Affiliate Policy

1. Introduction

This Affiliate Policy (“Policy”) governs participation in the Affiliate Program operated by Sininelabs OÜ (“Company”, “we”, “our”, “us”), the operator of https://tideofsteel.com (“Platform”).

The purpose of the Affiliate Program is to reward approved affiliates for introducing new users to the Platform through lawful and transparent marketing activities.

This Policy establishes the eligibility requirements, onboarding procedures, marketing standards, commission structure, payment process, fraud prevention measures, compliance obligations, and other conditions applicable to all Affiliates participating in the Program.

Participation in the Affiliate Program constitutes acceptance of this Policy.

For affiliate-related inquiries, please get in touch with affiliate@tideofsteel.com

2. Definitions

For the purposes of this Policy:

Affiliate means an individual or legal entity approved by the Company to promote the Platform using a unique referral link.

Affiliate Account means the account assigned to an approved Affiliate.

Affiliate Program means the Company’s referral marketing program.

Qualified Player means a player satisfying all qualification requirements described in Section 8.

Referral Link means a unique tracking URL assigned to an Affiliate.

Commission means the compensation payable to an Affiliate for Qualified Players.

OCT (Original Credit Transaction) means the payment mechanism used exclusively for affiliate reward payouts.

Company means Sininelabs OÜ.

Platform means https://tideofsteel.com.

3. Purpose of the Affiliate Program

The Affiliate Program is intended to encourage lawful promotion of the Platform by independent marketing partners.

Affiliates promote the Platform using approved advertising materials, websites, applications, social media, blogs, communities, or other lawful marketing channels.

When a prospective user accesses the Platform through an Affiliate’s unique referral link, registers an account, and becomes a Qualified Player, the Affiliate may become eligible for compensation under the agreed commission model.

4. Affiliate Eligibility

Participation is available to:

• individuals aged 18 years or older;
• sole proprietors;
• companies;
• advertising agencies;
• affiliate networks;
• media buyers;
• website owners;
• application owners;
• freelance marketers;
• other marketing professionals approved by the Company.

Applicants must:

• provide complete and accurate information;
• complete Company verification procedures;
• comply with applicable laws;
• comply with this Policy;
• comply with all Company branding requirements.

Applicants located in countries or territories subject to the relevant sanctions, embargoes, or internal Company restrictions are not eligible.

The Company may approve or reject any application at its sole discretion without providing reasons.

The Company may periodically review Affiliate eligibility throughout the business relationship.

5. Affiliate Onboarding

To participate in the Program:

Step 1

The applicant submits a request to affiliate@tideofsteel.com

Step 2

The applicant completes the onboarding questionnaire and provides KYC documentation, including:

• Full legal name
• Contact information
• Government-issued identification (for example, passport)
• Most recent residential address confirmation

Step 3

The Company performs:

• KYC verification;
• Sanctions and PEP screening;
• country eligibility verification;
• compliance review.

Verification may take up to five (5) business days.

Step 4

Following approval, the Affiliate receives a unique Referral Link and marketing guidelines.

6. Referral Tracking

Each Affiliate receives a unique Referral Link.

A prospective user:

1. clicks the Referral Link;
2. is redirected to the Platform;
3. registers a player account and enters their e-mail address;
4. becomes associated with the referring Affiliate through the Company’s tracking system.

Referral attribution is determined solely by the Company’s internal tracking systems.

The Company’s records shall be final in determining referral ownership.

7. Marketing Rules

Affiliates shall promote the Platform only through lawful, honest, and transparent advertising practices.

All promotional materials created by an Affiliate require prior Company approval.

• The Affiliate shall prepare its own marketing materials, which must be submitted to and approved by the Company before publication or use.
• The Affiliate shall not use, modify, distribute, or publish any marketing materials that the Company has not approved. Any modifications to previously approved materials must also receive the Company’s prior written approval before being used.
• Marketing materials may be used solely for the purpose of promoting the Company’s products and services and performing the Affiliate’s obligations.
• The Affiliate shall ensure that all marketing materials are displayed accurately and appropriately and shall be solely responsible for any violations arising from their publication, placement, or use.
• The Company reserves the right, at any time and at its sole discretion, to require the Affiliate to amend, replace, suspend, or remove any marketing materials. The Affiliate shall comply with such request within the timeframe specified by the Company and, in any event, no later than forty-eight (48) hours after receipt of the Company’s notice.
• The Affiliate shall monitor the use of marketing materials, ensure compliance with this Policy and all applicable laws and regulations, and, upon the Company’s request, provide information regarding the placement, distribution, or use of such marketing materials.
• The Affiliate may promote the Company’s products and services only through marketing methods that comply with this Policy and all applicable laws and regulations.

Prohibited Activities

Affiliates shall not:

• Distribute unsolicited communications (“spam”) through any communication channel, including email, social media platforms, messaging applications, SMS, or any other electronic means.
• Use cookie stuffing or any other technology or practice that places referral or affiliate cookies on a user’s device without the user’s informed action or consent.
• Mislead or deceive users in any manner, including by impersonating the Company, creating the appearance of an official affiliation or endorsement, or imitating the Company’s websites, branding, communications, or representatives.
• Publish, distribute, or promote any content that is unlawful, fraudulent, defamatory, abusive, discriminatory, offensive, misleading, or otherwise inappropriate.
• Infringe or otherwise violate the intellectual property rights or other proprietary rights of any third party.
• Offer or provide any monetary or non-monetary incentive, reward, rebate, cashback, or other consideration in exchange for a user’s registration, installation, purchase, or completion of any other qualifying action, unless expressly authorized in writing by the Company.
• Sell, transfer, sublicense, exchange, or otherwise distribute promotional materials or marketing assets provided by the Company, unless expressly authorized in writing by the Company.
• Request, collect, store, or otherwise obtain users’ confidential or sensitive information, including login credentials, authentication information, payment card details, bank account information, or other financial data.
• Engage in self-referrals or any other fraudulent activity designed to generate commissions, including registering accounts, making purchases, or completing qualifying actions through the Affiliate’s own referral links or through accounts controlled by the Affiliate.

8. Qualified Player Criteria

The Affiliate Program operates under a CPA (Cost Per Acquisition) model.

A Qualified Player is a newly registered player who:

• registered through the Affiliate’s Referral Link;
• successfully created a player account;
• is not a duplicate account;
• is not fraudulent;
• is not self-referred;
• complies with the Platform Terms and Conditions;
• has not previously registered.

A User’s registration with the Game shall not qualify for commission or other compensation if the User accessed the registration page through any of the following means:

• Through search engines or paid search advertising platforms (including Google Ads, Yahoo! Search Marketing, Microsoft Advertising (formerly adCenter), or any similar services);
• Through automatic redirects or forced redirections without the User’s explicit action or consent;
• Through deceptive, misleading, or fraudulent advertising or promotional materials;
• Through the use of automatically generated page openings, search engine crawlers, bots, automated requests, unsolicited email or chat messages, script generators, links placed on websites other than the publisher’s website identified during the Affiliate’s registration, or any other similar methods, technologies, or technical means intended to artificially or improperly increase commissions or other payments;
• any method intended to manipulate commission calculations.

The Company has sole discretion to determine whether a player qualifies.

9. Commission Model

Commission structures are agreed individually with each Affiliate.

Compensation may depend on factors including:

• number of Qualified Players;
• quality of acquired traffic;
• geographic markets;
• marketing methods;
• historical Affiliate performance.

The Company reserves the right to modify commission structures upon prior notice.

No Commission becomes payable until verified by the Company.

10. Payment Policy

Affiliate rewards are paid only after successful verification of Qualified Players.

Minimum payout amount: EUR 5

Available payment methods may include:

• Visa
• Mastercard
• other payment methods supported by the Company.

Payments are generally processed within one (1) business day following approval.

The Company may delay payment where:

• verification is pending;
• fraud indicators exist;
• AML review is ongoing;
• sanctions screening is incomplete;
• additional documentation is required.

Payout Rules

• The Original Credit Transfer (OCT) shall be used exclusively to pay accrued Affiliate commissions.
• Payments shall be made only to duly registered Affiliates.
• Each payment must be supported by appropriate documentation evidencing the legal and contractual basis for the payment.
• Each payment must correspond to the commission calculation in accordance with the agreed commission structure with Affiliate.
• All payments shall be accurately recorded in the Company’s accounting and financial records.
• Payments processed through OCT shall not be used to issue refunds or reimbursements to Players.
• OCT shall not be used to make payments or transfers to third parties.

Affiliate Payout Flow

The payout process consists of the following stages:

1. Affiliate submits a payout request.
2. The Company verifies Qualified Players and commission entitlement.
3. The Company approves the payout.
4. Payment details are confirmed.
5. The payment provider performs AML, sanctions, fraud, and transaction monitoring checks.
6. The Company initiates an Original Credit Transaction (OCT).
7. Funds are transferred to the Affiliate.
8. Accounting records are updated.

Each payout:

• is supported by documented commission calculations;
• is recorded in the Company’s accounting records;
• is subject to compliance review where required.

11. AML and Sanctions Compliance

The Company maintains risk-based Anti-Money Laundering (AML) and sanctions compliance procedures.

Affiliate onboarding, verification, screening, and commission-payout controls are further described in the Affiliate Payout Compliance Policy published on the Platform. That policy applies to Affiliate payouts; player Card-sale and Company-buyback proceeds are governed separately by the Terms and Conditions and the User Compliance Policy.

The Company reserves the right to suspend payments pending completion of compliance checks.

12. Fraud Prevention

The Company actively monitors Affiliate activity for fraud and abuse.

Monitoring may include detection of:

• bot traffic;
• fake registrations;
• duplicate accounts;
• self-referrals;
• VPN abuse;
• proxy abuse;
• click fraud;
• cookie stuffing;
• incentive abuse;
• artificial traffic;
• attribution manipulation;
• identity fraud;
• payment abuse.

Where fraud or abuse is suspected, the Company may:

• suspend commissions;
• reverse unpaid commissions;
• suspend payouts;
• request additional documentation;
• terminate Affiliate participation;
• report suspicious activity to competent authorities where required by law.

13. Record Keeping

The Company generally maintains records for a minimum of five (5) years following the termination of the Affiliate relationship, or longer as required by applicable law.

14. Audit Rights

The Company may at any time:

• review traffic sources;
• request supporting marketing statistics;
• inspect advertising campaigns;
• review promotional materials;
• verify referral quality;
• audit commission calculations;
• suspend payouts pending completion of an audit.

Affiliates shall cooperate fully with any audit.

15. Confidentiality

All non-public information relating to the Affiliate Program is confidential.

Affiliates shall not disclose:

• commission rates;
• payment amounts;
• internal statistics;
• player information;
• business processes;
• commercial information;
• compliance procedures.

Confidentiality of affiliate information:

The Company shall treat all affiliate information, including but not limited to personal data, payment details, performance metrics, and other non-public information, as confidential and shall not disclose such information to any third party, except where disclosure is required by applicable law, a valid court order, or a lawful request from a competent governmental or regulatory authority.

Confidentiality obligations survive termination of participation in the Program.

16. Data Protection

The Company processes personal data in accordance with:

• the General Data Protection Regulation (EU) 2016/679 (GDPR);
• applicable Estonian data protection legislation.

Personal data shall be:

• processed lawfully;
• collected only where necessary;
• protected by appropriate technical and organizational measures;
• accessible only to authorized personnel;
• retained only for the period required by law or legitimate business purposes.

Further information is available in the Company’s Privacy Policy – https://tideofsteel.com/privacy.html.

17. Data Retention

The Company retains records relating to the Affiliate Program only for as long as necessary to fulfill contractual, legal, regulatory, accounting, tax, fraud prevention, and compliance obligations.

Where litigation, regulatory investigations, or legal proceedings are ongoing, relevant records may be retained until such matters have been fully resolved.

Upon expiration of the applicable retention period, records are securely deleted, anonymized, or destroyed in accordance with the Company’s data retention and information security procedures.

18. Intellectual Property

All trademarks, logos, graphics, software, promotional materials, and other intellectual property relating to the Platform remain the exclusive property of the Company.

Affiliates receive only a limited, non-exclusive, revocable license to use approved promotional materials solely for participation in the Affiliate Program.

19. Responsibilities

Affiliate Responsibilities

Affiliates shall:

• comply with all applicable laws;
• comply with this Policy;
• provide accurate information;
• maintain up-to-date contact information;
• use only approved advertising methods;
• cooperate during compliance reviews.

Company Responsibilities

The Company shall:

• maintain referral tracking systems;
• calculate commissions;
• process eligible payments;
• maintain accounting records;
• perform compliance reviews;
• safeguard Affiliate information.

20. Suspension and Termination

The Company may suspend or terminate participation where an Affiliate:

• commits fraud;
• breaches the present Policy;
• violates applicable law;
• becomes subject to sanctions;
• presents unacceptable AML risk;
• publishes false or misleading advertising;
• infringes intellectual property rights;
• damages the Company’s reputation.

Termination may occur immediately, where necessary, to protect the Company or to comply with legal obligations.

21. Limitation of Liability

The Company shall not be liable for indirect, incidental, consequential, or special damages arising from participation in the Affiliate Program.

The Company’s total liability shall not exceed the amount of unpaid approved commissions due to the Affiliate.

22. Force Majeure

The Company shall not be liable for delays or failures resulting from events beyond its reasonable control, including natural disasters, governmental actions, cyberattacks, telecommunications failures, labour disputes, or failures of payment systems.

23. Governing Law

This Policy shall be governed by and construed in accordance with the laws of the Republic of Estonia.

Any dispute arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of the competent courts of Estonia.

24. Review of this Policy

The Company may amend this Policy at any time to reflect:

• changes in applicable laws;
• payment system requirements;
• AML or sanctions obligations;
• operational changes;
• improvements to the Affiliate Program.

The latest version shall be published on the Platform’s website (https://tideofsteel.com) and shall become effective upon publication unless otherwise stated.

25. Contact Information

Sininelabs OÜ

Website: https://tideofsteel.com

Affiliate inquiries: affiliate@tideofsteel.com