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Marketing Guidelines Under Affiliate Program for BigPirate

1.  Purpose & Scope

These Marketing Guidelines contemplated under the Affiliate Program for BigPirate (“Guidelines”) set the baseline requirements for any promotional activity by Affiliates in connection with the Affiliate program managed and operated by AFFIQO LIMITED, with an address at DOUGLAS CHAMBERS, NORTH QUAY, DOUGLAS, IM1 4LA, Isle of Man (“Company”) related to its proprietary www.bigpirate.com website. These Guidelines are incorporated by reference into the Affiliate Agreement and shall be deemed to supplement (and not supersede) the provisions of that Affiliate Agreement. Capitalized terms not defined here have the meanings given in the Affiliate Agreement. In the event of any conflict between these Guidelines and the Affiliate Agreement, the more stringent requirement shall prevail.

2.  Governance, Approvals & Change Control

·   Pre- Clearance Requirement:

Affiliates shall obtain prior written approval from Company for all proposed Marketing Materials, including but not limited to campaign briefs, scripts, and key visual assets, before any such Marketing Materials are published or disseminated.

·   Use of Approved Materials

Affiliates shall not make any deviation from the Marketing Materials approved by Company unless renewed written consent is obtained in advance.

·   Record-Keeping Obligations

Affiliates shall maintain a version-controlled log of all published Marketing Materials and any subsequent modifications thereto, for a period of not less than twenty-four (24) months from the date of last use.

·   Corrective Actions and Enforcement‍

Company reserves the right to require the removal, amendment, or inclusion of corrective disclosures in any Marketing Materials at its sole discretion. Affiliates shall comply with such requests within the timeframe specified in the written notice issued by Company.

3.  Territorial Controls & Market Eligibility

Territorial Restrictions and Market Eligibility

·   Prohibited Jurisdictions

Affiliates shall not market, promote, or otherwise make the Promoted Site available in any jurisdiction that is either (i) expressly designated by the Company as a Prohibited Territory under the Affiliate Agreement, or (ii) qualifies as a Prohibited Territory by virtue of the definition set forth in the Affiliate Agreement.

·   Geographic Targeting Controls

Affiliates shall implement and maintain appropriate geo-filtering mechanisms and audience targeting settings, where such tools are available, to ensure compliance with territorial restrictions. Affiliates shall not engage in any activity intended to circumvent location-based blocks or eligibility criteria imposed by Company or Applicable Law.

·   Platform-Specific Restrictions

Affiliates shall comply with all platform-specific policies and restrictions, including but not limited to those imposed by app stores, social media networks, and advertising platforms. Such requirements shall apply in addition to, and not in derogation of, these Guidelines.

·   Applicable Laws

Affiliates shall ensure that all Affiliate Marketing Materials fully comply with the Guidelines, as well as all Applicable Laws (including, but not limited to, all Applicable Laws and regulations governing marketing, consumer protection, competition, anti-discrimination and false advertising).

4.  Transparency & Endorser Disclosures

For campaigns directed at audiences within the United States, Affiliates shall comply with all applicable disclosure obligations under the Federal Trade Commission’s Guides Concerning Endorsements and Testimonials in Advertising, as well as the .com Disclosures: How to Make Effective Disclosures in Digital Advertising guidance.

·   Disclosure of Material Connections

Affiliates must clearly and conspicuously disclose any material connection to Company, including but not limited to compensation, incentives, or other consideration received in connection with promoting the Promoted Site.

·   Placement and Proximity of Disclosures

Disclosures shall be placed in close proximity to the endorsement, such that they are immediately visible to the consumer. For audiovisual content, disclosures must appear at or near the beginning of the Marketing Materials.

·   Language Requirements

Disclosures must be made using plain and unambiguous language. Acceptable examples include: “Ad,” “Sponsored,” or “Paid Partnership with [Promoted Site].” Affiliates shall avoid vague or potentially misleading terminology such as “#partner” or “#collab” unless accompanied by a clear and explicit disclosure.

·   Device and Format Visibility

Disclosures must be readily viewable across all device types and formats, and shall not be obscured by truncation, expandable sections, or “more” links that require user interaction to reveal the disclosure.

·   Persistence of Disclosures Upon Republishing

Where Marketing Materials is republished, shared, or syndicated, the associated disclosure must remain attached to the Marketing Materials and be presented with equal clarity and prominence.

Affiliates are individually responsible for ensuring compliance with all applicable disclosure requirements and must monitor third-party content accordingly

5.  Authenticity & Tone

·   Use of Personal Voice

Affiliates are encouraged to communicate in their own authentic voice and style, provided that all messaging remains consistent with the approved key messages issued by Company. Affiliates shall refrain from using scripted or unapproved claims in any Marketing Materials.

·   Tone and Thematic Emphasis

All communications shall emphasize entertainment, community engagement, and user experience. Affiliates shall avoid exaggerated, sensationalist, or comparative statements, particularly those that reference or imply comparisons to gambling products or services.

·   Prohibited Implications

Affiliates shall not make any express or implied representations regarding the impact of participation on a user’s well-being, financial success, social status, or personal outcomes. All Marketing Materials must avoid suggesting that engagement with the Promoted Site will result in any form of guaranteed benefit or improvement.

6.  Product Positioning & Lexicon

Company supports a promotional sweepstakes model and social play experience through the Promoted Site. Accordingly, all Affiliate communications must be factually accurate, legally compliant, and free from any framing that may reasonably be interpreted as real-money gambling.

·   Permitted Messaging Themes

Affiliates shall emphasize themes such as entertainment, social engagement, free-to-play features, virtual coins, daily rewards, themed slot-style games, sweepstakes entries, and prize redemption (where available).

·   Prohibited Terminology

Affiliates shall refrain from using terminology commonly associated with gambling, including but not limited to: “bet,” “wager,” “stake,” “cash out,” “odds,” “house edge,” “high roller,” “jackpot,” or “win real cash.”

·   Approved Terminology Substitutions

Where relevant, Affiliates shall use alternative language that accurately reflects the nature of the promotional model, such as: “play,” “spin,” “try,” “redeem prizes,” “enter sweepstakes for a chance to win,” “special rewards,” or “grand prizes.”

7.  Clear Explanations of Coins & Sweepstakes

·   Coins used for sweepstakes entries (commonly referred to as “Diamonds” or equivalent) are not available for sale and may not be purchased under any circumstances.

·   Sweepstakes entries or coins may be awarded solely as promotional incentives, including, without limitation, upon account registration, daily login, participation in raffles or promotional campaigns, or as a complimentary bonus accompanying the purchase of non- sweepstakes coin packages.

·   Affiliates shall not make any representation, express or implied, that coins may be purchased for the purpose of participating in sweepstakes.

·   Affiliates shall include the following disclaimer in a clear and conspicuous manner: “No purchase necessary. Void where prohibited.” Affiliates shall also direct users to the official sweepstakes rules for full terms and conditions.

8.  Illustrative Permitted Messaging

The following examples reflect compliant and approved messaging language that Affiliates may use, provided such statements are presented truthfully and in accordance with these Guidelines:

·   “Play for fun, collect coins, and explore colourful slots—no purchase required.”

·   “Log in daily to pick up free coins and unlock new themed games.”

·   “Use eligible coins for sweepstakes entries and redeem prizes where available.”

·   Affiliates are encouraged to use similar language that emphasizes entertainment, social play, and promotional participation, without implying monetary risk or gambling-related outcomes.

9.  Prohibited Claims & Constructions

Affiliates shall refrain from making any statements, representations, or implications that conflict with the nature of the promotional sweepstakes model or that may mislead users. Specifically, the following are strictly prohibited:

·   No guarantees or assurances of prize outcomes, including statements such as “win every time” or “guaranteed jackpot.”

·   No references to real-money gambling or analogous experiences, including phrases such as “place your bets,” “just like Vegas,” or “cash out your winnings.”

·   No exaggerated or misleading language, including terms such as “risk-free” or “no strings attached.”

·   No claims suggesting psychological, emotional, social, or financial improvement as a result of participation or gameplay.

·   No misrepresentations regarding probabilities, odds, house edge, or similar constructs, including statements such as “easier than ever to win.”

·   No statements or implications that sweepstakes coins may be purchased, directly or indirectly.

10.  Audience, Age & Placement Controls

Affiliates shall ensure that all promotional activities are conducted in a manner that is appropriate for the intended audience and compliant with applicable platform and legal standards. Specifically:

·   Affiliates shall not target minors or vulnerable populations. Where available, Affiliates must implement age-gating mechanisms and interest-based audience filters to restrict access to Marketing Materials appropriately.

·   Affiliates shall avoid placing Marketing Materials adjacent to or within environments containing sensitive or inappropriate material, including but not limited to content involving violence, hate speech, or illegal activity.

·   All Marketing Materials must be fully compliant with the advertising, branded content, and promotional policies of the platform(s) on which it is published or distributed.

11.  Responsible Play & Consumer Information

Affiliates shall ensure that the Marketing Materials reflect a commitment to responsible engagement and consumer transparency. Specifically:

·   Where space permits, long-form promotional content shall include a brief and visible reminder encouraging responsible play, consistent with the entertainment-focused nature of the Promoted Site.

·   Affiliates shall provide clear and accessible pathways to customer support resources and to the official sweepstakes rules, where applicable, to enable users to make informed decisions regarding participation.

12.  Compliant Creative Directions (Optional)

Affiliates may produce Marketing Materials that align with the promotional nature of the Promoted Site, provided such content does not misrepresent the sweepstakes model or imply gambling-related outcomes. Permitted creative directions include:

·   Instructional walkthroughs demonstrating platform features such as account registration, daily reward collection, and exploration of themed slot-style games.

·   Feature spotlights highlighting visual design, sound elements, and thematic content, provided such presentations do not imply probabilities, odds, or monetary outcomes.

·   Community-oriented content, including challenges, non-monetary achievements, badges, and other engagement features that promote entertainment and social play.

13.  Monitoring, Enforcement & Remedies

Company reserves the right to monitor Affiliate activities to ensure ongoing compliance with these Guidelines. Specifically:

·   Company may conduct pre-publication and post-publication reviews of Affiliate Marketing Materials, including but not limited to marketing materials, social media posts, and paid media placements.

·   Any breach of these Guidelines may result in corrective action, including but not limited to: issuance of formal notices, temporary suspension of promotional campaigns, termination of Affiliate participation, and withholding or clawback of fees attributable to non-compliant activity.

Affiliates shall promptly remove or amend non-compliant Marketing Materials upon request and shall provide documentary evidence of such removal or modification. Affiliates further agree to cooperate with compliance audits, including the provision of relevant assets, media plans, and performance data upon request.

14.  Recordkeeping

Affiliates shall maintain comprehensive records of promotional activities to support compliance verification and audit processes. Specifically:

·   Affiliates shall retain copies of all Marketing Materials, including but not limited to posts, captions, scripts, storyboards, live-read outlines, and paid media settings, for a period of not less than twenty-four (24) months following their last use.

·   Affiliates shall maintain distribution records and platform analytics sufficient to demonstrate compliance with these Guidelines, including the visibility and placement of required disclosures across all relevant formats and devices.

15.  Contact & Updates

·   For questions, clarifications, or support regarding these Guidelines, Affiliates may contact Company at: partners@sweepdreams.com

Company reserves the right to amend or update these Guidelines at any time. Material updates shall be communicated to Affiliates in writing. Continued participation in the Affiliate Program following such updates shall constitute acceptance of the revised Guidelines.

Email:
partners@sweepdreams.com
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