Privacy Policy

GamifyTech Ltd.

Effective Date: December 2^nd 2025

At Smartico.ai ("Website"), operated by GamifyTech Ltd. ("we," "us," or "our"), your privacy is a priority. This Privacy Policy explains how we collect, use, and protect your personal data, ensuring compliance with the General Data Protection Regulation (GDPR).

1. Data Controller Information

GamifyTech Ltd. is the Data Controller of the personal data collected through this Website. https://www.theaffiliateplatform.com/

Company Name: GamifyTech Ltd.

Email: privacy@gamifytech.com

Registered Address: Republic of Bulgaria, Sofia city, Building 5B, g.k. Mladost 4, ul. "Business Park Sofia" Floor 6, 1715 Sofia.

2. On what basis do we collect your personal data?

We use your data to provide and improve the Website. By using the Website, you agree to the collection and use of information in accordance with this policy and our Cookie Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://https://www.theaffiliateplatform.com/legal/terms-and-conditions.

3. Purpose and Legal Basis for Processing

If you are from the European Union (EU) and/or European Economic Area (EEA), GamifyTech Ltd. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We process your data legally based on:

i) Consent (Article 6(1)(a))

For non-essential cookies, analytics, and marketing activities.

ii) Legitimate Interests (Article 6(1)(f))

For ensuring Website functionality, maintaining security, and improving services.

iii) Legal Obligation (Article 6(1)(c))

For complying with regulatory and legal requirements.

4. Definitions

“Website” is the https://www.theaffiliateplatform.com website operated by GamifyTech Ltd.

“Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

“Data Subject” (or User) is any living individual who is using our Service and is the subject of Personal Data.

“Cookies” are small files stored on your device (computer or mobile device).

“Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

“Tracking Technologies” are technologies used to collect information about users and their activities on a website. Examples of tracking technologies include cookies, web beacons, and embedded scripts.

“Usage Data” is data collected automatically either generated by the use of the Website or from the Service infrastructure itself (for example, the duration of a page visit).

5. Types of Personal Data We Collect

a) Data You Provide Directly

Name, email address, phone number and any information submitted through contact forms, account registrations, or communications with us.

b) Data Collected Automatically

When you visit our website https://www.theaffiliateplatform.com, we use cookies and similar technologies (further described in our Cookies Policy) to collect:

i) IP address (anonymized where applicable).

ii) Browser type and version.

iii) Device information.

iv) Geographic location (general, based on anonymized IP).

v) Pages viewed, time spent, and interactions on the Website.

6. What rights do you have?

If you are a resident of the EEA or the UK, you may exercise certain data protection rights in accordance with the EU, respectively the UK GDPR. We aim to take reasonable steps to facilitate you in the exercise of these rights by allow you to correct, amend, delete or limit the use of your Personal Data.

Under GDPR, you have the following rights:

6.1. Right to access, update or delete the information we have on you.

Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. When you withdraw your consent for the processing of your personal data and there is no other legal basis for the processing; when you object to processing based on legitimate interest and that interest does not override your rights, freedoms, and interests; when the processing is unlawful; or when the erasure of your personal data is our legal obligation under the law of the EU.

You have the right to access and may request more detailed information about whether we process your personal data, what categories of data, for what purposes, to whom it is disclosed, and more. If you wish, we will provide you access to your personal data that is being processed, in the form of a copy. The copy is free of charge. If you request additional copies, individually formatted or more detailed information, or exercise your rights disproportionately (abusing them), we may charge you a reasonable fee to cover our administrative costs for preparing them. If we do not process your personal data, we will inform you of this. If we refuse your request for a copy of the data, we will explain the reasons for our decision.

Exercising your right of access should not adversely affect the rights or freedoms of other individuals, including trade secrets or intellectual property, and in particular copyright protecting software. If we determine that there is a basis to expect such adverse impact, we may justifiably limit the portion of information provided to you to prevent it.

6.2. Right to Rectification

You have the right to have your information rectified if that information is inaccurate or incomplete. When you want us to rectify your personal data, you may request that we also notify the third parties to whom the data has been disclosed, except in cases where this is impossible or involves disproportionate effort.

6.3. Right to Erasure ("Right to be Forgotten")

You have the right to have your information erased if that information is no longer necessary for the purpose GamifyTech originally collected, or we don’t have legitimate interest to continue processing your personal information.

6.4. Right to Restrict Processing

You have the right to request that we restrict the processing of your personal information. To exercise the right to restriction of processing, the following conditions must be met:

You contest the accuracy of the personal data;

The processing is unlawful, but instead of erasing the data, you request the restriction of its use;

We no longer need the personal data for the purposes of processing, but you require them for the establishment, exercise, or defense of legal claims;

You have objected to the processing based on “legitimate interest”.

6.5. Right to Data Portability

Receive your data in a portable format or request its transfer to another controller.

You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. The right to data portability exists and can be exercised only when the following two conditions are met: (1) the processing is carried out in an automated manner (i.e., this right does not apply to the processing of data in paper form), and (2) in addition to being automated, the processing of your personal data is based on (a) your consent or (b) a contract to which you are a party, or for taking steps at your request prior to entering into a contract. You have the right to request the direct transfer of your personal data to another controller, where technically feasible.

You should be aware that when you exercise the right to data portability, your personal data is not deleted from our systems.

6.6. Right to Object

You have the right to object to our processing of your Personal Data.

Object to processing based on legitimate interests or for marketing purposes.

6.7. Right to Withdraw Consent

You also have the right to withdraw your consent at any time where GamifyTech Ltd. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

Withdraw consent for non-essential processing activities at any time.

To exercise these rights, please contact us at privacy@gamifytech.com.

7. Data Sharing and Third Parties

We may share your data with:

Service Providers: For analytics, marketing, and operational support (e.g., Google Analytics, Microsoft Clarity).

Legal Authorities: To comply with legal obligations.

Third-party providers are contractually obligated to process your data in compliance with GDPR.

Further details on our Cookies Policy may be found on our website in the said document.

8. Data Transfers

If your data is transferred outside the EEA, we ensure appropriate safeguards, such as standard contractual clauses or adequacy decisions, are in place.

The information processed in Bulgaria is subject to oversight by the Commission for Personal Data Protection (CPDP), which aims to safeguard your rights in relation to its processing. In case of any suspicion of misuse in the processing of your personal data, you can contact the Commission, with a link to its website: https://cpdp.bg/, or through address Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2, email: kzld@cpdp.bg, contact phone: 02/91-53-519, 02/91-53-555.

GamifyTech Ltd. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

9. Data Retention

GamifyTech Ltd. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations - for example, if we are required to retain your data to comply with applicable Bulgarian or EU laws such as conducting contract with you, resolve disputes and enforce our legal agreements and policies.

GamifyTech will retain your Personal Data (identity data) when conducting contracts with you for 5+1 years after contract termination.

Be aware of retaining your location data (country, region) and demographic data (date of birth/age) will last 5 years after your last interaction with our Website, or until you withdraw your consent.

10. Data Security

We implement robust measures to protect your data, including:

i) Encryption.

ii) Access controls.

iii) Regular security audits.

11. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in practices or legal requirements. The updated policy will be posted on this page with the revised "Effective Date."

12. Contact Information

For questions, concerns, or to exercise your rights, contact us at: