This document is effective from September 2020
PRIVACY & COOKIE POLICY
Please read Digital Platform’s Privacy Policy before using POKS services as it will let you know how we collect, store, use and disclose your personal information when providing our services to you. If you have questions or complaints regarding our Privacy Policy or practices, please see Contact Us.
Digital Platforms (similar to Digital platforms LLC or TSIFROVYE PLATFORMY OOO) is the developer and owner of the POKS online poker software for mobile devices. Digital Platforms is deeply committed to safeguard the privacy expectations of its users (“User(s)”, “you” or “your”). Accordingly, we have put in place this privacy Policy and Cookie Policy, which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Information, as well as your rights with respect to your Personal Information.

For purposes of data protection laws, Digital Platforms is the “data controller” of your personal information.

INFORMATION WE COLLECT

The information we collect depends on what Services you use and how you use them.
Please see below for more details.

1.1 INFORMATION YOU GIVE US DIRECTLY

We collect information that you provide us, including:

• Your POKS Account information, including your email address.
• Security questions and answers;
• Information you provide when seeking help from us such as your name, phone
number and email records of the issues you experience;

1.2 INFORMATION YOU PROVIDE WHEN PLAYING ONLINE

When you participate in social features such as chat, the audio, visual, and electronic information that you disclose may become publicly available. It also may be read, copied, collected, or used by other players. Please make sure your privacy settings reflect your preferences.

1.3 OTHER INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES

We may collect other information automatically when you use our Services, including IP address;

• Mobile and other hardware or device identifiers, platform type;
• General geolocation data (derived from IP or device settings);
• Browser information, including your browser type and the language you prefer;
• Referring and exit pages, including landing pages and pages viewed and other interactions with web content;
• Information about your device, hardware and software, such as your hardware settings and components, POKS software and updates you have installed or use, and presence of required plugins;• Details about what POKS game or Services you purchase or obtain, and your use of them;
• Inferences regarding your preferences, predispositions, behavior, abilities, and aptitudes;
• Device event information, including crash reports, request and referral URLs and system activity details (e. g. whether you encountered an error playing our game or lost Internet access);• Other information (such as your likeness) that you may provide as part of your participation in live events.
We also may collect and store information locally on your device, using mechanisms like cookies, browser web storage (including HTML 5) and application data caches.

LEGAL BASIS FOR PROCESSING

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing for our Services and on contractual necessity to process information when you create a POKS Account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us
via the options below.

2.1 HOW WE COLLECT INFORMATION

We and third parties use technologies described below to collect information to deliver best experiences. Data collected from application or social media (if you use it as a login) may only be shared with third parties to improve the application or serve advertising. We provide the user's consent when collecting data, even if such data is considered to be anonymous at the time of or immediately following collection. For example, when registering, the user must enter their consent and express it by "ticking a box" or by clicking on the "consent button" in a special form.

Users can easily withdraw their consent by writing in a free form to our support email address with the subject "withdrawal of consent to data collection/processing". Data is deleted within 10 days. The user is notified of this by return email.

2.2 COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what game you play. This information helps us keep track of your shopping cart, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly and otherwise help enhance your player experience. You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences.

We use other technologies for similar purposes as a cookie. We use tracking pixels or clear GIFs to collect information about your use of our Services and your response to our marketing emails. We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our services, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement. Other examples include HTML 5 cookies, Silverlight Application Storage, device fingerprints and "flash cookies. " If you want to remove flash cookies or prevent them from being placed, adjust your preferences in the Macromedia Website Privacy Settings Panel at:
www.macromedia.com/support/documentation/en/flashplayer/help
We currently do not respond to Do Not Track (DNT) signals. You may opt out of certain types of tracking,
including certain analytics and tailored advertising, by changing your cookie settings.

We also use Analytics, Advertising, Anti-Cheat and Anti-Fraud technologies in our Services that utilize the same cookies and similar mechanisms. These technologies are described below.

2.3 ANALYTICS TECHNOLOGIES

We use our own game servers and internal and third-party analytic technologies to collect information about how you use our Services, your computer or device and the health of our Services. For instance, POKS may collect and store data from your computer or device when you use our Services. This information includes technical and related information about your computer or device and operating system (such as IP Address and device ID), information about your feature usage, gameplay and usage statistics, system interactions and peripheral hardware for purposes described in Section 3, below. If you play a game offline, this data will be stored on your device and transmitted to POKS when your device connects to the Internet. If you participate in online Services, POKS also may collect, use, store, transmit and publicly display your persona and/or statistical data regarding your game play (including scores, rankings and accomplishments), or identify content that is created and shared by you with other players.

Third party analytics technologies integrated into our Services may combine the information they collect in connection with POKS Services with information they have independently collected over time and across different websites. Many of these companies collect and use information under their own privacy policies.

2.4 ANTICHEAT AND FRAUD PREVENTION TECHNOLOGIES

POKS strives to provide a safe and fair gaming environment for all players. When you log in to one of our Services, set up a POKS Account we or third parties may use cookies, device fingerprinting or game data and similar technologies to create a machine "fingerprint" or "hash" of your machine components, for fraud prevention, security and authentication purposes. We may also monitor publicly available information, third party sites and/or use anti-cheat technology with our Services, including Security Team with access to the in-game data to prevent cheating and Fraud.

HOW WE USE YOUR INFORMATION

We use your personal and non-personal information, both individually and combined together, in the following ways:

TO OPERATE OUR BUSINESS AND TO ENHANCE AND PERSONALIZEYOUR GAME EXPERIENCE INCLUDING TO:

• Operate, improve, and develop our game and Services;
• Undertaking research for technological development and demonstration;
• Help you find your friends or tell your friends about a game or Service;
• Facilitate sharing on social networks;
• Serve and measure the effectiveness of advertising;
• Measure the health of our Services;
• Detect security incidents, protect against malicious, deceptive, fraudulent or illegal
activity, and prosecute those responsible for that activity;
• Set up and maintain accounts you register for;
• Provide game experiences that you may like and set up loyalty programs;
• Identify, fix, and troubleshoot bugs and Service or functionality errors;
• Provide software updates;
• Performing audits related to interactions, transactions and other compliance activities;
• Other purposes you consent to, are notified of, or are disclosed when you provide
personal information;
• Adhere to your preferences and to deliver dynamic content; and
• Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.

TO PROVIDE YOU SUPPORT, INCLUDING TO:

• Help identify and troubleshoot problems with your account or game;
• Survey your opinions through surveys or questionnaires;
• Communicate with you and respond to your specific requests or questions; and
• Manage and send you confirmations and important information about your account,
Services, purchases, subscriptions, and warranties.

TO PERSONALIZE OUR COMMUNICATIONS WITH YOU, INCLUDING TO:

• Present offers and/or information relating to game you might like;
• Make recommendations to you; and
• Personalize advertising for you and deliver targeted marketing, service updates and
promotional offers.

We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary, for legal, operational or other legitimate reasons.

INFORMATION WE SHARE WITH THIRD PARTIES

We do not share, sell (as the term is defined under applicable privacy laws, such as the California Consumer Privacy Act), or disclose your personal information with Third Parties other than for Security Reasons (Anti-Cheating Measures).

We confirm that any third party with whom we share user data such as analytics tools, advertising networks and third-party SDKs, as well as any parent, subsidiary or other related entities that will have access to user data — will provide the same or equal protection of user data as stated in the application’s privacy policy and required by the Guidelines of Apple (https://developer.apple.com/app-store/review/guidelines/#privacy).

WHERE WE HOLD YOUR INFORMATION

Personal information we collect may be stored and processed for the purposes set out in this Privacy and Cookie Policy in Brazil or any other country in which POKS, its subsidiaries, or third-party agents operate. By using our Services, you acknowledge that your personal information may be transferred to recipients in Brazil and other countries that may not offer the same level of privacy protection as
the laws in your country of residence or citizenship.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Security of our players' information is a priority at POKS, and we take a range of measures to help protect it, including encryption of sensitive financial information. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

YOUR CHOICES AND CONTROLS
We give you meaningful choices when it comes to important uses and collection of information. For example, if you no longer wish to receive marketing emails from POKS, you may click the unsubscribe link included in the footer of every marketing email we send.

To protect your account security and personal information, you may be asked before exercising these rights to verify your account ownership, for example by reciting a code sent to the email address associated with your POKS account to a customer support representative. Once you have verified your account ownership, you may also provide your written confirmation authorizing an agent to exercise these rights for you.

Your right to deletion. You may deactivate your POKS Account or delete the personal information associated with your account by contacting support. If you do so, you will no longer have access to the POKS game or Services associated with your account. Note that POKS may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your personal information for as long as reasonably
necessary to provide you with, create, and improve our Services, and to comply with the law.
Your right to access. You can access the personal information we hold about you in a portable format by contacting support. Your right to correction. You can request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools, such as those on the POKS customer account portal.

Your right to opt out or object to certain processing. You may have the right to opt out of the sale of your personal information to third parties, if applicable, or object to some processing of your data, where such requests are permitted by law. You have a right not to receive discriminatory treatment for the exercise of the privacy rights described in this section.

SAFE AND FAIR PLAY

We consider providing a fair and secure gameplay environment a top priority. In pursuing that goal, we do not tolerate cheating or abusive behavior. We expect our players to play fairly and by the rules of the game at all times.
Misconduct with any of the practices listed below or our Terms and Conditions, will lead to penalties such as, including but not limited to, revoked in-game items, temporary game suspension and permanent game account closure.
Help us create a great gaming environment, and safeguard your account and device by keeping the following in mind while playing:

8.1 DISRUPTIVE BEHAVIOUR

We're all here to enjoy games together. Sometimes that can mean arguing with friends over bad beats and being unlucky. That's fine but being abusive towards others drains the fun from the game.

When engaging in any kind of in-game communication, we kindly ask that you are respectful of others.
Here are a few examples of that we consider inappropriate:
1. Hate speech, racism and other discriminatory language
2. Obscene or sexually explicit banter
3. Threats or harassment
4. Excessive swearing
5. Bullying

Report! If you encounter another player misbehaving towards yourself or others,
please let us know by reaching out to your respective Club host or Your Agent or
reach out to us by sending email to support@poks.poker.
Consequences of misconduct: Disruptive behavior can lead to temporary and even permanent game account closure. Making false reports just to get someone banned can lead to the same.

8.2 USE OF THIRD PARTY SOFTWARE

Third party software consists of using 3rd Party Tools that manipulate gameplay.
By altering game functionality, third party software aims to provide unfair
advantages while putting your account and privacy at risk.

Third party software includes:
1. Hacks, "mods", or programs that unfairly alter game functionality
2. "Bots", or gameplay automation services or scripts
3. Any other programs that aim to modify or provide users with information
about other users’ actions not accessible to them without using such tools

Consequences of misconduct: Trying to gain an unfair advantage by using
prohibited 3rd party software will result in a permanent ban for any offending
account(s).

8.3 UNAUTHORIZED IN-APP BUYING/SELLING

Certain websites and individuals might offer cheaper in-app products. Don't be fooled - it's a scam.

Such services request private login data (such as your POKS, ID, Apple ID, Google Play credentials, etc) in order to access your game account. These vendors will gain access to your account and oftentimes, hijack the account and try to use your chips and account to cause you harm.

IMPORTANT: If you release your private information/credentials to 3rd parties, you're permanently placing your game and financial/online security in a high-risk situation.

Consequences of misconduct: Purchasing gems or diamonds from 3rd party vendors can lead to revoked in-app items and can even get your account permanently banned.

8.4 BUYING, SELLING AND SHARING GAME ACCOUNTS

Selling, buying, sharing or giving game accounts other players is against our User Agreement and never endorsed by POKS.

Consequences of misconduct: We cannot guarantee the security of any account that has been passed from one player to another; we reserve the right to permanently ban any account that has been transferred between players.

8.5 OTHER UNACCEPTABLE BEHAVIOUR

1. POKS Staff impersonation
2. Phishing other players' accounts
3. Refund abuse
4. Knowingly exploiting a bug
5. Encouraging others to break the rules
6. Asking for or providing personal contact information
7. Misuse of in-game chat for Advertising, Spamming & Scamming

HOW WE ENFORCE FAIR PLAY

Whenever we can, we aim to prevent cheating and disruptive behavior in our game e.g. we implemented systems that proactively prevent players from using inappropriate language and/or 3rd party software. Where we cannot implement preventative methods, we use a mix of automated and manual review systems. To achieve a fair playing field for every player, we aim to enforce all rules equally to everyone. While much of our systems are automated, we also employ trained moderators who focus on leaderboards, tournament participants and community sourced reports. If you feel like you have received an unjustified penalty, please contact support and we will review your case.

Our Customer Care contacts: support@poks.poker

CHANGES TO OUR POLICY

We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our home page (www.poks.poker) effective immediately. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this policy.

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