Version 1.2

Poly Casino Affiliate Program Privacy Policy

Effective Date: July 1, 2026

This Privacy Policy explains how Bungie Softworks Limited collects, uses, discloses, stores, and protects personal information in connection with the Poly Casino Affiliate Program.

Bungie Softworks Limited is a company organized under the laws of Texas, with registered address at 700 Lavaca St. Suite 1401, Austin, TX, USA 78701.

Bungie Softworks Limited manages the Poly Casino Affiliate Program only. Bungie Softworks Limited does not own, operate, control, or provide Poly Casino, the Poly Casino website, the sweepstakes casino services, player accounts, gameplay, purchases, redemptions, Gold Coins, Sweeps Coins, prize redemptions, payment processing, identity verification, or player-facing services.

In this Privacy Policy, “Bungie Softworks,” “Affiliate Program Manager,” “we,” “us,” and “our” refer to Bungie Softworks Limited in its role as manager of the Poly Casino Affiliate Program.

“Affiliate,” “you,” and “your” refer to any person or entity that applies to participate in, participates in, communicates with us about, or otherwise interacts with the Poly Casino Affiliate Program.

If you do not agree with this Privacy Policy, please do not apply for or participate in the Poly Casino Affiliate Program.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected by Bungie Softworks in connection with:

This Privacy Policy does not govern the player-facing privacy practices of Poly Casino, polycasino.com, the Poly Casino sweepstakes casino services, player accounts, gameplay, purchases, redemptions, or player support.

Player-facing data practices are governed by the privacy policy made available by the applicable Poly Casino operator.

2. Role of Bungie Softworks

Bungie Softworks acts as the manager of the Poly Casino Affiliate Program.

In this role, Bungie Softworks may collect and process Affiliate information and limited affiliate-attribution data for purposes such as application review, campaign approval, affiliate tracking, commission calculation, fraud prevention, compliance review, invoice processing, payment administration, and Affiliate Program management.

Bungie Softworks does not decide, operate, or control player-facing gameplay, player accounts, Gold Coins, Sweeps Coins, purchases, redemptions, identity verification, prize fulfillment, or player support.

3. Affiliate Program Eligibility and Geographic Restrictions

The Poly Casino Affiliate Program relates to the promotion of Poly Casino, a U.S.-only sweepstakes casino brand intended for eligible users who are 21 years of age or older and located only in jurisdictions where Poly Casino is available.

Affiliates must not target users outside the United States or in Restricted Jurisdictions.

Restricted Jurisdictions currently include:

Bungie Softworks may process information relating to Affiliate traffic sources, user location signals, campaign targeting, and performance reports to help monitor compliance with these restrictions.

4. Personal Information We Collect

We may collect the following categories of personal information in connection with the Affiliate Program.

4.1 Affiliate Account and Identity Information

When you apply for or participate in the Affiliate Program, we may collect:

4.2 Affiliate Business and Traffic Source Information

We may collect information about your business and promotional activities, including:

4.3 Payment, Invoice, and Tax Information

To process affiliate payments, we may collect:

4.4 Affiliate Tracking and Performance Information

We may collect or receive Affiliate Program performance information, including:

4.5 Limited Referred-User Attribution Information

Bungie Softworks may receive limited information relating to users referred through Affiliate links or campaigns for affiliate tracking, commission calculation, fraud prevention, compliance review, and traffic-quality analysis.

This information may include:

Bungie Softworks does not operate player accounts or player services. We do not control player gameplay, purchases, redemptions, identity verification, or prize fulfillment.

4.6 Communications Information

When you contact us or communicate with us, we may collect:

4.7 Device, Internet, and Technical Information

When you use affiliate.polycasino.com or related Affiliate Program tools, we may automatically collect:

4.8 Information from Third Parties

We may receive Affiliate Program information from third parties, including:

5. How We Use Personal Information

We may use personal information for the following purposes.

5.1 To Operate the Affiliate Program

We use personal information to:

5.2 To Review Traffic Quality and Compliance

We use personal information to:

5.3 To Process Payments

We use personal information to:

5.4 To Communicate with You

We may use personal information to send:

5.5 For Security and Fraud Prevention

We may use personal information to:

5.6 For Legal, Business, and Administrative Purposes

We may use personal information to:

6. Cookies and Similar Technologies

We may use cookies, pixels, SDKs, local storage, tracking links, device identifiers, and similar technologies in connection with the Affiliate Program.

These technologies may be used to:

You may be able to manage cookies through your browser settings. If you disable cookies, some Affiliate Program features may not function properly.

7. How We Share Personal Information

We may share personal information with the following categories of recipients.

7.1 Service Providers

We may share personal information with companies that help us operate the Affiliate Program, including:

7.2 Poly Casino and the Poly Casino Operator

We may share Affiliate Program information with Poly Casino and the applicable Poly Casino Operator for purposes including:

7.3 Payment, Tax, and Professional Service Providers

We may share information with payment providers, banks, tax advisers, accountants, auditors, legal advisers, and other professional service providers to process payments, maintain records, comply with legal obligations, and manage business operations.

7.4 Legal, Compliance, and Safety Disclosures

We may disclose personal information where we believe it is necessary to:

7.5 Business Transfers

We may disclose or transfer personal information in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, change of control, or similar business transaction involving Bungie Softworks or the Affiliate Program.

8. Sale or Sharing of Personal Information

We do not sell personal information for money.

However, certain privacy laws may define “sale,” “sharing,” or “targeted advertising” broadly. Some Affiliate Program tracking, analytics, marketing, or attribution activities may be considered a “sale,” “sharing,” or use for targeted advertising under certain state privacy laws.

Where required by applicable law, eligible individuals may have the right to opt out of such sale, sharing, or targeted advertising.

To submit a privacy request, contact us at affiliate@polycasino.com.

9. Marketing Choices

You may opt out of promotional emails by using the unsubscribe link included in the email.

Even if you opt out of marketing communications, we may still send you non-promotional messages, including account notices, payment notices, security alerts, compliance notices, support responses, policy updates, and legal notices.

10. Your Privacy Rights

Depending on your state of residence and applicable law, you may have certain privacy rights, including the right to:

To exercise privacy rights, contact us at affiliate@polycasino.com.

We may need to verify your identity before fulfilling your request. We may deny or limit requests where permitted by law, including where information is needed for security, fraud prevention, legal compliance, transaction completion, dispute resolution, account integrity, or other permitted purposes.

11. Authorized Agents

Where required by applicable law, you may authorize another person to submit a privacy request on your behalf.

We may require proof that the agent is authorized to act for you. We may also require you to verify your identity directly with us.

12. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to:

Retention periods may vary depending on the type of information, the nature of your relationship with us, legal requirements, and business needs.

When personal information is no longer required, we may delete, de-identify, aggregate, or securely retain it as permitted by law.

13. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, loss, misuse, disclosure, alteration, or destruction.

However, no website, app, system, database, or electronic transmission is completely secure. We cannot guarantee absolute security.

You are responsible for keeping your affiliate login credentials confidential and for notifying us promptly if you believe your Affiliate account has been compromised.

14. Children and Minors

The Affiliate Program is not intended for children or minors.

You must be at least 21 years old to participate in the Affiliate Program or promote Poly Casino.

We do not knowingly collect personal information from anyone under 21 in connection with the Affiliate Program. If we learn that we have collected personal information from a person under 21, we may delete the information and close or restrict the account.

If you believe that a person under 21 has provided personal information to Bungie Softworks, please contact us at affiliate@polycasino.com.

15. Third-Party Links and Services

Affiliate Program websites, dashboards, emails, or materials may contain links to third-party websites, services, payment providers, analytics providers, affiliate platforms, Poly Casino websites, social media platforms, or promotional pages.

We are not responsible for the privacy practices, content, or security of third-party services. You should review the privacy policies of any third-party services you use.

16. International Data Transfers

Bungie Softworks is based in the United States. However, our service providers, vendors, or technical systems may process personal information in other jurisdictions.

When personal information is transferred or processed outside your state or location, we take steps designed to protect personal information as required by applicable law.

17. Do Not Track Signals

Some browsers may transmit “Do Not Track” signals. Because there is no uniform industry standard for responding to such signals, Bungie Softworks does not currently respond to all browser-based Do Not Track signals.

You may still manage cookies, advertising preferences, and tracking technologies through your browser, device, and applicable opt-out tools.

18. Affiliate Responsibilities

Affiliates are responsible for ensuring that their own websites, landing pages, social media channels, email lists, SMS campaigns, tracking technologies, and marketing activities comply with applicable privacy, advertising, consumer protection, and data protection laws.

Affiliates must provide all required notices, obtain all required consents, honor opt-out requests, and maintain appropriate records for their own marketing activities.

Affiliates must not provide Bungie Softworks with personal information unless they have the legal right to do so.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make changes, we may update the version number, effective date, and/or publish the updated Privacy Policy at affiliate.polycasino.com/privacy.

If changes are material, we may provide additional notice as required by law.

Your continued participation in the Affiliate Program after the updated Privacy Policy becomes effective means you acknowledge the updated Privacy Policy.

20. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or your privacy rights, you may contact us at:

Bungie Softworks Limited
700 Lavaca St. Suite 1401
Austin, TX, USA 78701

Email: affiliate@polycasino.com

Privacy Policy URL: affiliate.polycasino.com/privacy