JUS Partners Privacy Policy

1. Who we are and scope

Alfa Gates Partners, incorporated in Georgia, registration number 404831410, registered office Georgia, Tbilisi, Nino and Ilia Nakashidze Street, No. 1, (former Avlevi), Apartment No. 3, Building No. 3, operates JUS Partners (JUS, we, us) and is the controller of the personal data described in this Policy. Data-protection contact for users: dpo@jus.partners. Legal department: legal@jus.partners.

This Policy applies to visitors of jus.partners, affiliate applicants, affiliates and their representatives, business contacts and persons whose pseudonymous click or conversion data is processed through our tracking. It covers the websites jus.partners and partners.jus.partners, the tracking domain traffg.com, the short-link domain go.jus.partners and any other domain operated by us that links to this Policy.

JUS is a B2B affiliate network, not a gambling operator. Advertisers process player data under their own privacy notices; this Policy does not cover player accounts, deposits or gameplay.

We work with affiliates and visitors from many countries. Where the data-protection law of your country applies to the processing of your data, such as the GDPR in the EU and EEA or the UK GDPR in the United Kingdom, you have the rights it gives you in addition to those described in this Policy. Send requests to dpo@jus.partners.

2. Data we collect

Data you provide: name or team name, company and role, country, email, telephone, Telegram or other messenger contact, traffic sources and websites, preferred GEOs and models, account login, messages to us, including messages in the website chat, and your marketing preferences.

Account and payment data: payee name, company details, invoice and tax data, payment method and wallet or bank details, payment history, and KYC documents we request (identity, company registration, beneficial ownership, proof of address).

Technical data: IP address, approximate location derived from IP, browser and device type, operating system, language, referrer, the UTM tags of the link that brought you to the site (utm_source, utm_medium, utm_campaign, utm_content, utm_term), pages visited, time of visit, and identifiers stored in your browser described in section 4.

Tracking data: click IDs, affiliate, Offer and sub-IDs, source and placement, time of click and conversion, conversion status, pseudonymous player references and the deposit or revenue values provided by Advertisers to calculate Commission.

Short-link data: when you follow a link on go.jus.partners, we record a random click ID, the link, the time, the sub1–sub5 tags from the address, the country and the device type. This record does not contain your IP address or browser data. To count unique visits we use a one-way hash of the IP address and browser data with a salt that changes every day.

Sources: you and your authorised users, your device and browser, our tracking platform Affise, Advertisers, payment providers, and public registers. Please do not send us sensitive data, player identity documents or personal data of players in tracking parameters.

3. Purposes and legal bases

We process data to: assess applications and register accounts (performance of a contract or steps before it); run campaigns, track and validate conversions and pay Commission (performance of a contract and our legitimate interest in accurate settlement); verify identity, prevent fraud, abuse and sanctions violations and protect our systems (legitimate interests and legal obligations); keep accounting and tax records (legal obligation); defend legal claims (legitimate interest); respond to enquiries (legitimate interest or steps before a contract); and understand which channels and campaigns bring applications and affiliates, for which we count visits through short links and store with an application the UTM tags, the address of the page it is sent from and the click ID; the click ID links the application to the click and then to the results of the affiliate account (legitimate interest in measuring advertising; the data comes from the page address, uses no cookies and does not require analytics consent).

With your consent we use analytics cookies and session recording on our website and send marketing messages. You can withdraw consent at any time in the cookie settings or by the unsubscribe link or a message to dpo@jus.partners; withdrawal does not affect earlier processing. Service, security and payment notices are not marketing.

For representatives of corporate affiliates we rely on our legitimate interest in managing the business relationship. Where processing is based on legitimate interests, you may object as described in section 9.

We apply the data-protection law of Georgia, where we are established, and additional local rules where they mandatorily apply to us.

4. Cookies and similar technologies

Necessary storage (always on): jus-cookie-consent-v1 and jus-consent store your cookie choice for 180 days; jus-lang stores your language for 365 days; jus-theme, jus-motion and jus-fs store display preferences until you clear them; jus-notice-hidden hides the announcement bar for the browser session; __Host-jus_admin is a session cookie for our staff admin area only. Cloudflare may set __cf_bm (30 minutes) and cf_clearance (up to one year) for security and bot protection. Google reCAPTCHA may set _GRECAPTCHA (up to six months) when a protected login or form is used.

Analytics (only after you accept analytics): Google Tag Manager loads Yandex Metrica (counter 113130526), which sets _ym_uid and _ym_d (one year), _ym_isad, _ym_visorc and similar short-lived identifiers, and may record your session (Webvisor) with form fields and passwords masked. Our server may also count anonymous presence pings (a random session number, page path, language, referrer host and country derived from the Cloudflare header); these are kept only in server memory and are not linked to your identity.

After separate consent to analytics, Google Analytics 4 through Google Tag Manager collects visit and tagged interaction statistics and uses first-party _ga and _ga_* cookies for up to 180 days. Form field values, passwords, login codes and chat content are not sent to Google Analytics; only UTM tags are passed from the page address; other URL query strings and fragments are removed. Ad personalisation and Google Signals are disabled. Adding Google Analytics requires a fresh cookie choice; earlier Yandex-only consent is not reused. Withdrawing consent stops subsequent delivery and clears accessible first-party Google Analytics cookies; it does not delete data already sent. Google processes technical visit data in its infrastructure, including in the United States. More information: https://policies.google.com/privacy and https://policies.google.com/technologies/partner-sites.

Affiliate tracking: when you click a tracking link on traffg.com or another tracking domain, Affise records a click ID and may set cookies needed to attribute the conversion for the attribution window of the Offer, normally up to 90 days. Affiliates and Advertisers are responsible for obtaining any consent required at their own sites and apps.

You can change or withdraw your choice at any time through the Cookie settings link in the website footer. Refusing analytics disables Yandex Metrica and Google Analytics 4 and clears their first-party cookies where technically possible. You can also block or delete cookies in your browser; blocking necessary storage may affect login.

5. Recipients

Access is limited to JUS staff who need it. We disclose data to: Affise (affiliate-management and tracking platform, processing on our instructions); our dedicated server hosting provider; Cloudflare, Inc. (content delivery and security); Google LLC (Google Tag Manager, Google Analytics 4 only with consent, reCAPTCHA and our corporate email); Telegram (team notifications about applications and the website chat: your messages and application details are passed to the team’s private work group); corporate messengers the team uses to handle applications; Yandex (Yandex Metrica analytics, only with consent); payment providers, banks and crypto-payment services used to pay you; and professional advisers.

Advertisers receive only pseudonymous campaign data needed for attribution, validation and settlement and, where a dispute or fraud review requires it, information about your traffic sources. Affiliates receive aggregated statistics for their own traffic.

We may disclose data to authorities, courts and law-enforcement bodies where required by law or to protect our rights, and to a buyer or successor in a reorganisation under equivalent confidentiality. We do not sell personal data.

6. International transfers

Our service providers process data in several countries, including Georgia, the United States (Cloudflare, Google), the Russian Federation (Yandex Metrica, only with consent), the countries where our hosting provider and Affise operate their infrastructure, and the countries of the payment providers you choose. Cloudflare also processes traffic in its global network nearest to the visitor.

We use providers that undertake to protect data under their data-processing terms and apply contractual and technical safeguards appropriate to the transfer. The current list of providers and countries is available on request at dpo@jus.partners.

7. Retention

We keep data only as long as necessary. Retention periods: enquiries and unsuccessful applications (12 months after the last contact); affiliate accounts and correspondence (the duration of the relationship and 5 years after it ends); raw click, conversion and security logs (24 months, after which statistics are kept in aggregated form); payment, tax and KYC records (7 years after the end of the relationship or longer where the law requires); consent records (while the consent is valid and 3 years after withdrawal or expiry); staff audit logs (3 years); short-link click records (180 days, after which only totals are kept; a click ID linked to an application is kept with the application); hashes for counting unique visits and their salt (no longer than two days); presence pings (in server memory only, no longer than 24 hours).

Data deleted from live systems disappears from backups within 35 days. We may keep data longer if needed for a pending dispute, investigation or legal obligation, and may keep a minimal suppression record to respect your opt-out. Where possible we anonymise data instead of deleting it.

8. Security and automated decisions

We use access control, encrypted connections, password hashing, separation of staff access, logging and backups to protect data. No system is fully secure; if you suspect a data exposure, write to dpo@jus.partners.

Automated rules may flag suspicious traffic and calculate preliminary Commission. Decisions to reject Commission or close an account are reviewed by JUS staff, and you can provide your explanation.

9. Your rights

Subject to applicable law, you may request access to and a copy of your data, correction, deletion, restriction of processing and data portability, object to processing based on legitimate interests, object to direct marketing at any time and withdraw consent.

Send requests to dpo@jus.partners from your registered email. We may ask for information to verify your identity. We answer within 30 days; if the request is complex we may extend this period by a further 30 days and will tell you why. Some data must be kept despite a deletion request, for example payment and tax records.

You may lodge a complaint with the data-protection authority of Georgia (State Audit Office, sao.ge) or with the authority in your country where its law gives you that right. We encourage you to contact us first so that we can resolve the issue.

10. Age and changes

Our services are intended only for persons aged 18 and over who have reached the age of majority in their jurisdiction. We do not knowingly collect data of minors and delete it if we discover it.

We may update this Policy. The current version and its date are published on the website; material changes are announced in the panel or by email before they take effect. English and Russian versions are provided; the English version prevails. Contact: dpo@jus.partners, Georgia, Tbilisi, Nino and Ilia Nakashidze Street, No. 1, (former Avlevi), Apartment No. 3, Building No. 3.