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Gambling Affiliates’ Guide to GDPR

George Miller

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Gambling Affiliates’ Guide to GDPR
Reading Time: 7 minutes

As of the 25th May 2018, the GDPR comes into effect, and its influence will be felt across virtually every industry imaginable where data is being collected and used on individuals located in the EU. Its overall aim is to ensure better protection of consumers’ information, both online and offline, by enforcing regulations on how data is collected, processed and secured.

What is GDPR?

GDPR stands for General Data Protection Regulation. It’s the result of over 6 years of preparation and consultation over data privacy concerns for EU consumers. The way in which data is collected and used today is profoundly different to how it was a decade ago. According to a report published in 2016 by IBM, “90 percent of the world’s data had been created in the last 12 months” and “many data analysts are suggesting the digital

universe will be 40 times bigger by 2020”.

 

Prior to GDPR, the ‘Data Protection Directive 95/46/EC’ attempted to harmonise the practices of EU member states in terms of their approach to data privacy. Directive 95/46/EC built on the ‘Guidelines on the Protection of Privacy and Transborder Flows of Personal Data’ first published in 1980, which was acknowledged by both the European Union and the United States, as a way to protect personal data and individuals’ privacy.

 

These guidelines still form the basis for the GDPR, but as they and Directive 95/46/EC were merely guidelines and directives, a more stringent and consistent approach was required to “protect the fundamental rights of individuals throughout future waves of innovation”.

 

The GDPR not only unifies the approach to data privacy across the EU, it also regulates it, meaning it is enforceable by law, and in turn carries penalties of up to 4% of annual turnover, or €20 million, whichever is the greater.

 

Pinch yourself all you like, this is happening affiliates, and failure to act now is nothing short of corporate suicide..!

Consent

The main way in which the GDPR aims to protect data subjects (individuals), is through consent. Data subjects must be made aware of the data being collected on them, why it is being collected, what will be done with it, and how long it will be retained for.

Personal Data

The most important thing for affiliates to realise is what Personal Data includes. It doesn’t stop at names, email addresses and phone numbers; it extends to social media posts, IP addresses, and even information stored in tracking cookies.

The GDPR defines it as..

any information relating to an identified or identifiable natural person

 

And importantly..

an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

 

The use of the words ‘directly or indirectly’ is important here. Just because a person’s name and address isn’t stored in a cookie, it doesn’t mean that the information in that cookie can’t be used to identify them. Cookies used by ad networks are able to track an individual from one site to the next, extremely well. In fact, they can potentially track a user across millions of websites.

 

Not only must you pay attention to any data you are collecting directly from individuals, such as name, phone number, email address; you must also think about what tracking codes and analytics software you have installed on your websites, which are used to build a ‘profile’ of someone, usually for advertising purposes.

 

Standard analytics code doesn’t track users across websites, so providing you don’t have any advertising features enabled in your Google Analytics (or other) code, then you won’t necessarily need to obtain consent before setting those cookies. Anything more will require clear and concise consent from your visitors though, ensuring the request for consent includes what, why, and how that data is being collected and used.

Informed Choice

The ‘Cookie Law’ introduced in 2011 (yes, it’s been 7 years!) targeted the usage of non-essential cookies i.e. those not entirely necessary for the basic functionality of a website. However, it didn’t offer users much control or choice.

 

The GDPR aims to change this in that users should be given a choice as to whether or not they agree to non-essential cookies being stored on their computer/browser. Now, accepting that cookies used by standard analytics software aren’t essential, and that they don’t contain ‘personal data’, then where does that leave us? Well, the answer lies in transparency. So long as you are clear in your ‘request for consent’ that the cookies used in your analytics software don’t collect identifiable data, nor are they shared across websites, then you should be fine. Otherwise, if they do (i.e. you have advertising features enabled), you must obtain consent from each and every visitor before setting those cookies.

Newsletter Subscriptions & Accounts

Similarly, if you have a newsletter subscription or account creation feature on your website, then you must obtain consent from users before you can collect their data. Common practice has usually been to present a “Send me occasional news by email” or “I agree to the website T&Cs” checkbox to users. This practice is now imperative, and furthermore, the declaration should be a request for consent, and should point to your Privacy Policy (it can’t be hidden in your T&Cs) which contains the full ‘request for consent’ in a clear and intelligible form, remembering to detail the what, why’s and how’s.

 

And whatever you do, don’t pre-tick the checkbox, or have any kind of “opt-out” option. Consent must be definitive, and unambiguous, and a timestamp of when that consent was obtained, and what the user was consenting to, must be recorded for audit purposes.

 

If your current privacy policy doesn’t satisfy the conditions of the GDPR, then you will need to obtain additional consent from your existing users or subscriber base.

 

In addition, “it must be as easy to withdraw consent as it is to give it”. Users must be offered an option to unsubscribe in all communications, or delete their account on your platform.

 

Think about what data you’re collecting, and whether you really need to. Obtaining consent to collect that data may present more risks than what it’s worth. Additionally, if you later decide to start collecting more data than is detailed in your original privacy policy (or the terms of your privacy policy change), then you will need to obtain additional consent to the updated privacy policy.

Affiliate Tracking Codes

Affiliate tracking cookies are fundamental to online gambling affiliates. Most affiliates are unlikely to want to offer users the ability to disable their tracking codes, and strictly speaking, as the cookies do not (shouldn’t) contain identifiable data that is shared between websites, then it might not be necessary.

 

However, affiliates should still be crystal clear about what cookies may be set as a result of clicking links on their site, why they’re being set, and how they’re being used.  It would also be prudent to offer advice about how users can block these kinds of cookies, for those who choose not to have them set.

Data Subject Rights

The GDPR also empowers individuals with control over their data, as well as outlines a number of responsibilities organisations must adhere to in order to fulfil individuals’ rights to access and control the data held on them.

 

Affiliates must be aware of their responsibilities, and put plans in place to be able to handle those responsibilities:-

Right to Access

Data subjects have the right to know what data is held on them, and how it is being used. They also have the right to request access to that data, which must be delivered to them with 1 month of the the request, in a standard electronic format, free of charge, such that they can transmit that data to another data controller (organisation) should they wish to (Data Portability).

Right To Be Forgotten

Data subjects will also have the right to be forgotten and have any data held on them deleted. Such data will include their personal information, as well as any data which could lead to them being identified, directly or indirectly. If you have implemented any tracking solutions which create a link between the data you hold, and data stored in third party software, then that link will also need to be deleted, and potentially the data stored in the third party software.

Privacy by Design & Security

The GDPR will enforce strict penalties on organisations that have failed to invest appropriate resources into securing their systems, and preventing access of data to unauthorised persons, both online and offline…

 

“The controller shall..implement appropriate technical and organisational measures..in an effective way..in order to meet the requirements of this Regulation and protect the rights of data subjects”.

 

Affiliates should ensure that any data they collect and process has been secured from the outset. If freelancers, designers or content writers have access to data unnecessarily, then it should be restricted. Similarly, any physical data should be locked safely away to prevent unauthorised access, and any new systems or website features should be designed with data privacy in mind.

 

Thought should also be given to data that can be encrypted – it may no longer be acceptable to only encrypt passwords.

Breach Notification

Organisations will be required to notify their appropriate Data Protection Authority within 72 hours of a data breach, where that breach is likely to “result in a risk for the rights and freedoms of individuals”. The gambling industry carries many negative connotations – most individuals probably wouldn’t want their identity associated with a gambling-related website, and so any data breach in this industry is likely to fall into the above category.

Data Protection Officers

Organisations who deal with large scale data processing or ‘special’ categories of data will be required to appoint a Data Protection Officer. Whilst this might not apply to most affiliates, they must understand their responsibilities as data controllers (and/or processors) to ensure the safety and security of data they hold, and ensure it isn’t shared or otherwise fall into the wrong hands. They should keep appropriate internal records, and ensure that their records are auditable.

 

This article contains general information for affiliates to make their own informed decisions about the upcoming GDPR. You must not rely on the information in this article as an alternative to professional legal advice.  The article has been contributed by Pavlos Sideris of Cashbacker – the leading gambling cashback community.

George Miller (Gyorgy Molnar) started his career in content marketing and has started working as an Editor/Content Manager for our company in 2016. George has acquired many experiences when it comes to interviews and newsworthy content becoming Head of Content in 2017. He is responsible for the news being shared on multiple websites that are part of the European Gaming Media Network.

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Affiliate Industry

Meet Traffic Puma. The New Affiliate Marketing on the block

George Miller

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Meet Traffic Puma. The New Affiliate Marketing on the block
Reading Time: 2 minutes

Traffic Puma is the newest name in affiliate marketing. You better watch out for this animal. Because it is born to prowl the affiliate marketing space and bring some new ideas to market.

 

Meet Traffic Puma.

One of the newest to enter the affiliate marketing space. A space which is pretty saturated as it is. But Traffic Puma is not a business idea made up in the basement office. Because the company is founded by three friends from the iGaming industry.

Together they have several decades in the business. Experience that could be of benefit, if one is able to find the right project.

Traffic Puma

And the first project for Traffic Puma Ltd is one that targets the UK.

In the UK the market for online sports betting and casinos is very high, so this will be a natural starting point. Also, because Traffic Puma has special knowledge in these areas.

To spearhead Traffic Puma’s campaign in the UK, they will use the newly developed site Wisegambler.com

And the communicational task at hand for CEO Ken Larsen at Traffic Puma will be to explain how “wise” merges with “gambling” in the first place.

The Wise Gambler

In our gaming universe we want to attract people like you and me, who like to play online games – for money – occasionally”, he explains. “The important thing is to keep your gambling under control. And we want to focus on that in all of our communication”.

The project was conceived, planned, and executed in full compliance with UK regulations, which changed recently.

Our core values include responsibility. And for us, it is on our part we need to see more responsibility. We will communicate this idea better.

Information is a key piece of the puzzle, as more and more users seek just that. Wisegambler.com appeals to responsible players who want to keep their playing under a little control.

And, at the same time, enjoying themselves.

Malta Location

Traffic Puma is located on the small island/country of Malta. And it seems fitting, not just because Malta is one of the best places to be if you’re in the gaming industry, but also because people in the business mix more here.

Traffic Puma was started by three colleagues and friends from “the business.”

And according to Larsen, one of Traffic Puma’s main weapons is exactly the collective experience of its founders.

It is Traffic Puma’s ability to consolidate tech and resources from already existing ventures that will be our main strength.

The company already has several affiliate sites in various foreign markets, such as Northern Europe, and South America. Wisegambler is going well, and the plan is to launch several other sites soon. Keep an eye out for this up-and-coming company from Malta, if you’re interested in lead marketing and affiliate marketing for the iGaming industry.

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Affiliate Industry

Raketech Appoints Annika Billberg to Board of Directors

George Miller

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Raketech Appoints Annika Billberg to Board of Directors
Reading Time: 2 minutes

Raketech, a leading online affiliate and content marketing company, today announced that Annika Billberg has been appointed as a new member of its Board of Directors. Annika Billberg has a solid background in communications and finance, and is currently Chief Brand & Communications Officer at Intrum, the undisputed market leader in credit management services.

Raketech is in a growth phase where the company over the past 12 months has strengthened both its executive management and board to secure continued high and sustainable growth, as well as a strengthened leadership in the European affiliate industry. The board was previously extended with Fredrik Svederman, with a background as CFO of Evolution Gaming, and Christian Lundberg, with experience from several leading operational positions at companies like Fortum and Microsoft.

Annika Billberg joining will further strengthen Raketech’s board profile. Billberg has served as Chief Brand & Communications Officer of Intrum since 2010, and has previously worked as Head of IR & Corporate Communications at the IT-services company HiQ in Stockholm and as Equity Research Analyst at Hagströmer & Qviberg in Stockholm.

Christian Lundberg, Raketech Chairman said:Over the last year, Raketech has undergone a substantial transformation journey, both in terms of staff and its way of working. We have doubled the number of employees to more than 100 people, acquired several leading assets, and rolled out a new operational model based on three clear growth pillars. To have the right expertise on the board is vital for our continued development, and both the board and management team welcome Annika to the company.

Annika Billberg added:Raketech is an exciting company with lots of opportunities ahead. I look forward to supporting the management team in the continued journey, with more acquisitions as well as new products and markets on the agenda. The company has also made solid progress in looking over its activities within sustainability and responsibility, where there is good potential to take the lead and push the entire industry in the right direction.

For more information, please contact: press@raketech.com.

About Raketech Group
Raketech is one of Europe’s leading online affiliate and content marketing companies with a passion for sports and gambling, based in Malta. Raketech was launched in 2010 with a purpose to guide users to the best possible services and deliver excellent results for our partners, with a vision to always be the first choice.

The long list of websites operated by the award-winning affiliate includes leading gaming websites in Sweden, Denmark, Finland and Norway. Successful brands include flagship casino website Casinoguide.se, specialist sports betting portals BetXpert.com and Betting.se, plus leading sports TV listing platform TVmatchen.nu.

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Affiliate Industry

Affiliate marketing on the rise in Latin America

Zoltan Tundik

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Top Smart Cities in Latin America - Photo credits: Cities Digest
Reading Time: 2 minutes

Contribution of Jimena Gamboa Baragaño

They are passionate, they are fanatic and they love gaming – this is Latin America in a nutshell.

Due to recent developments, the Latin American iGaming-market has received a growing interest of late. With Colombia becoming the first country to approve a regulated online-gaming market in 2016, the latest trends indicate that more countries will follow. Market leading games developer NetEnt recently signed a customer agreement with Caliente, Mexico’s largest online casino in their regulated market. This is yet another huge step towards more doors opening for both operators and affiliates alike.

Experts believe that it will not take long before more Latin American authorities  realize  the benefits of the added tax income and job opportunities that a regulated online gaming market will provide.

Thanks to great advancements in technology, Latin American gamers have quickly developed a huge interest for online gaming. The surge in the use of smartphones, especially among young people, means that online gaming operators now have a strong advantage over land-based casinos.

The Latin American region has a population of over 600 million people and online operators are constantly finding new ways to tap into this market. Some of Europe’s biggest operators have already made their presence known, especially in countries like Mexico, Colombia and even Brazil.

As the number of operators increase, affiliate marketers have more brands to advertise. The number of affiliate marketers around Latin America are still relatively few and this means that there’s plenty of room for new affiliates to stake their claim.

This is why Scandinavian affiliate network Matching Visions have their sights set on conquering Latin America in 2018. Mexican international Jimena Gamboa Baragaño, was recently added to the Matching Visions team and they are now preparing to travel  West and start building relationships with the Latin American affiliate crowd.

With so many countries being potentially just months away from regulation, this is the perfect time for affiliates to educate themselves in this market, Jimena adds. CEO and CO-founder Dennis Dyhr-Hansen, added that the timing couldn’t be better, especially with the upcoming football World Cup this summer.

Matching Visions Operations Manager, Andreas Lilja went on to say that trust is the key to any affiliate relationship, especially in the iGaming sphere. Hence, our initial aim will be to simply establish contact with affiliates and operators alike.

Lately, Matching Visions have been keeping busy with developing and running a Latin American affiliate site of their own, http://onlinecasinoguia.com/, aimed at educating players about the best brands in the region.

Will 2018 be the year where iGaming in Europe and Latin America come together? Only time will tell!

 

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