Privacy and Cookies Policy (the “Policy”)
1.1 We are committed to protecting and respecting your privacy. This Policy explains the basis on which personal information we collect from you, or that you provide to us, will be processed by us for all online services. Please read it carefully to understand our practices regarding your personal information and how we will treat it.
1.2 We, POKER LONDON Limited (a company registered under number 09945514), comply with all applicable data protection laws including the Data Protection (Bailiwick of Guernsey) Law 2001 and the Data Protection Act 1998.
1.3 The data controller is POKER LONDON Limited.
2. INFORMATION COLLECTION AND USE
2.1 Personal information is collected primarily during the registration process, but is also monitored and collected when there is activity on your account and when you use our site http://pokerdapp.io including versions of our website viewed on mobile phones, tablets or other electronic devices (in all cases referred to as the “website”). Personal information (as used in this Policy) refers to such types of information that can be used to personally identify you and which are described in more detail below.
Types of information
2.2 You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, age address, telephone number, e-mail address and bank details.
2.3 If you create an account during the registration process certain information will be stored by us under your account profile include your username, email address, and password.
2.4 We may collect technical information about your computer or device including your IP address, operating system, browser type, time-zone, and browser plug-in details.
2.5 In relation to your activity on our website, we may collect information relating to web addresses that you arrive from or click through to, pages viewed, page response times, download errors, length of time spent on certain pages, page interaction information such as scrolling and clicks, and methods used to browse away from pages.
2.6 We may receive information about you if you use any of the other websites we operate or the other services we provide.
How we may use that information
2.7 Personal information submitted by you to the website or collected by us will be used for the following purposes only. We will only collect and retain personal information to the extent that it is required for our purposes.
2.8 These purposes are to:
2.8.1 ensure that content from our website is presented in the most effective manner for you and for your computer;
2.8.2 carry out our obligations arising from any contracts entered into between you and us;
2.8.3 verify your identity and undertake checks for the purposes of the prevention of fraud;
2.8.4 allow you to participate in interactive features of our service, when you choose to do so;
2.8.5 notify you about changes to our service;
2.8.6 assist us in setting up and managing your account and to build up an accurate customer profile of you;
2.8.7 provide you, or permit selected third parties to provide you, with information, products or services which we feel may interest you and contact you, or permit selected third parties to contact you, for market research purposes. If you do not want us to use your information in this way please tick the relevant box on the registration form or contact us by one of the methods described in paragraph 4.2 below;
2.8.8 enable us to comply with all regulatory requirements, in particular those relating to the identification of individuals under money laundering legislation; and
2.8.9 disclosure as set out in paragraph 5 (Disclosure of your Personal Data) below.
2.9 We may combine some aspects of your information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
3.1 We may also obtain information about you by using cookies. Cookies are small software files, typically consisting of numbers and letters, which are placed by a website onto the computer or other device used to access that website.
3.2 We will place cookies onto any devices you use to access our website. These cookies will enable information to be:
3.2.1 stored on your devices; and
3.2.2 sent to and from our website and your devices.
3.3 Cookies help us to improve our website and to deliver a better and more personalised service. They enable us to:
3.3.1 estimate our audience size and usage pattern;
3.3.2 store information about your preferences, and so allow us to customise our website according to your individual interests (including the delivery of advertising that we think might be of interest to you);
3.3.3 analyse the impact and effectiveness of marketing activities;
3.3.4 speed up your searches; and
3.3.5 recognise you when you return to our website.
3.4 An indication of the types of cookies that may be placed on your devices can be found in the table below:
|Cookie Name or ID||Purpose of the Cookie||Information held by the Cookie||Cookie Expiry Date|
|AFF_ID||Tracking||A unique tracking identification code||30 days|
|SUB_ID||Tracking||A unique tracking identification code||30 days|
|PreRegCookie||Conversion tracking||Registration progress||24 hours|
|AFF_CREATION_DATE||Tracking||Marks the creation date of AFF_ID||30 days|
|NR||Tracking||A unique tracking identification code||30 days|
|muid||Session Tracking||Session reference for logged in users||30 days|
|JSESSIONID||Apache routing||Used to route traffic across load balancers||Session only|
|ga||Tracking / Google Analytics||Contains an anonymous data used to distinguish users||2 years|
|mmcore.pd||Test & Metrics||Visitor ID + Content served||365 days|
|mmcore.srv||Test & Metrics||Visitor ID + Content served||365 days|
|mmcore.tst||Test & Metrics||Visitor ID + Content served||31 days|
|mm_monitoring||Metric||Records if a visitor completed pre-registration||35 days|
|mm-t81-reg-start||Metric||Records if a visitor starts registration||Session only|
|mm_tracked_account||Metric||Records if a visitor completes registration||60 days|
|mm_reg_complette||Metric||Records if a visitor completes registration||1 day|
|mm_current_register_session||Test||Records if a visitor registered in that session||Session only|
|mm-t66-counter||Test & Metrics||Used to track promotional opt-in||365 days|
|mm-t66-generated||Test & Metrics||Used to track promotional opt-in||365 days|
|mm-t66-hompepage-active||Test & Metrics||Used to track promotional opt-in||365 days|
3.5 You may refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of all or some cookies. However, if you do not accept cookies you may be unable to access the whole or part of our website or may be unable to enjoy the benefit of the full functionality of it.
3.6 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis) may also place cookies on your computer or device as a result of you using our website. We have no control over these cookies or how they are used and they are not listed in the table above.
4.1 If you do not wish to receive promotional or other marketing information from us or third parties then please tick the appropriate opt-out box during the registration process.
4.2 Alternatively you can easily opt-out of marketing communications at a later date by clicking on the ‘My Account’ section of our website and clicking on ‘Personal Details’; you can then change your communication methods and opt-out. Alternatively, you can send us an email to email@example.com and we will change your contact status as soon as reasonably possible.
5. DISCLOSURE OF YOUR PERSONAL DATA
5.1 We may share your personal information with any member of our group, which includes all subsidiaries of our parent company, POKER London Plc.
5.2 We may also share your personal information in the manner set out below:
5.2.1 to reputable marketing partners selected by us for the purposes of selecting and serving relevant promotional materials and adverts to you and others (unless you have told us not to);
5.2.2 to a third party in the event that all or a substantial part of our business and assets are acquired (or it is proposed that they be acquired) by that third party and, in such circumstances, personal information held by us about our customers is likely to be one of the transferred assets;
5.2.3 to any competent legal, regulatory or law enforcement authority, in order to comply with any legal obligation or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property or safety of POKER LONDON LIMITED, our customers, or others. In the event of disclosure to a law enforcement authority, you may not be informed of any disclosure nor of any reasons for such disclosure;
5.2.4 to exchange information with other companies and organisations for the purposes of age verification, fraud protection and credit checking and/or risk reduction; and
5.2.5 to our professional advisers or other appropriate third parties, if your use of our gaming services or our website is in breach of the terms and conditions or this Policy.
6. DATA ACCESS AND CORRECTIONS
6.1 You have the right to access information held about you in accordance with data protection laws. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
6.2 Written requests should be addressed to: The Data Protection Officer at POKER LONDON LIMITED, 90 Broad Street, Edgbaston, Birmingham, West Midlands, United Kingdom, B15 1AU or you can email firstname.lastname@example.org.
6.3 Upon receipt of your written request we will disclose to you your personal data held by us. We shall also correct or delete inaccurate details, and notify any third party recipients of the necessary changes. Changes to certain parts of your account information can also be made by accessing ‘My Account’.
7. TRANS-BORDER DATA TRANSFERS
Your personal data may be transferred outside the European Economic Area. Whenever such transfers are effected pursuant to arrangements made by us, we shall enter into agreements requiring the recipients of your personal data to adhere to standards of data protection substantially similar to those prevailing in the European Economic Area. By visiting the website and communicating electronically with us you consent to these transfers.
8. CHANGES TO OUR POLICY
We may make changes to this Policy at any time. We will make reasonable efforts to notify you of any significant changes by e-mail, notice on the website or account message. However, it is your responsibility to check the Policy from time to time to ensure that you agree with it and your continued use of the website will be deemed to be your acceptance of any changes that we make.
9. CONTACT INFORMATION
Last updated on: 7th May 2018