Program overview
Contractual Program operator identified in the Affiliate Program Agreement. The historical invoicing provision referring to Surfshark Ltd. (BVI) for services rendered before October 2021 must not be used to identify the current operator.
S2 currently identifies Surfshark VPN, Surfshark Antivirus, Surfshark Search, Surfshark Alert, Incogni and Alternative ID as covered products. Surfshark reserves the right to add products.
This statement concerns promotional language support. It does not establish worldwide publisher eligibility.
Publisher access
S3 additionally documents a direct contact path through the Surfshark Affiliates department. Automatic acceptance is not supported.
Worldwide availability and support for all promotional languages do not establish worldwide publisher eligibility.
Contractual provisions concerning Affiliate websites and Media apply when a website is used; they do not require every Affiliate to operate a website. No numeric minimum traffic threshold is established.
No universal minimum content requirement is established. Promotional restrictions are covered under Promotional and channel restrictions.
Contractual identity, fraud-prevention and payment-information obligations must not be converted into a universal application-stage KYC process.
Commissions
40% must not be represented as a universal immutable rate for every Affiliate or negotiated arrangement. No synthetic range.
OFFER_LEVEL is used only where a factual finding actually varies by Offer. Program-level architecture remains verified.
Not to be simplified to "recurring commissions available" nor to "recurring commissions never available". The negotiated exception must remain visible.
No generic routine 30-day hold period is created. Only the documented contractual mechanics are represented.
Tracking
S1 describes the 30-day affiliate cookie; S2 documents Surfshark placing a tracking cookie on the End-user's computer or mobile device.
No first-party / third-party classification is authorized.
The documented limitation is preserved as stated. It is not broadened into unsupported technical claims about every possible cross-device scenario.
The universal SubID field remains NOT_ESTABLISHED. A contextual source/sub-source-ID requirement in the Affiliate Network Campaign context is documented in the Agreement and preserved in Important context; it must not be promoted to universal SubID support.
Real-time reporting documented by S1 does not establish API access.
Attribution
This is an attribution/referral window. It coincides numerically with the cookie duration but remains a distinct factual concept.
S1 states that retained visit information applies to the customer's most recent visit, and that a later Affiliate referral receives the Commission. S2 confirms the last-Link requirement.
Payments
Sources use different threshold formulations.
S1 states: "Minimum payout threshold of $100."
S2 states: payment may be requested where total Commissions owed are "greater than $100," and also refers to the "$100 minimum."
The primary sources use materially non-identical threshold formulations. The contradiction is preserved and not resolved to a synthetic value.
payment on Affiliate request unless otherwise agreed; Surfshark may automatically generate an invoice for payable Commissions and/or an agreed fixed fee; payment is remitted within 30 days based on that invoice; payment is considered made when funds are deducted from Surfshark's payment account; where an Affiliate generates steady revenue, an invoice may be sent at the beginning of each month without the Affiliate messaging Surfshark first
The steady-revenue mechanism is conditional and must not become a universal monthly cadence. "Within 30 days based upon that invoice" is not evidence of a universal monthly payment schedule. Commission validation, invoice generation and payment processing are distinct stages.
No universal main-Program payment method is established. Affiliate Referral Program payment mechanics (Annex 3) must not be inherited.
No generic routine hold period is created. Validation, refund and chargeback mechanics are represented through the validation period and this record's notes.
Promotional and channel restrictions
Not to be simplified to "all paid search prohibited".
S1 gives Facebook, X and YouTube as examples of alternative promotional channels; S2 frames paid campaigns.
Conditional treatment; not a categorical exclusion of all cashback publishers.
Terms and restrictions
Agreement entered into between Surfshark B.V. and the applying party; applies to participation in the surfshark.hasoffers.com Affiliate Program; offer-based contractual structure; individual Offers may contain additional terms incorporated into the Agreement; program agreement begins upon Surfshark approval of the Affiliate application
The historical invoicing provision referring to Surfshark Ltd. (BVI) for services rendered before October 2021 must not be used to identify the current operator.
Other verified legal findings (six-month inactivity provision, Netherlands governing law, Netherlands Arbitration Institute dispute-resolution mechanism in Rotterdam, English-language proceedings) are preserved in Important context.
Network / Platform Relationship
S1 describes TUNE / HasOffers as Surfshark's main affiliate platform. S2 expressly states that the Agreement applies to the surfshark.hasoffers.com Affiliate Program. Annex 3 uses TUNE for the separate Affiliate Referral Program operations. Governance is mixed: Surfshark defines admission, Program terms, economics, Qualified Actions, promotional rules and contractual enforcement; TUNE / HasOffers is used as the Program platform. affiliation_type remains NOT_ESTABLISHED; no DIRECT_HOSTED, REDISTRIBUTED or PARTNER_MANAGED is inferred. No canonical network_slug is established by the frozen evidence.
Important context
Material boundaries preserved from the canonical factual record.
Institutional boundaries
- TUNE / HasOffers ≠ every other named platform. TUNE / HasOffers has the strongest Program-level evidence. Impact Radius, Avant, CJ, AppsFlyer and Awin have verified official mentions but unresolved exact institutional roles.
- Surfshark Affiliate Program ≠ Affiliate Referral Program. Annex 3 creates a distinct Affiliate Referral Program through which existing Surfshark Affiliates can refer new Affiliates. Its economics and payment mechanics must not be used as ordinary customer-acquisition Program economics.
- Surfshark Affiliate Program ≠ Consumer Refer & Earn. Consumer referral economics are outside this audit and must not be inherited.
- Promotional globality ≠ publisher eligibility. Support for all promotional languages and broad product availability do not establish universal Affiliate acceptance.
- Conditional identity requirements ≠ universal KYC. Contractual identity, fraud-prevention and payment-information obligations must not be converted into an unsupported universal application-stage KYC claim.
- Network-campaign source/sub source IDs ≠ universal SubID feature. The contractual requirement is contextual to the Affiliate Network Campaign context.
- Affiliate Referral Program payment method ≠ main Program payment methods. The payment-method mention in Annex 3 (TUNE account) must not be inherited into the ordinary customer-acquisition Affiliate Program.
- Historical operator boundary: the invoicing provision referring to Surfshark Ltd. (BVI) for services rendered before October 2021 under agreements entered into before 1 October 2021 is historical. It must not be used to identify the current operator.
- Offer-level contractual architecture: the Agreement uses an Offer-based structure. OFFER_LEVEL is used only where a factual finding actually varies by Offer.
Tracking and attribution
The 30-day cookie duration and the 30-day attribution/referral window coincide numerically but remain separate factual concepts. Tracking and attribution remain structurally distinct. Attribution is based on the documented most-recent-visit / last-referral mechanism.
Commission representation
The advertised starting rate is 40% revenue share on new sales. It is not a universal immutable rate for every Affiliate or negotiated arrangement. Custom payouts or offers may be available based on performance and traffic values. No synthetic range is produced.
Recurring commissions
Standard recurring-sale commissions are not paid. Recurring treatment may be separately agreed through an Advertising Agreement. This must not be flattened into a universal "yes" or a universal "no".
Qualified Action and refund boundaries
The Agreement establishes cumulative Qualified Action requirements: End-user reaches the Program Website through the Affiliate Link; that Link is the last Link to the Program Website; End-user is not automated/artificial/fraudulent; required information is completed within the permitted period; End-user subscribes to paid Surfshark services; subscription is not cancelled within the applicable permitted period; End-user is not later classified as fraudulent, incomplete, unqualified or duplicate. Qualified Actions associated with End-users located, organized or resident in comprehensively sanctioned or embargoed jurisdictions do not qualify for Commission. The corresponding Commission may be cancelled, withheld, charged back or deducted where the underlying transaction ceases to satisfy Program requirements.
Additional verified promotional restrictions
- Retargeting: prior written permission required. Retargeting events without a seven-day inactivity window will not be approved.
- Popup / pop-under: prohibited unless Surfshark grants written permission.
- Comment spam: prohibited. Relevant affiliate promotion in contexts discussing VPN/proxy services is distinguished from off-topic comment spam.
- Cookie stuffing: prohibited.
- Domain / trademark restrictions: infringing use of Surfshark or affiliated entities' trademarks is prohibited, including use of protected marks in domain names.
- Self-referral: using Affiliate Links to order subscriptions for the Affiliate itself is prohibited.
- Chat rooms / message boards: association or placement of Affiliate Links is restricted unless otherwise agreed in writing.
- Online auction platforms: Surfshark ads may not be placed on online auction platforms such as eBay or Amazon.
- Geographic promotional restrictions: targeting End-users located, organized or resident in comprehensively sanctioned/embargoed jurisdictions is prohibited; India is subject to a written-agreement condition for targeting. This is a promotional / Qualified Action restriction and does not by itself establish the complete geographic eligibility rules for Affiliate applicants.
Contextual source / sub-source IDs
The Agreement requires, specifically in the Affiliate Network Campaign context, that an Affiliate and/or Third Party Affiliate provide source and sub source IDs for optimization. This contextual requirement is not promoted to universal SubID support for every Affiliate in every Program interface.
Additional officially named platforms
S1 states that Surfshark can also be found on Impact Radius, Avant, CJ, AppsFlyer, Awin and others. Their existence is VERIFIED at the level of the official statement. Their exact governance, institutional role and affiliation_type remain NOT_ESTABLISHED. They are not represented here as equivalent confirmed network affiliations. "And others" is not converted into named platforms.
Additional verified legal findings
Six-month inactivity provision: where an Affiliate has earned no commissions or has not logged into the Affiliate account during a six-month period, Surfshark may, at its discretion, terminate the Agreement, close the account and withhold unpaid Commissions. Governing law: Netherlands. Dispute resolution: Netherlands Arbitration Institute mechanism; Rotterdam; English-language proceedings.
Sources
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S1 Join the Surfshark Affiliate Programhttps://surfshark.com/affiliate
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S2 Affiliate Program Agreement / Terms & Conditionshttps://surfshark.com/affiliate-terms-and-conditions
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S3 How to join the Surfshark Affiliate programhttps://support.surfshark.com/hc/en-us/articles/360012218919-How-to-join-the-Surfshark-Affiliate-program
AffiliateAct verifies Program information against documented sources and preserves uncertainty where evidence is incomplete or conflicting. Read the methodology.