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Universal Poker Logo

Privacy Policy

Last updated: 5 March 2026

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1. Introduction2. Data Controller3. The Data We Collect & How We Use It4. Legitimate Interests (transparency)5. Partner Operators6. Marketing & Communications7. Cookies & Analytics8. International Transfers9. Who We Share Data with10. Data Retention11. Your Rights12. Security13. Personal Data Breaches14. Contact15. Changes

1. INTRODUCTION

This Privacy Policy (Part B) explains how we collect, use, share, and protect your personal data when you use the Platform, in accordance with the UK GDPR and the Data Protection Act 2018. It should be read together with Part A (Terms & Conditions) and Part C (Cookie Policy).

We process personal data only to the extent necessary to support fairness, transparency, user protection, fraud prevention, and legal/regulatory compliance.

2. DATA CONTROLLER

Universal Affiliates Limited is the data controller responsible for your personal data.

Universal Poker is a trading name of Universal Affiliates Limited.

Sutherland House, 1759 London Road, Leigh-on-Sea, Essex, SS9 2RZ

Contact for all privacy and data protection queries: Support@universalaffiliates.com

We have not appointed a Data Protection Officer (DPO), as we do not meet the thresholds requiring mandatory DPO appointment under the UK GDPR (Article 37). The contact point for all data protection matters is the address and email above.

We may record acceptance events for compliance/evidential purposes.

3. THE DATA WE COLLECT & HOW WE USE IT

You are not required to provide all data, but without certain data some features cannot function.

A) Account creation (mandatory)

  • Data: email, encrypted password, declared country, identifiers/timestamps, and optional profile/contact fields you choose to provide (e.g., full name, Discord ID, Telegram).
  • Purpose: account creation and security, operational service delivery, account administration/support, and compliance controls including legal eligibility verification by jurisdiction
  • Lawful basis: Contract; Legitimate interests (security/compliance)

B) Apply for deal / reactivation (optional)

  • Data: operator username (and where needed operator-registered email), application metadata/status logs
  • Purpose: process and operationally manage your request; liaise with operators/affiliate systems
  • Lawful basis: Contract (or Consent where a specific feature requires it)

C) Dashboard / performance

  • Data: rake generated (including provisional or estimated values where operator reporting is pending), reward estimates, deal status
  • Purpose: provide dashboard reporting
  • Lawful basis: Contract Performance (Art. 6(1)(b)) — displaying performance data in your dashboard is part of the contracted service. You may control this as a personal display preference via account settings.
  • Note: Dashboard values are sourced from Partner Operator reporting channels and may be delayed, reconciled, or adjusted retroactively

D) Referrers (commission verification only)

  • Data shared: masked identifiers/alias + aggregated metrics
  • Not shared: name/email/address/password
  • Purpose: commission verification; disputes; audit trail
  • Lawful basis: Legitimate Interests (UK GDPR Art. 6(1)(f)) — necessary for transparent commission verification and the commercial operation of the Platform. A Legitimate Interests Assessment (LIA) has been conducted and is available on request.
  • Right to object: you may object at any time via Account Settings or by emailing support@universalaffiliates.com — objections are actioned immediately
  • Removing your objection: if you remove your objection, reporting resumes on a forward-looking basis only from the date the objection was removed — no historic data from the objection period is retroactively shared

E) Support

  • Data: contact details, messages, account identifiers, diagnostics/security logs
  • Purpose: support/enforcement/abuse prevention
  • Lawful basis: Contract; Legitimate interests

F) Technical/security/anti-abuse (always-on)

  • Data: device/browser, login events, IP-derived location signals, account and identity-related information where available, security logs, fraud indicators, geo-blocking signals (incl. VPN/proxy indicators)
  • Purpose: security, legal age and eligibility checks by jurisdiction, fraud prevention, anti-money-laundering compliance support, social responsibility safeguards, geo-blocking enforcement, and restricting access from prohibited or high-risk jurisdictions where required
  • Lawful basis: Legitimate interests; Legal obligation where applicable

4. LEGITIMATE INTERESTS (TRANSPARENCY)

We use legitimate interests for Platform security, fraud prevention, compliance controls, and referrer-visible reporting for commission verification. Where we rely on legitimate interests, we apply safeguards such as data minimisation, access controls, and pseudonymisation/masking. You have the right to object to legitimate interests processing — see Section 3D above for details.

5. PARTNER OPERATORS

Partner Operators are independent third parties. If you use their services, they process your data under their own privacy policies and terms. We do not control their KYC decisions, gameplay, or payments/rewards.

6. MARKETING & COMMUNICATIONS

We send marketing emails only where you have opted in (or where permitted). You can unsubscribe at any time. We may use an email provider (e.g., Brevo). If email analytics/tracking is enabled, we use consent controls where required by law. We maintain opt-in/opt-out controls and suppression handling for marketing communications. Where applicable to our services, marketing and promotional activity is operated in alignment with the Gambling Commission's Licence Conditions and Codes of Practice (LCCP), the CAP Code, and ASA advertising rules.

7. COOKIES & ANALYTICS

We use strictly necessary cookies (e.g. for authentication and security). Where analytics or marketing cookies are enabled (including GA4), we use a cookie consent mechanism and only load non-essential cookies after you have given consent where required by law.

You can manage or withdraw cookie consent at any time via Cookie Settings on the Platform. For full details, see our Cookie Policy at /cookie-policy. This Privacy Policy (Part B) should be read together with our Terms & Conditions (Part A) and Cookie Policy (Part C).

8. INTERNATIONAL TRANSFERS

Your data may be processed outside the UK. Where transfers occur, we use appropriate safeguards (e.g., UK IDTA and/or UK Addendum to EU SCCs) or other lawful mechanisms.

9. WHO WE SHARE DATA WITH

We do not sell your personal data. We may share it only as described below.

Service Providers (Data Processors)

  • Supabase Inc. — database and authentication provider. Servers located in East US (Northern Virginia, USA). Transfers are covered by Supabase's executed Data Processing Addendum (DPA), incorporating the UK Addendum (B.1.0) to the EU Standard Contractual Clauses, enforceable under the UK Data Protection Act 2018. Data processed: account data, authentication records, application data, consent logs, and security logs.
  • Brevo SAS — transactional and marketing email delivery. Data may be processed in the EU and USA. Transfers are covered by Brevo's DPA incorporating applicable Standard Contractual Clauses. Data processed: email address, full name (where provided), and country.
  • Vercel Inc. — hosting and infrastructure. Servers located in the USA. Transfers are covered by Vercel's DPA incorporating applicable Standard Contractual Clauses. Data processed: request metadata, IP-derived signals, and access logs.
  • Google LLC (Google Analytics 4, when enabled) — website analytics. Servers located in the USA. Transfers are covered by Google's DPA incorporating applicable Standard Contractual Clauses. Data processed: anonymised/pseudonymised device and browser information, page view and interaction events. IP addresses are anonymised before storage where technically possible.

Referrers / Sub-Affiliates

  • We may share limited, masked reporting data (masked alias and aggregated metrics only) with the Referrer who introduced you to the Platform, solely for commission calculation, verification, and related audit purposes. No name, email, address, or password is shared. This processing is carried out on the basis of our Legitimate Interests (UK GDPR Art. 6(1)(f)). You have the right to object at any time via Account Settings or by emailing support@universalaffiliates.com. If you object, we will stop future sharing of such reporting with the Referrer on a forward-looking basis, subject to retention of historic records where required for accounting, audit, or legal purposes. If you later remove your objection, reporting will resume on a forward-looking basis only and no historic data from the objection period will be shared retroactively.

Partner Operators

  • Where you apply for a deal, we share your operator username (and where needed operator-registered email) plus application-related identifiers and status updates with the relevant Partner Operator and/or their affiliate tracking system, to the extent necessary to process and track your application.

Self-Exclusion Compliance Handling

  • If we are notified that you are self-excluded with a Partner Operator or through a multi-operator scheme (e.g. GAMSTOP), we process relevant data to suppress marketing communications, apply account restrictions/closure on our Platform where applicable, and retain compliance records as required by law.
  • We do not reverse or override self-exclusion decisions made by Partner Operators or GAMSTOP.

Authorities and Professional Advisers

  • We may share data with regulators (including the ICO), law enforcement agencies, courts, or professional advisers where required by law, court order, or for the purposes of fraud prevention, compliance, or the establishment, exercise, or defence of legal claims.

10. DATA RETENTION

We retain data only as needed for the purposes above, compliance, fraud prevention, dispute handling, and legal requirements. Typical retention:

For retention purposes, relationship end date means the date your Platform account is closed, terminated, disabled, or otherwise moved into a terminal status.

  • Account/profile/auth data: active + normally up to 5 years after relationship end date
  • AML/compliance and customer due diligence records: normally 5 years from the later of (a) relationship end date or (b) transaction completion date. In specific cases where required by applicable law, regulation, legal hold, or regulator request, retention may be extended up to the applicable statutory maximum (up to 10 years).
  • Deal/application and dashboard/performance records: normally up to 5 years after relationship end date
  • Referrer reporting records: normally up to 5 years after relationship end date
  • Support (including support mailbox records in Gmail): typically up to 3 years from ticket closure, subject to mailbox administration capabilities and legal requirements
  • Security/anti-abuse logs: typically 12-24 months
  • Consent/compliance logs: normally up to 5 years unless a longer legal retention duty applies
  • Marketing preferences: while subscribed; suppression as needed to ensure no re-contact

11. YOUR RIGHTS

Under UK GDPR and the Data Protection Act 2018, you may have the following rights: access to your personal data; rectification of inaccurate data; erasure ('right to be forgotten') where legally applicable; restriction of processing; objection to processing (including direct marketing); data portability; and withdrawal of consent at any time where processing is consent-based. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

How to exercise your rights: Submit a request by email to Support@universalaffiliates.com, clearly stating your name, the email address linked to your account, and the specific right(s) you wish to exercise. We may ask you to verify your identity before processing your request. We will respond within one calendar month of receipt. For complex or multiple requests, we may extend this by a further two months and will notify you accordingly.

If your country of residence changes, request an account-country update by contacting Support@universalaffiliates.com from your registered account email. We may request reasonable verification information to protect account security and compliance, and we may temporarily restrict access to affected offers until verification is completed and records are updated.

Right to complain: If you are not satisfied with how we handle your data or your request, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the opportunity to address your concerns before you contact the ICO.

12. SECURITY

We use reasonable technical and organisational measures including access controls, least privilege, encryption in transit, secure credential handling, monitoring, and anti-abuse processes.

13. PERSONAL DATA BREACHES

If a personal data breach occurs, we assess it promptly and notify competent regulators where legally required, including the ICO and, where relevant to gambling regulatory obligations, the Gambling Commission. We also notify affected users where required by law, without undue delay.

14. CONTACT

  • Universal Affiliates Limited
  • Email: Support@universalaffiliates.com
  • Address: Sutherland House, 1759 London Road, Leigh-on-Sea, Essex, SS9 2RZ

15. CHANGES

We may amend this Privacy Policy at any time for legal, regulatory, compliance, security, operational, or service-related reasons.

Unless stated otherwise, updates take effect when posted. We will publish the latest version and update the "Last updated" date.

Where required by our legal-consent framework, continued use of the Platform may be conditional on explicit re-acknowledgement of the latest legal documents. If you do not agree with an update, you must stop using the Platform.

Important Notice

Please review this policy periodically. We may require explicit re-acknowledgement of updated legal documents before continued Platform access.

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Universal Affiliates Limited

Sutherland House

1759 London Road

Leigh on Sea

Essex, SS9 2RZ

Company Number 11667550

Universal Poker is a trading name of Universal Affiliates Limited.

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Universal Affiliates Limited

Sutherland House

1759 London Road

Leigh on Sea

Essex, SS9 2RZ

Company Number 11667550

Universal Poker is a trading name of Universal Affiliates Limited.

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UNIVERSALPOKER.COM © 2026 All Rights Reserved.