Data

For the categories of third parties to whom personal data is disclosed, see the section “WHO DO WE SHARE YOUR PERSONAL DATA WITH?” in this Policy.

9.4. Privacy Rights

Affiliates residing in the U.S. states listed above have specific rights over how their personal data is collected, used, shared, and processed. These rights are subject to applicable laws and may differ depending on the state:

(i) Right to Know / Access. You have the right to know what personal data we collect about you. This includes the categories of sources from which we collect your personal data, the purposes for which we collect, “sell,” “share,” or process it for targeted advertising, the categories of third parties with whom we share personal data, the types of personal data disclosed, and the specific pieces of personal data we hold about you in a usable format.

(ii) Right to Data Portability. You have the right to access your personal data in a portable format.

(iii) Right to Delete. You have the right to request that we delete the personal data we have collected from or about you.

(iv) Right to Correct. You have the right to request that we correct inaccurate personal data that we maintain about you.

(v) Right to Opt Out of Targeted Advertising, Sale, or Sharing of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” or “sharing” of your personal data.

(vi) Right to Request Categories of Third Parties. You have the right to request a list of the categories of third parties to which we have disclosed your personal data.

(vii) Right to Appeal. You have the right to challenge our decision if we decline to act on your privacy rights request. To do so, please contact us and let us know that you wish to file an appeal. We will review your appeal and provide a written response within 60 days, explaining our decision and any actions we have taken. If we deny your appeal, you can file a complaint with the relevant data protection authority or consumer protection agency in your state.

(viii) Right to Non-Discrimination. You have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise your rights. However, the exercising of the rights described below may result in a different price, rate, or quality/level of product or service where that difference is reasonably related to the impact the right has on our relationship with you or is otherwise permitted by law.

(ix) Right to Request Specific List of Third Parties (residents of Minnesota, Rhode Island, and Oregon only). You have the right to request a list of the specific third parties to which we have disclosed personal data.

(x) Shine the Light Requests (resident of California only). Under California’s Shine the Light law, California residents may, once per year, request: (i) a list of the categories of personal data we disclosed to third parties in the preceding calendar year for their direct marketing purposes, and (ii) a list of the categories of third parties to whom such data was disclosed.

10. HOW DO WE SECURE YOUR PERSONAL DATA?

HIGHLIGHT: We work hard to keep your personal data safe and will let you know if something goes wrong.

We take the security of your personal data seriously. To protect it, we use trusted service providers, secure technologies, and strong internal practices, including regular staff training and device security. While no system is perfect, we work hard to prevent unauthorised access, loss, or misuse of your personal data. If we ever discover a breach that could affect you, we will notify you as required by law and take steps to keep your personal data safe.

11. HOW DO WE UPDATE THIS POLICY?

HIGHLIGHT: We update this Policy as needed and will let you know if changes could affect you.

We may update this Policy from time to time to keep it clear, accurate, and in line with changing laws or the Program. When we do, we will change the “Last Updated” date at the top. If any update could significantly affect you, we will let you know in advance, as required by law, and notify you by email or through the Program.