Privacy policy

Last updated: 23 September 2026. Deutsche Fassung

1. Who we are

The controller responsible for your personal data is Eco Sure Energy Ltd, trading as Cobalt Funnel, 71–75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom, company number 16660663. Contact: support@cobaltfunnel.com.

2. What we do

We are an affiliate marketing partner of licensed online gaming operators. We send marketing emails about their offers to adults who have consented to receive them, and the operators' affiliate programmes pay us when someone we referred registers or plays.

3. The data we hold

• Contact details: name, email address and, where we have them, phone number, postal address and date of birth.
• Consent records: when and how you agreed to receive marketing, and any later unsubscribe.
• Email activity: whether an email was delivered or bounced, and whether it was opened (via a small image in the email).
• Clicks: when you click a link in our emails, we record the time, your IP address and your browser type, and give the click a random ID.
• Referral outcomes: the operators' affiliate programmes tell us, against that random click ID only, whether the click led to a registration, a deposit or a commission payment to us.

4. Where your data came from

We collected your contact details ourselves: Eco Sure Energy Ltd, which trades as Cobalt Funnel, collected them through www.ecosureenergy.co.uk during the sign-up and payment process, between September 2025 and September 2026. At that point you chose to receive future correspondence and special offers from Cobalt Funnel. We did not buy, rent or receive your details from anyone else.

5. Why we use it, and the legal basis

• Sending you marketing emails: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time with the unsubscribe link in any email.
• Measuring which emails and offers work: delivery, opens, clicks and referral outcomes. Basis: your consent to marketing, and our legitimate interest in running our campaigns effectively (Art. 6(1)(f)).
• Detecting automated or fraudulent clicks: IP address and browser type. Basis: legitimate interest (Art. 6(1)(f)).
• Keeping a do-not-contact list after you unsubscribe: so that we never email you again. Basis: legal obligation and legitimate interest (Art. 6(1)(c) and (f)).
• Age: we use date of birth, where held, to make sure we never send gambling marketing to anyone under 18.

6. Who we share it with

• Infobip Ltd (email delivery), acting as our processor.
• Fasthosts Internet Ltd (hosting of our systems in the United Kingdom), acting as our processor.
• Gaming operators and their affiliate programmes receive only the random click ID when you click a link. We do not pass them your name, email address or other contact details. If you choose to register with an operator, that operator's own privacy policy applies to the data you give them.

We do not sell your personal data.

7. International transfers

Our systems are hosted in the United Kingdom, which the European Commission recognises as providing an adequate level of data protection. Where one of our processors handles data outside the UK or the European Economic Area, we rely on an adequacy decision or the European Commission's standard contractual clauses.

8. How long we keep it

• Contact details and activity data: until you unsubscribe, or for 24 months after your last interaction with our emails, whichever is sooner.
• Consent records: for as long as we hold your data and for 3 years afterwards, so we can show that consent was given.
• Do-not-contact list: only your email address and the date you unsubscribed, kept indefinitely so you are never emailed again.

9. Your rights

You have the right to access, correct or delete your data, to restrict or object to its use (including at any time to direct marketing), to data portability, and to withdraw consent. Email support@cobaltfunnel.com. You can also complain to a data protection authority, for example the data protection authority of your German federal state or the UK Information Commissioner's Office (ico.org.uk).

10. This website

This website sets no cookies and uses no analytics or tracking. Our web server keeps standard access logs (IP address, time, page) for up to 14 days for security.

11. Automated decisions

We do not make decisions with legal or similarly significant effects about you by automated means.