> For the complete documentation index, see [llms.txt](https://docs.triumpharcade.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.triumpharcade.com/privacy-policy-triumph-affiliates.md). # Privacy Policy: "Triumph Affiliates" Effective Date: July 21, 2026 | Last Updated: July 21, 2026 ## 1. Introduction and Scope Triumph Labs, Inc. and its affiliates (including, without limitation, Triumph Arcade LLC and Triumph TCG, LLC) (collectively, the “Company,” “we,” “us,” or “our”) take your privacy seriously. This Affiliate Program Privacy Notice (this “Notice”) describes how we collect, use, disclose, and retain personal information about participants and applicants in the Triumph Affiliate Program (the “Program”), including information collected through our Program enrollment forms, Program communications and dashboards, and tax and payment onboarding processes. This Notice supplements, and does not replace, the privacy policies applicable to your use of Company applications and websites as a consumer or vendor, such as the Triumph Partners Suite Privacy Policy; where you use those products, those policies apply to that use. This Notice does not apply to information collected by third parties, including the social media platforms on which you publish content; those parties have their own privacy policies, which we encourage you to read. By applying to or participating in the Program, you acknowledge this Notice and agree that we may collect, use, and disclose your information as described in it, consistent with applicable law. ## 2. Information We Collect We collect the following categories of information in connection with the Program: * Identity and contact information. Your legal name, date of birth (used to verify that you are at least 18 years of age), electronic signature, mailing address, email address, and telephone number, and, if you participate on behalf of an entity, the entity’s legal name, address, and authorized representative information. * Channel and promotional information. The social media accounts, handles, websites, and other channels you identify or use to promote the Program; publicly available information about those channels (such as follower counts and audience metrics); and the content you publish that promotes or references the Company. * Tax information. IRS Form W-9 and related tax documentation, including your Social Security Number or Employer Identification Number, tax classification, and certification information. We do not collect tax information at enrollment; it is requested only when a payment becomes due to you, as described in the Affiliate Program Terms and Conditions. * Payment information. Bank account and routing information or other payment account details needed to pay you by wire, ACH, or other methods; invoices we prepare on your behalf and your approvals or disputes of them; and records of payments and credits made to you. * Program performance information. Referral link and promotional code activity, click, install, registration, and transaction attribution data, commission calculations, and compliance review records relating to your participation. * Communications. Correspondence between you and the Company, including emails, support requests, and messages through Program tools. * Technical information. When you interact with our enrollment forms, dashboards, or websites, we may automatically collect your IP address, approximate location derived from your IP address, device and browser information, and the date and time of access, including as part of the audit trail associated with your electronic signature. Our websites use cookies as described in our Cookie Policy. We collect this information directly from you (for example, when you complete the enrollment form or submit tax or payment information), automatically when you interact with our forms and systems, from the platforms and channels on which you publish (including publicly available information), and from service providers that support the Program, such as form, e-signature, tracking, and payment providers. ## 3. How We Use Your Information We use the information described above to: * evaluate Program applications and verify your identity, age, and eligibility; * administer the Program, including providing referral tools, tracking and attributing referred activity, calculating commissions, and communicating with you about the Program; * pay you, including processing wires, ACH transfers, and app credits, and maintaining payment records; * satisfy tax and financial obligations, including collecting Form W-9, preparing and filing information returns (such as IRS Form 1099), and performing any required withholding; * monitor and enforce compliance with the Affiliate Program Terms and Conditions and applicable law, including FTC endorsement and disclosure requirements, and investigate and prevent fraud, tracking manipulation, and other misuse of the Program; * establish, exercise, and defend legal claims, and comply with court orders, laws, and legal processes, including responding to government and regulatory requests; and * maintain compliance, financial, tax, and other legally required records, and operate, analyze, and improve the Program. ## 4. How We Disclose Your Information We may disclose aggregated or de-identified information that does not identify any individual without restriction. We may disclose personal information: * to contractors and service providers that support the Program (including form and e-signature providers, tracking and analytics providers, payment processors and banks, tax preparation and filing providers, and compliance and fraud-prevention provider) who are bound by contractual obligations to keep personal information confidential and to use it only for the purposes for which it is disclosed to them; * within our corporate family (Triumph Labs, Inc. and its affiliates and subsidiaries) for the purposes described in this Notice; * to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets; * to comply with any court order, law, or legal process, including to respond to any government or regulatory request (for example, reporting payment information to the IRS); * to enforce our rights arising from any contracts entered into between you and us, including the Affiliate Program Terms and Conditions; * if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our users, or others, including exchanging information with other companies and organizations for fraud protection; and * for any other purpose disclosed to you when you provide the information, or with your consent. The Company does not sell personal information collected in connection with the Program, and does not share such information with third parties for cross-context behavioral advertising or for third-party marketing purposes. Mobile information and SMS opt-in consent will not be shared with third parties or affiliates for marketing or promotional purposes. If our practices change, we will update this Notice and provide any legally required notices and opt-out mechanisms before doing so. ## 5. Data Retention We retain personal information for as long as needed for the purposes described in this Notice, and thereafter as required or permitted by law. Because Program information is associated with financial transactions, tax reporting, and business security practices, the following information will be retained for a period of seven (7) years from the last payment or your deletion request, whichever is later: full name, date of birth, taxpayer identification information, tax forms and information returns, payment and invoice records, transaction and commission history, and related compliance records. Information related to participants terminated for fraud or material breach may be retained for business security purposes, including full name, date of birth, contact information, channel identifiers, and IP address. ## 6. Your Rights and Choices Subject to the limitations and exceptions in applicable law (including exceptions for information we must retain for tax, financial, anti-fraud, and legal compliance purposes) you have the following rights with respect to your personal information: * Right to confirm whether we are processing your personal information and to know the categories collected and used; * Right to access the personal information we have collected from you (no more than once per year unless otherwise required by law), delivered in a portable format such as CSV, TXT, or PDF; * Right to correct errors in the personal information we store; * Right to delete your personal information, subject to the retention requirements described in Section 5 and other legal exceptions; following a verified deletion request we will delete or de-identify information not subject to an exception; * Right to opt out of marketing communications, by following the opt-out instructions in such communications; and * Rights to opt out of the sale of personal information, the sharing of personal information for cross-context behavioral advertising, and targeted advertising. However, we do not currently engage in any of these practices. To exercise your rights, contact us at . We will verify your identity before acting on a request, which may include verification against the information in your Program enrollment. Residents of certain states (such as California) and certain other jurisdictions may have additional rights; please see our California Privacy Policy and Notices for more information. We will not discriminate against you for exercising your privacy rights. ## 7. Data Security We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Tax and payment information is handled through access-controlled processes limited to personnel and service providers who need it to pay you and meet our legal obligations. Please submit tax documents (such as your Form W-9) and payment details only through the channels we designate for that purpose, and do not include your Social Security Number in ordinary email correspondence unless we direct you to a designated secure channel. The transmission of information via the internet is not completely secure; any transmission of personal information is at your own risk, and we are not responsible for circumvention of any privacy settings or security measures we provide. ## 8. Age Requirement The Program is open only to individuals who are at least eighteen (18) years of age. We collect date of birth at enrollment to verify this requirement. We do not knowingly collect personal information from anyone under 18 in connection with the Program; if we learn that we have done so, we will delete that information and terminate the associated enrollment. If you believe a person under 18 has enrolled in the Program, please contact us at . ## 9. Changes to This Notice We may update this Notice from time to time. If we make material changes to how we treat personal information collected in connection with the Program, we will post the updated Notice and notify you by email or through the Program dashboard. The date this Notice was last revised is identified at the top of this page. Your continued participation in the Program after we revise this Notice means you accept those changes. ## 10. Contact Information To ask questions or comment about this Notice and our privacy practices, or to register a complaint or concern, contact us at , or by mail at: Triumph Labs, Inc., ATTN: Legal/Business Affairs, 1265 Battery Street, 4th Floor, San Francisco, CA 94111. ## 11. Governing Law and Dispute Resolution This Notice arises under the Affiliate Program Terms and Conditions, and any dispute between you and the Company related to this Notice shall be governed by the dispute resolution provisions contained in the Affiliate Program Terms and Conditions, including the arbitration provisions therein, except to the extent an alternative choice of law is required under applicable law.