Unprofessional, unethical Behavior

Official Response from CristalPoker Casino.

We strongly dispute the allegations made in this complaint.

First of all, the affiliate never generated a commission of €4,217 as claimed.

The affiliate account in question generated only 7 FTDs under a €100 CPA agreement, which would have resulted in a total commission of €700 if the traffic had been legitimate and compliant with our Terms and Conditions. 

Proof:

https://prnt.sc/-xpoIR396Ooi

https://prnt.sc/VDkAku0QVUEV

https://prnt.sc/Cp5U3MOXr-oJ

Our decision to terminate the collaboration was based on multiple incidents involving abusive tracking behavior and traffic quality concerns.

The affiliate initially approached us claiming to work with retargeting traffic. In good faith, we allowed the integration of his tracking scripts through our GTM.

However, within just a few days, we detected extremely abusive behavior. More than 80% of newly registered customers on CristalPoker were suddenly being attributed to his affiliate account, including players coming from other affiliates’ campaigns.

We provided him with clear proofs showing cases where:

• customers received emails from other affiliates,

• clicked “Register Now” buttons from those affiliates,

• but after registration were incorrectly assigned under his affiliate account.

• Even users entering directly to cristalpoker.com for the first time, in incognito mode were being attributed to him after registration.

Proof:

https://prnt.sc/tKVmKl4Db7KG

One particularly clear example involved another affiliate who created multiple accounts using his own referral link. Despite this, all of those registrations were attributed to the affiliate who submitted this complaint, demonstrating the extremely aggressive attribution behavior of the tracking setup being used.

When these issues were raised, the affiliate acknowledged the problem and provided a replacement script, assuring us that the issue had been fixed.

Unfortunately, the same behavior continued after the replacement script was installed.

Additionally, we observed a number of highly suspicious events generated through the affiliate’s traffic source, including:

• Thousands of clicks generating virtually no legitimate registrations.

• Large volumes of suspicious chat interactions from users who did not even have accounts on the platform. Thousands of them entering in Live Chat in the same time and asking same absurd things as you can see here: https://prnt.sc/JPZPp1Si-6Hl  And all of them comming from this affiliate referral link.

Moreover, he appears to be part of a group/network of affiliates using similar abusive methods. Here is another affiliate account which we also blocked for exactly the same reason and type of activity:

Proofs:

https://prnt.sc/eeySjEJCsRpa

https://prnt.sc/yEVFNs5k_vn4

https://prnt.sc/EHIvhlHZ3_so

These screenshots provide more than enough evidence that he is part of a group/network of affiliates using similar abusive methods.

After a detailed internal review, we concluded that the activity created significant risks for our affiliate program and other partners. As a result, the affiliate account was terminated and all related tracking integrations were removed.

We would also like to clarify the following:

• No legitimate earned commissions remain unpaid.

• No commission balance of €4,217 has ever existed on the affiliate account.

• The account was closed due to traffic quality and attribution concerns, not as a method of avoiding payment.

CristalPoker has worked with affiliates for many years (since 2010) and has successfully paid commissions to thousands of partners. We have a zero-tolerance policy toward abusive attribution methods, fraudulent traffic, or activities that negatively impact other affiliates participating in our program.

Best Regards,

Victor

CristalPoker Casino Affiliate Manager

I respectfully disagree with both the characterization of my activities and the decision to terminate my account without prior notice or a transparent investigation process.

1. Tracking Integration Was Approved by Your Team

The tracking setup and scripts used on CristalPoker were not installed without your knowledge. The screenshots attached clearly demonstrate that:

I openly informed you that we were running retargeting campaigns.

I provided the tracking code directly to your team.

Your team reviewed, discussed, and voluntarily implemented the code through your GTM.

When concerns were raised, I immediately cooperated, explained the setup, and provided an alternative implementation upon request.

At no point did I attempt to hide the tracking method being used.

2. No Evidence of Intentional Fraud Has Been Presented

Your statement contains allegations of “abusive tracking behavior,” “fraudulent traffic,” and being part of a “network” of affiliates.

These are serious accusations.

However, no evidence has been presented proving that:

I intentionally hijacked traffic.

I manipulated your platform.

I generated fake registrations.

I violated any specific clause of your affiliate agreement.

Technical attribution issues can occur for many reasons, especially when third-party tracking systems are involved. Such issues do not automatically constitute fraud.

3. Contradictory Position Regarding Tracking

Your response acknowledges that:

The original script was approved and installed.

Concerns were later raised.

I cooperated and provided a replacement script.

The replacement script was also approved and installed.

If the tracking implementation was considered unacceptable, it should have been rejected before installation rather than approved and used.

Holding an affiliate solely responsible for a tracking setup that was reviewed and deployed by the operator raises serious concerns regarding fairness and accountability.

4. Lack of Due Process

The account was terminated without:

A formal warning.

A reasonable remediation period.

A documented technical investigation shared with me.

An opportunity to independently verify the allegations.

Instead, the account was blocked and commissions were withheld based on internal conclusions that I was never given the opportunity to review or challenge.

5. Commission Dispute

You state that only 7 FTDs were attributed to my account and that the maximum commission would have been €700.

However, the affiliate dashboard displayed different performance data during the cooperation period. If adjustments were made, I request a complete audit log showing:

Registrations.

FTDs.

Attribution changes.

Deducted commissions.

Reasons for each adjustment.

Transparency is necessary to verify the accuracy of your claim.

6. Request for Resolution

I remain willing to resolve this matter professionally.

Therefore, I request:

A complete export of all traffic and conversion data associated with my account.

The specific Terms & Conditions clauses allegedly violated.

Technical evidence demonstrating intentional misconduct rather than attribution discrepancies.

Reconsideration of the account termination and unpaid commission decision.

I have always acted transparently, responded promptly to concerns, and cooperated whenever issues were raised. For this reason, I believe the account termination and withholding of commissions were disproportionate and unsupported by sufficient evidence.

I look forward to your response.

Kind regards,

Andranik Mirzoyan

Thank you for your reply.

However, after reviewing your comments, our position remains unchanged.

First, we would like to clarify that this was not a case of a minor attribution discrepancy or a technical misunderstanding.

We have already provided multiple examples showing that customers who received promotional emails from other affiliates, clicked on registration links belonging to those affiliates, and proceeded to register on CristalPoker were nevertheless attributed to your affiliate account.

One of the screenshots previously provided clearly demonstrates this exact scenario.

We also provided examples where:

• Completely new users visiting CristalPoker directly through our domain using an incognito browser session were attributed to your affiliate account.

• Registrations generated through another affiliate’s referral link were attributed to your affiliate account.

These are not normal attribution discrepancies. They are clear examples of tracking behavior that interferes with the legitimate attribution of other affiliates’ traffic.

Once the issue was detected, we immediately contacted you and explained our concerns.

You then provided a replacement script and assured us that the issue had been resolved.

We accepted this explanation in good faith and allowed the collaboration to continue.

Unfortunately, after implementation of the replacement script, the exact same behavior continued.

Therefore, your statement that no warning was given is incorrect. The first detection of the issue and our discussion regarding it constituted a formal warning and remediation opportunity. The account was terminated only after the same behavior was detected again.

Regarding the commissions:

You continue to reference a figure of €4,217.

As already demonstrated through screenshots from the affiliate platform, no such commission balance ever existed on your account.

The account generated a total of 7 FTDs under a €100 CPA agreement, resulting in a maximum potential commission of €700.

The screenshots previously provided clearly show:

• 5 approved FTDs;

• 2 additional FTDs;

• €100 CPA per FTD.

At no point did the affiliate account display or generate €4,217 in legitimate commissions.

Furthermore, pursuant to the Affiliate Terms and Conditions accepted during registration, CristalPoker reserves the right to terminate affiliate accounts and withhold commissions generated through abusive or non-compliant traffic.

In particular:

• Clause 2.8 prohibits benefiting from traffic not generated in good faith and expressly allows CristalPoker to retract commissions and terminate affiliate accounts where fraudulent or abusive activity is detected.

• Clause 4.12 states that no revenue shall be generated from accounts involved in fraudulent activity or other prohibited conduct.

• Clause 4.14 reserves the right to withhold payments from affiliates who violate the Affiliate Terms and Conditions.

• Clause 10.2(d) states that if an affiliate fails to fulfill its obligations and responsibilities, CristalPoker is not required to pay referral fees otherwise owing upon termination.

For this reason, the request for a complete export of player-level data cannot be accommodated.

We do not share internal customer information, tracking data, verification records, fraud-detection systems, or attribution methodologies with affiliates whose accounts have been terminated for abusive activity.

Finally, we note that the concerns were not limited to a single script or isolated incident.

We also provided evidence showing another affiliate account using exactlly the same script, tracking methodology and producing the same attribution issues.

Combined with the examples already provided, this strongly indicated a pattern of activity rather than an isolated technical error.

At this stage, we believe we have provided more than sufficient evidence explaining:

• why the traffic was classified as abusive;

• why the commissions were deemed invalid;

• why the affiliate account was terminated; and

• why no payment is due.

Accordingly, CristalPoker considers this matter closed.

Best Regards,

Victor

CristalPoker Casino Affiliate Manager