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Terms And Conditions

Privacy Policy

Terms And Conditions

Affiliate Program Terms and Conditions

Last updated: 10 April 2026

These Terms and Conditions (the "Terms") govern participation in the ZenoBet Affiliate Program operated by 3102938112 S.R.L., having its registered address at Condominium Guachipelín, San José, Escazú, San Rafael, Costa Rica (the "Company", "we", "us"). By submitting an affiliate application, accessing an Affiliate Account, using Affiliate Links, promoting the Company Websites, or accepting any Commission, an approved affiliate (the
"Affiliate", "you") confirms that it has read, understood, and accepted these Terms.

The Company may amend these Terms from time to time in accordance with Section 11. Continued participation in the Affiliate Program after the effective date of an amendment constitutes acceptance of the updated Terms unless the Affiliate ceases participation before that effective date.

1. Introduction

These Terms govern the Affiliate’s participation in the ZenoBet Affiliate Program for the promotion of the Company Websites and related services.

2. Definitions

For the purposes of these Terms:

Affiliate means the individual or legal entity approved to participate in the Affiliate Program.

Affiliate Account means the account approved by the Company for participation in the Affiliate Program, including any account created for the Affiliate on the Company’s designated third-party affiliate management and tracking platform, currently Raventrack.

Affiliate Links means tracking links, promo codes, banners, creatives, and other attribution tools supplied or approved by the Company through the Affiliate Platform or otherwise in writing.

Affiliate Platform means the third-party tracking and affiliate management system used by the Company from time to time for reporting, attribution, and commission calculation for the Affiliate Program, currently Raventrack.

Affiliate Program means the marketing relationship under which the Affiliate promotes the Company Websites in return for Commission.

Applicable Law means all laws, regulations, licence conditions, codes, advertising rules, consumer-protection requirements, privacy laws, anti-spam rules, sanctions laws, and responsible-gambling requirements applicable to the Affiliate, the Company, the marketing activity, and the target jurisdiction.

Commission means the compensation payable to the Affiliate for referring Qualified New Customers in accordance with the applicable Commission Structure and these Terms.

Commission Structure means the agreed commercial model between the Company and the Affiliate, including revenue share, CPA, hybrid, or any custom arrangement.

Company Reports means the reports, statistics, tracking data, financial data, and related records generated by the Affiliate Platform and/or the Company’s internal systems and used to calculate Commission.

Company Websites means https://www.zenobet.io and any related or mirror websites operated or designated by the Company.

High-Roller means a customer generating negative NGR of EUR 10,000 or more in a qualifying month.

Net Gaming Revenue or NGR means revenue generated by referred customers, calculated by the Company using Company Reports, the Affiliate Platform, and the Company’s reconciliation
methodology, subject to the applicable Commission Structure.

New Customer means a first-time depositing customer meeting the applicable minimum deposit requirements, excluding the Affiliate and any related parties, and excluding duplicate, fraudulent, refunded, self-referred, or otherwise disqualified accounts.

Prohibited Territory means any jurisdiction where gambling, affiliate marketing related to gambling, or the promotion of the Company Websites is prohibited, restricted, or not approved under Applicable Law or Company policy.

Qualified New Customer means a New Customer that meets all qualification criteria set out in these Terms and any applicable commercial schedule.

3. Affiliate Registration and Account

3.1 Approval

Participation in the Affiliate Program is subject to approval by the Company at its sole discretion.

3.2 Accuracy of information

The Affiliate shall ensure that all information provided to the Company is accurate, complete, and kept up to date at all times.

3.3 Security and credentials

The Affiliate is responsible for maintaining the confidentiality of its login credentials and for all activity conducted through the Affiliate Account, including access to the Affiliate Platform.

3.4 One account rule

The Affiliate may not open or operate more than one Affiliate Account without the Company’s prior written consent.

3.5 Use of Raventrack

The Affiliate acknowledges that the Affiliate Program is operated using the Affiliate Platform, currently Raventrack. Access details for the Affiliate Platform may be provided by the Company or generated automatically by the platform.

3.6 Review of reports

The Affiliate is responsible for regularly reviewing reports, statistics, and data made available in the Affiliate Platform and must notify the Company in writing of any suspected discrepancies, missing tracking, or reporting errors within thirty (30) days of the relevant report date or report availability date.

3.7 Reconciliation and finality

If the Affiliate reports a discrepancy in time, the Company will investigate in good faith using Affiliate Platform data, internal system logs, and other reasonably available evidence. In the event of any discrepancy between data shown in the Affiliate Platform and the Company’s internal records, the Company’s reconciled records shall govern for Commission purposes unless the Affiliate demonstrates a manifest error with supporting evidence.

3.8 Deemed acceptance

If the Affiliate does not report a discrepancy within the thirty (30) day review period, the relevant Company Reports shall be deemed accepted and final for Commission purposes, except in cases of fraud, abuse, or obvious technical failure.

4. Affiliate Obligations

4.1 Promotion and representation

The Affiliate may promote the Company Websites solely via approved Affiliate Links and approved marketing materials made available through the Affiliate Platform or otherwise supplied or approved by the Company.

The Affiliate shall not present itself as the Company or imply ownership, official representation, or operational control of the Company Websites unless expressly authorised in writing by the Company.

4.2 Prohibited traffic and conduct

The Affiliate shall not:

●refer itself or related parties, including employees, family members, or associates;

●generate fraudulent, misleading, artificial, incentivised, or non-genuine traffic;

●engage in bonus abuse, money laundering, or any form of affiliate fraud;

●mask, obscure, manipulate, or misrepresent traffic sources;

●offer cashback, value-back, rebates, rewards, or loyalty schemes not offered or approved
by the Company;

●promote the Company Websites in any Prohibited Territory or in any jurisdiction where
such activity is unlawful, restricted, or not compliant with Applicable Law;

●target minors, persons under the legal gambling age, vulnerable persons, or self-excluded
persons;

●use spam, unsolicited email, unsolicited SMS, unlawful direct messaging, or any
non-compliant direct marketing;

●use tracking links, promo codes, pixels, or other attribution tools not generated by or
expressly approved through the Affiliate Platform or by the Company in writing;

●self-refer, use duplicate accounts, or otherwise seek to manipulate attribution or
Commission outcomes.

Any traffic or New Customers generated in breach of these Terms shall be deemed invalid and non-commissionable. The Company reserves the right to reverse Commission generated by fraudulent, duplicate, bonus-abuse, or non-genuine players at any time.

4.3 Brand bidding and keyword restrictions

The Affiliate shall not, directly or indirectly, bid on, purchase, or otherwise use the Company’s brand names, trademarks, or any confusingly similar variations as keywords in paid search, display advertising, social media advertising, or any other form of paid media.

Prohibited keywords include, but are not limited to:

●ZenoBet;

●ZenoBet bonus;

●ZenoBet promo;

●any misspellings, pluralisations, abbreviations, or combinations of the above.

This restriction applies to search engines, domain names, subdomains, social media advertising platforms, and any paid traffic source. Any New Customers acquired through prohibited branded keyword activity shall be deemed invalid and shall not qualify for Commission. The Company reserves the right to void such Commission, apply the minimum revenue share rate, suspend the Affiliate Account, or terminate participation in the Affiliate Program.

4.4 Content and website compliance

Affiliate websites, channels, pages, and content must:

●comply with all Applicable Law and advertising regulations;

●not target minors or restricted jurisdictions;

●not contain illegal, misleading, offensive, defamatory, discriminatory, or deceptive
content;

●not create confusion with, imitate, copy, or misrepresent the Company Websites;

●be promptly amended or removed if the Company requests changes for legal, regulatory,
platform, or brand-protection reasons.

4.5 Records and evidence

The Affiliate shall maintain accurate and complete records of campaigns, creatives, placements, domains, media buys, consent evidence, and relevant traffic-source information for at least five (5) years and shall provide such records promptly upon the Company’s request where reasonably required for compliance, investigation, or audit purposes.

5. Data Protection and Privacy

The Affiliate shall comply with the General Data Protection Regulation (GDPR), where applicable, and all other applicable data protection and privacy laws.

The Affiliate shall not receive, process, or store personal data of Company customers except where expressly authorised by the Company in writing and permitted by Applicable Law.

The Affiliate shall implement appropriate technical and organisational measures to protect any personal data it processes in connection with the Affiliate Program.

6. Commission and Payments

6.1 Basis of calculation

Commission is calculated monthly in accordance with the applicable Commission Structure using Company Reports sourced from the Affiliate Platform, currently Raventrack, and
reconciled with the Company’s internal accounting and fraud-control systems. The minimum payout threshold is EUR 100. Commission below this amount will be carried forward to the following month until the threshold is reached.

6.2 Primary reporting source

The Affiliate acknowledges that clicks, registrations, New Customers, wagering activity,GGR/NGR, and Commission are primarily tracked and reported through the Affiliate Platform. TheAffiliate must review Affiliate Platform reports and notify the Company in writing of any discrepancies within thirty (30) days after the relevant monthly report becomes available.

6.3 Error correction

Where a discrepancy is reported in time and the Company identifies a manifest tracking or reporting error following review of Affiliate Platform data, internal logs, and other available evidence, the Company may correct or adjust the relevant figures and any resulting Commission in the next payment cycle.

6.4 Finality of reporting

If the Affiliate does not report a discrepancy within the review period, the Company Reports, as reconciled by the Company, shall be deemed final and binding for Commission purposes except in the case of fraud, abuse, or obvious technical failure.

6.5 Payment timing

Payments are made monthly in arrears, no later than the 25th day of the following calendar month, subject to receipt of any required invoice or payout information.

6.6 Payment method

Payments shall be made via cryptocurrency unless otherwise agreed in writing. The Affiliate is solely responsible for providing a correct wallet address. The Company shall not be liable for payments sent to an incorrect wallet address provided by the Affiliate.

6.7 Negative carryover

If the Affiliate Account has a negative NGR balance at the end of any calendar month, that negative balance shall be carried forward to the following month or months and offset against future positive NGR generated by the Affiliate’s referred customers until the balance returns to a positive figure. No Commission shall be payable until the negative balance has been fully offset.

6.8 Inactive accounts

If the Affiliate fails to refer at least one (1) New Customer within a rolling period of one hundred and eighty (180) days, the Company reserves the right to classify the Affiliate Account as inactive. During inactive status, the Company may reduce the commission rate to 0% until the Affiliate refers a new depositing customer.

6.9 Withholding and investigations

The Company reserves the right to delay, withhold, adjust, or cancel Commission payments while investigating suspected fraud, bonus abuse, breach of these Terms, sanctions issues, payment risk, duplicate accounts, tracking manipulation, or other suspicious activity.

6.10 Taxes

The Affiliate is solely responsible for all applicable taxes, duties, levies, reporting obligations, and other governmental charges arising in connection with any Commission paid under these Terms.

6.11 Commission changes

The Company reserves the right to change the Commission Structure with one (1) day notice, provided that any such change may be notified through the Affiliate Platform and/or by email.

7 . High-Roller Policy

If a High-Roller generates negative NGR of EUR 10,000 or more in a qualifying month:

●the qualifying month’s Commission remains unchanged;

●the negative NGR shall be carried forward and offset only against that same High-Roller’s
future positive NGR, unless otherwise agreed in writing;

●negative balances may not be offset against other customers.

Detailed calculations and adjustments are governed by the Company’s High-Roller Policy.

8. Confidentiality

All non-public information relating to the Company, the Affiliate Program, the Affiliate Platform, Commission, reports, commercial terms, and business operations is confidential and shall not be disclosed without the Company’s prior written consent, except where disclosure is required by law.

This obligation survives termination of participation in the Affiliate Program.

9. Suspension and Termination

9.1 Ordinary termination

Either party may terminate participation in the Affiliate Program with thirty (30) days’ written notice.

9.2 Immediate suspension or termination

The Company reserves the right to suspend or terminate the Affiliate Account and participation in the Affiliate Program immediately, without prior notice, in the event of:

●breach of these Terms;

●suspected fraud, bonus abuse, or illegal activity;

●provision of false or misleading information;

●inactivity as defined in Section 6.8;

●any activity that may harm the reputation or interests of the Company.

9.3 Consequences of termination

Upon termination:

●all Affiliate Links, tracking links, and creatives must be removed immediately;

●all rights and licences granted under these Terms shall cease;

●no further Commission shall be payable from the termination date, subject to any valid
accrued rights existing before termination and subject to fraud review, negative carryover,
and applicable hold periods;

●any unwithdrawn balances may be forfeited after six (6) months following termination.

10. Limitation of Liability and Indemnity

10.1 Warranty and liability

The Company undertakes that the Company Websites and Affiliate Program will be operated within the scope of current technical possibilities, but no liability is accepted for interruptions, downtime, technical issues, tracking failures, or further claims beyond the limits set out in these Terms.

The liability of the legal representatives and vicarious agents of the Company shall be limited to intent and gross negligence. The liability of the Company, for whatever reason, shall be limited to the amount of Commission paid to the Affiliate within the last three (3) months. If participation is terminated before the end of three months, the Commission paid until that date shall apply for the calculation of damages.

10.2 Indemnity

The Affiliate shall indemnify and hold harmless the Company, its group companies, officers, directors, employees, agents, and service providers from and against any losses, liabilities, claims, costs, penalties, fines, damages, and expenses arising out of or related to the Affiliate’s breach of these Terms, unlawful marketing, intellectual property infringement, privacy violations, spam, fraud, or breach of Applicable Law.

11. General

11.1 Amendments

The Company reserves the right to alter any regulations and provisions hereunder at any time,including changes to the Affiliate Platform provider, reporting methods, Commission Structure, or operational rules. The Affiliate shall be notified of the alteration by notification in the Affiliate Account or Affiliate Platform and/or via email sent to the Affiliate’s registered email address. If participation is not terminated within one (1) week from receipt of the alteration notice, the alteration shall be regarded as accepted.

11.2 Governing law

These Terms shall be governed by the laws of Costa Rica. Any dispute arising under or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Costa Rica.

11.3 Entire terms

These Terms constitute the entire terms governing participation in the Affiliate Program and supersede all prior agreements, understandings, negotiations, and communications relating to the Affiliate Program.

11.4 Severability

If any provision of these Terms is deemed invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.

11.5 Language

These Terms are drafted in English. In the event of any discrepancy between translated versions, the English version shall prevail.

11.6 Force majeure

The Company shall not be liable for any delay or failure to perform its obligations due to events beyond its reasonable control, including technical failures, cyberattacks, acts of government, natural disasters, war, civil unrest, labour disputes, failures of telecommunications providers, or interruptions to blockchain networks.

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.