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Last updated: 28 August 2026
This Affiliate Program Privacy Notice explains how Tensoris Technology Limited ("Tensoris", "LusyChat", "we", "us", or "our") collects, uses, shares, and protects personal data in connection with the LusyChat Affiliate Program, including affiliate applications, the affiliate portal, tracking links, conversion reporting, commission review, and payouts (collectively, the "Affiliate Program").
This notice applies to individual affiliates, affiliate applicants, and representatives or personnel of corporate affiliates. It supplements the general LusyChat Privacy Policy. Referred visitors and LusyChat customers should also read the general LusyChat Privacy Policy and the cookie information presented on the relevant LusyChat landing page. If this notice and the general LusyChat Privacy Policy address the same Affiliate Program processing activity, this notice takes precedence for that activity.
Reading or acknowledging this notice does not constitute consent to optional marketing. Where consent is required, it will be requested separately through a clear, optional choice.
The controller of personal data processed for the Affiliate Program is:
Tensoris Technology Limited
Company registration number: C112969
Registered address: Villa Malitah, The Village, Triq Il-Mediterran, San Ġiljan STJ 1870, Malta
Website: https://lusychat.ai
Affiliate and privacy contact: [email protected]
We use the affiliate-management platform provided by Trackdesk s.r.o. to operate the Affiliate Program. For personal data processed within our Trackdesk tenant on our instructions, Tensoris acts as controller and Trackdesk generally acts as processor. Trackdesk's own processing and contact information are described in the Trackdesk Privacy Policy.
We require Trackdesk and other processors to be bound by written data-processing terms appropriate to their role. Those terms must address processing on documented instructions, confidentiality, security, assistance with data-subject requests and incidents, deletion or return of data, and the engagement of subprocessors. We review relevant processor terms, subprocessor information, processing locations, and transfer safeguards before material use and when material changes are notified.
We may process personal data relating to:
We collect information directly from affiliate application and payout forms, from use of the affiliate portal and tracking links, and from LusyChat transaction and account systems. We may also receive relevant information from Trackdesk, payment providers, banks, public blockchain networks, fraud-prevention or sanctions-screening services, analytics or security providers, and publicly available professional or business sources where reasonably necessary to verify an application or investigate suspected abuse.
Where Article 14 GDPR applies because we obtained personal data from another source, we will provide the required information at the first communication, when the data is first disclosed, or within one month of obtaining it, as applicable, unless an exemption under applicable law applies.
We will never ask for a cryptocurrency private key, recovery phrase, seed phrase, complete payment-card number, or online-banking password. You must not submit such information to us or through the Affiliate Program.
We do not need and do not intentionally send a referred customer's name, email address, private chat content, prompts, generated content, account password, full payment details, precise sexual preference, sexual orientation, character or content tags, government identity document, or other special-category or unnecessary customer data to Trackdesk.
Affiliates must not place such information in tracking links, AffS1-AffS5 parameters, postbacks, support messages, coupon fields, or other custom tracking fields. Permitted tracking parameters should be limited to non-sensitive campaign information such as channel, campaign, ad set, placement, or creative identifier. If prohibited data is submitted, we may delete or restrict it and suspend the relevant integration.
Where we rely on legitimate interests, we assess the necessity and proportionality of the processing and balance our interests against the rights and reasonable expectations of the individuals concerned.
Fields marked as required are necessary to assess an application, enter into or perform the affiliate agreement, comply with applicable law, or process a payout. If required information is not provided or is inaccurate, we may be unable to approve or maintain an affiliate account or process a payout.
Telephone, Telegram, and Discord information is optional unless we clearly explain that a particular channel is required for a separately agreed support arrangement.
At the application stage, we normally collect only the information needed to review the application. We do not request an SSN as part of the general affiliate application. Tax information is requested after approval, normally when the affiliate approaches the first payout or when tax reporting otherwise requires it. The relevant field should be labelled "VAT / Tax ID / SSN (only if legally required)". We do not require every applicant to provide an SSN.
If an SSN or equivalent national tax identifier is legally required, we will identify the reason and provide a designated secure submission method. Affiliates must not send an SSN through ordinary email, Telegram, Discord, affiliate-manager messages, free-text application fields, or tracking parameters. Access is restricted to authorised finance, tax, compliance, privacy, security, or legal personnel with a work-related need. After verification, we will minimise, mask, or delete the full identifier where continued retention is not legally required. If a suitably secure collection method is not available, we will not request the identifier through the affiliate portal.
For USDT payouts, the affiliate must select a network currently shown as supported in the payout form and provide a wallet address valid for that network. The affiliate is responsible for checking network and address compatibility. We will not intentionally initiate a transfer on a network different from the selected network.
We may disclose personal data only as reasonably necessary to:
If an affiliate configures a postback, we may send that affiliate's own tracking platform limited pseudonymous conversion information selected in the approved postback configuration. We do not authorise postbacks containing customer names, customer email addresses, chat content, full payment information, special-category data, or other unnecessary identifiers.
We do not sell affiliate personal data.
Some recipients may process personal data outside Malta or the European Economic Area, including in the United States and other jurisdictions. Where required, we use an applicable adequacy decision, the European Commission's Standard Contractual Clauses, and appropriate supplementary technical and organisational measures. Information about relevant safeguards or how to obtain a copy may be requested at [email protected].
We maintain records of relevant processors and transfer safeguards and review them when a material provider or processing location changes. Further information about the categories of processors and applicable safeguards may be requested at [email protected].
The affiliate portal uses strictly necessary cookies or similar technologies for login, authentication, session management, security, load balancing, and interface preferences. Without these technologies, the portal may not function correctly.
When a visitor follows a LusyChat affiliate link, Trackdesk may generate a pseudonymous Click ID and store or read an attribution cookie, such as a trakdesk_cid cookie or tenant-specific equivalent. LusyChat may also retain the CID or External CID in a server-side record so that an eligible conversion can be matched to the referring affiliate.
The current standard Affiliate Program configuration is:
The setting in effect at the time of the click determines the applicable expiry for that click. Offer-specific settings may differ where clearly disclosed in the relevant offer terms.
Where consent is legally required, a non-essential affiliate-attribution cookie or similar technology will not be placed or accessed before valid consent is obtained. Visitors can refuse or withdraw consent as easily as they give it through the LusyChat consent interface. The live cookie declaration or consent interface identifies the technologies currently used, their providers, purposes, categories, and durations.
We maintain a cookie and similar-technology inventory and periodically test the LusyChat website, affiliate-link landing flow, and Trackdesk registration and portal surfaces. These checks are designed to confirm that non-essential technologies are blocked before consent where required, that refusal is offered as readily as acceptance, that consent can be withdrawn, and that the live names, domains, providers, purposes, and durations match the published information. If a scan identifies a material discrepancy, we will correct the configuration or update the relevant notice.
Each affiliate is independently responsible for providing notices and obtaining any consent required for technologies used on the affiliate's own website, app, email, advertisement, or other promotional property.
If an affiliate chooses a USDT payout, the wallet address, selected network, amount, transaction hash, timestamp, and related transaction information may be recorded on a public blockchain. Public blockchain records may be visible worldwide, may be copied or analysed by third parties, may reveal relationships between wallet addresses, and generally cannot be altered or deleted by Tensoris.
Cryptocurrency transfers are normally irreversible after confirmation. Affiliates must verify the wallet address and network before submitting or changing payout details. We may use payment, fraud-prevention, or sanctions-screening providers to assess a wallet or transaction where reasonably necessary or legally required.
The currently supported network list, network-selection rules, fees, and transfer conditions are maintained in the Affiliate Payment Terms and the live payout form rather than in this notice, because availability may change. We do not intentionally write an affiliate's name, email address, postal address, tax identifier, identity document, login information, or LusyChat chat or content data to a public blockchain.
The rights to correction or erasure do not enable Tensoris to alter or erase data already recorded on a public blockchain. We will, however, apply those rights to the off-chain association between an affiliate and a wallet address and to other personal data within systems under our control, subject to applicable legal and accounting exceptions.
We retain personal data only for as long as reasonably necessary for the purposes described in this notice and apply the following standard periods unless a longer or shorter period is required or justified:
We apply the retention schedule through periodic reviews and deletion or anonymisation procedures. A record may be placed on a documented legal hold where it is reasonably required for an unresolved payout, refund, chargeback, fraud or security investigation, audit, tax matter, dispute, or legal claim. The hold is reviewed and removed when the relevant need ends.
When a valid deletion request is received, we verify the requester's identity, identify the relevant systems and processors, separate records that must lawfully be retained, and delete or anonymise the remaining data. Where conversion or payout records must be preserved for accounting, fraud prevention, or dispute resolution, we may replace direct identifiers with anonymous or pseudonymous values while retaining the minimum necessary business record. We instruct relevant processors to take corresponding action where required. Copies in protected backups are isolated from ordinary use and deleted or overwritten in accordance with the applicable backup cycle, unless a legal hold applies.
We maintain a limited audit record of the request, the decision, the systems addressed, the action taken, the responsible person, and the date. That record is not intended to recreate personal data that has been erased. Public blockchain records are subject to Section 9 and are not under our unilateral control.
We use administrative, organisational, and technical measures designed to protect Affiliate Program personal data, including role-based access, least-privilege permissions, encryption in transit, account protections, security logging, vendor review, and incident-response procedures. Access to tax and payout details is restricted to personnel who require it for finance, tax, compliance, privacy, security, or legal functions. We periodically review access rights and remove access when it is no longer required.
No online system is completely secure. Affiliates are responsible for protecting login credentials and payout-account information and for reviewing payout details before submission. Contact [email protected] promptly if you suspect unauthorised access, an incorrect payout address, or another security issue.
We and our providers may use automated rules and risk signals to flag suspicious applications, invalid clicks, duplicate conversions, self-referrals, bots, chargebacks, prohibited traffic, sanctions concerns, or other potential abuse. A flag may temporarily place an application, conversion, commission, or payout on hold while it is reviewed.
We do not make a final decision to reject an application, terminate an affiliate account, permanently forfeit a commission, or deny a payout solely through automated processing where that decision would produce legal or similarly significant effects on an individual. A suitably authorised person reviews the relevant information before such a final adverse decision. The affected affiliate may request an explanation, provide relevant information, and contest the decision by contacting [email protected].
Subject to applicable law and relevant exceptions, you may have the right to:
To exercise a right, contact [email protected]. We may request information reasonably necessary to verify identity and protect the account from unauthorised disclosure. Requests are normally handled free of charge and within one month. Where permitted by law, this period may be extended by up to two additional months for a complex or numerous request, in which case we will explain the extension. We may charge a reasonable fee or refuse a manifestly unfounded or excessive request where applicable law permits.
You may lodge a complaint with your local data-protection authority or with:
Office of the Information and Data Protection Commissioner (Malta)
Floor 2, Airways House
High Street, Sliema SLM 1549, Malta
Telephone: +356 2328 7100
Email: [email protected]
Website: https://idpc.org.mt
The Affiliate Program is intended only for persons who are at least 18 years old and have legal capacity to enter into a business agreement. We do not knowingly accept affiliate applications from minors. If you believe a minor submitted personal data through the Affiliate Program, contact [email protected].
We may update this notice to reflect changes in the Affiliate Program, providers, legal requirements, or processing practices. We will update the version and last-updated date. Where a change materially affects individuals, we will provide additional notice through the affiliate portal, the LusyChat affiliate page, or email as appropriate. Changes to this notice do not create consent for optional processing that requires a separate consent.
Questions, requests, or complaints about the Affiliate Program or this notice should be sent to:
Tensoris Technology Limited
Attn: Affiliate Privacy
Villa Malitah, The Village, Triq Il-Mediterran
San Ġiljan STJ 1870, Malta
Email: [email protected]