Privacy Policy

PRIVACY POLICY

1. ABOUT THIS PRIVACY POLICY

This Privacy Policy applies where Tandem determines the purposes and means of processing Personal Data and therefore acts as a data controller under applicable data protection law. It covers Personal Data processed through or in connection with the Website, the Tandem Platform, campaigns, account management, business development, partner and advertiser relationships, customer and technical support, payments and compliance, recruitment, events, communications and other related business activities.

In certain circumstances, particularly in relation to campaign, tracking, attribution or conversion data processed on behalf of an Advertiser, Traffic Partner or other business customer, Tandem may act as a processor or service provider rather than as an independent controller. In those cases, processing may be governed by a separate data processing agreement, campaign terms, insertion order or other contractual arrangement, and the relevant business customer may be responsible for providing the applicable privacy notice to the individuals concerned.

This Privacy Policy should be read together with our Terms and Conditions and Cookie Policy, as updated from time to time.

2. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA

For the processing activities described in this Privacy Policy, Tandem is the data controller unless otherwise stated or unless Tandem processes Personal Data solely on documented instructions from another controller.

Tandem operates from Hungary and processes Personal Data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”), applicable Hungarian data protection legislation and other laws that apply to a particular processing activity.

Privacy and data protection requests may be submitted through the contact channels made available on https://www.tandem.pro/. Where required to verify identity or authority, we may request additional information before acting on a request.

3. DEFINITIONS

Advertiser: an operator, brand, agency, product owner or other business that acquires traffic, marketing services or related services through Tandem.

Affiliate / Traffic Partner: a publisher, affiliate, webmaster, media buyer, agency, influencer, streamer, network or other business or individual acting in a professional capacity that supplies or generates traffic or marketing services through Tandem.

Campaign: a marketing, advertising, traffic acquisition, lead generation, promotion or related activity managed, tracked, facilitated or supported by Tandem.

Cookie: a cookie or similar storage/tracking technology used on a device, as further described in our Cookie Policy.

Data Subject: an identified or identifiable natural person to whom Personal Data relates.

Personal Data: any information relating to an identified or identifiable natural person, including online identifiers where they can be linked to a person.

Platform: Tandem systems, dashboards, tracking infrastructure, account interfaces and related technology.

Processing: any operation performed on Personal Data, including collection, recording, organization, storage, use, disclosure, transfer, restriction or deletion.

Services: the advertising, affiliate, performance marketing, traffic acquisition, campaign management, technology, tracking, analytics, business development and related services provided or facilitated by Tandem.

Website: https://www.tandem.pro/ and pages or subdomains operated under the Tandem brand.

4. CATEGORIES OF PERSONAL DATA WE MAY COLLECT

4.1 Account and business contact data

name, surname and business role or job title;
company or trading name and professional affiliation;
business email address, telephone number, messenger handle and other contact details;
account username, account identifiers, settings and authentication information;
communications with Tandem account managers, support staff or other representatives;
records of meetings, negotiations, commercial approvals and campaign instructions.

4.2 Verification, compliance and payment data

identity and age verification information;
copies or details of identification documents where reasonably required for KYC/KYB, fraud prevention, sanctions or compliance checks;
company registration, ownership, authorized representative and beneficial ownership information;
address or residency information where required for verification;
bank account, payment wallet, payment method and invoice details;
tax identification or tax-related information where required by law or for invoicing;
transaction history, account balance, payout status and reconciliation records;
sanctions, politically exposed person, fraud-risk or other compliance screening results from lawful sources.

4.3 Website, device and technical data

IP address and approximate location derived from IP;
browser type, operating system, device type, language and time zone;
device, session, cookie and similar online identifiers;
pages viewed, referral URL, date and time of access, clicks and navigation activity;
security logs, authentication logs, diagnostic and error information;
consent preferences and cookie settings.

4.4 Campaign, traffic and attribution data

campaign, offer, source, sub-source, placement, creative and tracking identifiers;
click, impression, conversion, registration, lead, deposit or other event data, depending on the Campaign;
pseudonymous user, session, device or transaction identifiers supplied by Advertisers, Traffic Partners or tracking providers;
country, region, device, browser and other technical attributes used for attribution, anti-fraud or Campaign optimization;
conversion validation, rejection, chargeback, fraud and quality-control information;
aggregated statistics and campaign performance information.

We do not require Traffic Partners to provide Tandem with directly identifying player or end-user information unless such processing is specifically necessary, lawful and contractually authorized. Where campaign data can identify or reasonably be linked to an individual, we treat it as Personal Data.

4.5 Marketing and business development data

professional contact details;
company, market, traffic source, commercial interests and business requirements;
history of interactions with Tandem;
event attendance, conference meetings and networking information;
marketing preferences and records of consent, objection or unsubscribe requests.

4.6 Recruitment data

CV/resume and application information;
employment history, education, skills, language ability and professional qualifications;
contact details and links to professional profiles voluntarily provided by the candidate;
interview notes, assessments and recruitment correspondence;
salary expectations, availability and work authorization information where relevant.

4.7 Information you choose to provide

We may process additional information that you voluntarily provide when contacting us, submitting a form, participating in a survey, requesting support, attending an event or otherwise interacting with Tandem. Please avoid sending sensitive or special-category Personal Data unless it is genuinely necessary and lawful to do so.

5. SOURCES OF PERSONAL DATA

We may obtain Personal Data from the following sources:

directly from you;
your employer, company, agency, representative or colleagues;
Advertisers, Affiliates, Traffic Partners and other business counterparties;
tracking, analytics, hosting, security, fraud-detection, payment and compliance service providers;
publicly available professional sources, company websites, conference materials and business directories;
professional networking platforms and business databases where use of such data is permitted by applicable law;
referrals and introductions from business contacts;
our Website, Platform and communications systems through automated technical collection.

Where we obtain your Personal Data from a source other than you, we will provide information required by applicable law within the applicable timeframe unless an exemption applies.

6. PURPOSES AND LEGAL BASES FOR PROCESSING

Depending on the circumstances, Tandem relies on one or more of the legal bases permitted by applicable law. The principal purposes and legal bases are set out below.

Purpose	Examples of processing	Typical legal basis
Provide accounts, Platform access and Services	registration, authentication, account administration, support, campaign access	Performance of a contract / steps requested before entering a contract; legitimate interests
Manage partner and advertiser relationships	communications, negotiations, campaign approvals, account management, relationship history	Performance of a contract; legitimate interests in operating and developing our business
Campaign tracking and attribution	click and conversion tracking, validation, reconciliation, reporting	Performance of a contract; legitimate interests in measuring, preventing fraud and administering campaigns; consent where legally required for device storage/access
Payments and accounting	payouts, invoices, reconciliation, financial records	Performance of a contract; legal obligation; legitimate interests
KYC/KYB, AML, sanctions and fraud prevention	identity verification, ownership checks, sanctions screening, traffic-quality review, security investigations	Legal obligation where applicable; legitimate interests in preventing fraud and protecting the business
Website operation and security	logs, diagnostics, access control, cyber-security and abuse prevention	Legitimate interests; legal obligation where applicable
Analytics and improvement	service analytics, product improvement, aggregated performance analysis	Legitimate interests; consent where required for non-essential cookies or similar technologies
Business development and B2B communications	contacting existing or prospective professional partners, managing leads and opportunities	Legitimate interests, where permitted; consent where required by law
Marketing communications	news, updates, event invitations, service information and relevant offers	Consent where required; otherwise legitimate interests where permitted
Recruitment	reviewing applications, interviews, candidate communications and hiring decisions	Steps requested before entering a contract; legitimate interests; legal obligation where applicable
Legal claims and compliance	record keeping, responding to regulators, enforcing agreements, investigating disputes	Legal obligation; legitimate interests in establishing, exercising or defending legal claims

6.1 Legitimate interests

Where we rely on legitimate interests, we consider whether the processing is necessary for a legitimate business purpose and balance those interests against the rights and freedoms of affected individuals. Our legitimate interests may include operating and securing Tandem, preventing fraud, managing commercial relationships, measuring campaign performance, improving Services, maintaining business records, communicating with professional contacts and protecting or enforcing legal rights.

6.2 Consent

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Certain non-essential cookies or similar technologies may only be used after the consent required by applicable law has been obtained.

6.3 Contract and legal obligations

Certain Personal Data is necessary to create or administer an account, enter into or perform a commercial relationship, process payments, verify counterparties or satisfy legal requirements. If required information is not provided, Tandem may be unable to provide some or all Services, process a payment or continue the relevant business relationship.

7. BUSINESS-TO-BUSINESS COMMUNICATIONS AND DIRECT MARKETING

Tandem may use professional contact information to communicate with existing or prospective business partners, Advertisers, Affiliates, Traffic Partners, suppliers and other relevant professional contacts. Such communications may relate to Tandem Services, Campaigns, partnership opportunities, industry events or other matters reasonably relevant to the recipient’s professional role.

Where consent is required by applicable electronic marketing or communications law, Tandem will seek consent before sending the relevant communication. Where legitimate interests may lawfully be relied upon, Tandem may send proportionate B2B communications subject to the recipient’s right to object.

You may opt out of direct marketing at any time by using an unsubscribe mechanism where available or by contacting Tandem through the contact channels on the Website. An objection to marketing will not prevent us from sending non-marketing communications that are necessary to administer an existing account, Campaign, transaction or legal relationship.

8. COOKIES AND SIMILAR TECHNOLOGIES

The Website and Platform may use cookies, pixels, local storage, SDKs, tags and similar technologies for functions such as authentication, security, preference management, analytics, attribution and service improvement. Where required by applicable law, non-essential technologies will be used only after appropriate consent.

Further information about the types of technologies used, their purposes, providers, duration and available controls is provided in our Cookie Policy. Cookie preferences may also be managed through any consent-management tool made available on the Website.

9. TRACKING, ATTRIBUTION AND PROFILING

Tandem may process technical, campaign and conversion data to attribute events to traffic sources, measure Campaign performance, detect anomalies and fraud, apply Campaign rules, produce reporting and optimize Services. This may involve automated correlation of pseudonymous identifiers, device attributes, timestamps and Campaign parameters.

Tandem may also use rule-based or statistical risk indicators to identify potentially invalid, fraudulent or non-compliant traffic. Such processing may affect whether a conversion is flagged for review, but Tandem does not intend to make solely automated decisions producing legal effects or similarly significant effects on individuals unless permitted by applicable law and accompanied by required safeguards.

Where a specific processing activity constitutes profiling or automated decision-making subject to additional legal requirements, Tandem will provide any further information and safeguards required by applicable law.

10. SHARING OF PERSONAL DATA

We may disclose Personal Data where reasonably necessary to the following categories of recipients:

Advertisers, Affiliates, Traffic Partners and other Campaign counterparties, to the extent necessary to operate, attribute, validate, reconcile or investigate Campaigns;
hosting, cloud, analytics, communication, CRM, customer support, tracking, anti-fraud, cyber-security and technology providers;
payment processors, banks, accountants, auditors, tax advisers and financial service providers;
identity verification, KYC/KYB, AML and sanctions-screening providers;
professional advisers, including lawyers and consultants;
regulators, supervisory authorities, courts, law-enforcement bodies and public authorities where disclosure is legally required or reasonably necessary to protect legal rights;
potential acquirers, investors, lenders or successors in connection with a merger, financing, reorganization, sale of assets or similar corporate transaction, subject to appropriate confidentiality and data-protection safeguards.

Tandem does not sell Personal Data in the ordinary meaning of selling personal information for monetary consideration. We do not disclose Personal Data to unrelated third parties for their independent consumer marketing purposes without a lawful basis.

11. PROCESSORS AND CONTRACTUAL SAFEGUARDS

Where a service provider processes Personal Data on our behalf, we seek to use providers offering appropriate technical and organizational measures and, where required by law, enter into data-processing terms governing confidentiality, security, permitted processing and assistance with data-protection obligations.

Some providers may independently determine certain purposes and means of processing and therefore act as separate controllers. In those circumstances, their own privacy terms may also apply.

12. INTERNATIONAL DATA TRANSFERS

Tandem operates internationally and may process or transfer Personal Data in countries outside Hungary or the European Economic Area (EEA), including where Advertisers, Traffic Partners, technology providers, payment providers or other recipients are located abroad.

Where the GDPR requires a transfer mechanism for Personal Data transferred outside the EEA, Tandem will use an appropriate legal safeguard, which may include an adequacy decision of the European Commission, approved standard contractual clauses, participation in an applicable recognized transfer framework, or another lawful mechanism. Where required, Tandem will assess supplementary technical, contractual or organizational measures appropriate to the transfer risk.

Information about applicable transfer safeguards may be requested through the privacy contact channels made available on the Website, subject to confidentiality and security restrictions.

13. DATA RETENTION

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including to provide Services, administer commercial relationships, meet legal, accounting and tax obligations, prevent fraud, resolve disputes and establish, exercise or defend legal claims.

Retention periods depend on the category of data and context. In general:

account and business relationship records may be retained for the duration of the relationship and for an appropriate limitation or record-keeping period afterwards;
contracts, invoices, payment, tax and accounting records are retained for the period required by applicable Hungarian or other applicable law;
KYC/KYB, fraud-prevention and compliance records may be retained for the period necessary to satisfy legal obligations and protect against fraud or disputes;
support and business communications may be retained while relevant to the relationship and for a reasonable period afterwards;
marketing contact data is retained until consent is withdrawn, an objection is made, the purpose ceases to apply or another applicable retention limit is reached;
recruitment information for unsuccessful candidates is retained only for a reasonable period after completion of the recruitment process, unless a longer retention period is consented to or justified by law;
technical logs and analytics data are generally retained for shorter operational periods unless needed for security, fraud investigation or legal claims.

When Personal Data is no longer required, we will delete it, anonymize it or otherwise place it beyond use, subject to lawful backup and archival practices.

14. DATA SECURITY

Tandem uses technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, access or other unlawful processing. Depending on the nature and risk of the processing, measures may include access controls, authentication, encryption in transit, logging, monitoring, role-based permissions, vendor controls, backups, security testing and internal procedures.

No method of transmission or storage can guarantee absolute security. You are responsible for maintaining the confidentiality of account credentials and for notifying Tandem promptly if you suspect unauthorized access to your account or communications.

15. PERSONAL DATA BREACHES

Tandem maintains procedures for identifying, assessing and responding to suspected Personal Data breaches. Where a breach triggers notification obligations under applicable law, Tandem will notify the competent supervisory authority and/or affected Data Subjects within the legally required timeframe, as applicable.

16. YOUR DATA PROTECTION RIGHTS

Subject to the conditions and exceptions provided by applicable law, you may have the following rights in relation to your Personal Data:

Right of access – to obtain confirmation whether we process your Personal Data and receive a copy and related information;
Right to rectification – to correct inaccurate Personal Data and complete incomplete information;
Right to erasure – to request deletion in circumstances provided by law;
Right to restriction – to request restriction of processing in specified circumstances;
Right to data portability – to receive certain Personal Data in a structured, commonly used and machine-readable format and, where technically feasible, transmit it to another controller;
Right to object – including the right to object at any time to processing for direct marketing and, in certain circumstances, processing based on legitimate interests;
Right to withdraw consent – where processing is based on consent;
Right to lodge a complaint – with a competent data protection supervisory authority.

Requests may be submitted through the contact channels made available on https://www.tandem.pro/. We may need to verify your identity and authority before fulfilling a request. We normally respond within the timeframe required by applicable law. Under the GDPR, this is generally one month, subject to permitted extensions for complex or numerous requests.

Rights are not absolute. For example, we may retain information where processing is necessary to comply with a legal obligation, establish or defend legal claims, prevent fraud or satisfy another lawful basis for continued processing.

17. SUPERVISORY AUTHORITY

Because Tandem operates from Hungary, the Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvedelmi es Informacioszabadsag Hatosag, “NAIH”) may be a competent supervisory authority for relevant processing activities. Data Subjects may also have the right to complain to another competent supervisory authority, particularly in the EU Member State of their habitual residence, place of work or place of the alleged infringement.

Current information about NAIH and its complaint procedures is available through the Authority’s official website.

18. CHILDREN AND AGE-RESTRICTED SERVICES

Tandem Services are designed for business and professional users and are not directed to children. We do not knowingly create business accounts for persons under 18 years of age.

Tandem may provide marketing services to businesses operating age-restricted products, including iGaming products. Tandem does not intend to collect Personal Data directly from minors for such marketing purposes. Traffic Partners and Advertisers are responsible for complying with applicable age-gating, advertising, targeting and responsible-gambling requirements relevant to their own processing and Campaign activities.

If we become aware that we have collected Personal Data from a child without a valid legal basis, we will take reasonable steps to delete or otherwise lawfully address the data.

19. SPECIAL CATEGORIES OF DATA

Tandem does not ordinarily seek to collect special categories of Personal Data, such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data used for unique identification, health data or information concerning a person’s sex life or sexual orientation.

Please do not provide such information unless it is genuinely necessary for a specific lawful purpose. If special-category data is processed, Tandem will rely on an applicable legal condition and implement safeguards required by law.

20. THIRD-PARTY WEBSITES AND SERVICES

The Website, Platform or communications may contain links to third-party websites, Advertiser products, social networks, payment services or other external services. Tandem is not responsible for the independent privacy practices of third parties. You should review the privacy notices of those third parties before providing Personal Data to them.

21. DATA RELATING TO END USERS AND PLAYERS

Tandem primarily operates on a B2B basis. Depending on a Campaign, Tandem may receive limited technical or pseudonymous information relating to end users or players for attribution, reporting, fraud prevention and reconciliation. Tandem seeks to minimize such data and does not require directly identifying player information where it is not necessary.

Advertisers and Traffic Partners are independently responsible for ensuring that any Personal Data they disclose to Tandem has been collected and shared lawfully, that required privacy notices have been provided, and that any consent or other legal basis required for tracking, advertising or data sharing has been obtained. Contractual data-protection terms may impose additional obligations.

Where Tandem receives an individual rights request relating primarily to Personal Data controlled by an Advertiser or other business customer, Tandem may direct the requester to the relevant controller or assist that controller as required by applicable law and contract.

22. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our Services, processing activities, legal requirements or business practices. The current version will be published on the Website and the “Last modified” date will be updated.

Where changes materially affect the way we process Personal Data or where applicable law requires additional notice or consent, we will take reasonable steps to provide such notice or obtain consent as required.

23. CONTACTING TANDEM ABOUT PRIVACY

Questions, requests or concerns concerning this Privacy Policy or the processing of Personal Data may be submitted using the contact channels made available on https://www.tandem.pro/. Please include sufficient information for us to identify the relevant relationship or account and understand the nature of the request, but do not send unnecessary identity documents or sensitive information unless requested through an appropriate secure channel.

24. RELATIONSHIP WITH OTHER TERMS

This Privacy Policy governs the processing of Personal Data by Tandem in its capacity as controller. Commercial matters, including Campaign rules, payments, invalid traffic, account suspension and other contractual matters, are governed by the Tandem Terms and Conditions and any applicable Campaign Terms or separate agreements. The Cookie Policy provides additional information about cookies and similar technologies.