POKERGO® PRIVACY POLICY
Last Revised: January 4, 2023
INTRODUCTION
Your privacy is important to us. This Privacy Policy governs the collection, use, and disclosure of your Personal Data as explained below in connection with any websites, mobile websites, online video services, applications, or other services owned or operated by PokerGO® (“we” or “us”), including, without limitation, the websites currently located at www.pokergo.com and www.pgt.com and any mobile versions of the websites as well as the PokerGO® subscription product and other services we provide.
By using the websites and services we control, you consent to:
Residents of Europe
If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom and are protected by European data protection requirements, we will refer to you in this Privacy Policy as a “European resident” and treat your Personal Data in compliance with the European Union’s General Data Protection Regulation and/or the United Kingdom’s Data Protection Act (as applicable, and collectively referred to herein as “GDPR”). Please see information below applicable to European residents.
CONTENTS
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. JURISDICTION
11. CONTACT US
__________________________________________________________________________________________
1. IMPORTANT INFORMATION AND WHO WE ARE
This Privacy Policy aims to give you information on how we collect, process, and disclose your Personal Data. This policy only applies to the Personal Data we process in our role as a data controller. If we process Personal Data as a data processor, separate arrangements exist with respect to such processing and those arrangements are outside the scope of this Privacy Policy. This Privacy Policy also does not cover our privacy practices with regard to Personal Data we receive from or about job applicants, employees, contractors, or their dependents or beneficiaries.
Our sites and services are not intended for individuals under 18 years of age and we do not knowingly collect data relating to children, or direct marketing at children. If we become aware that we have inadvertently received Personal Data from a child under the age of 18, we will delete such information from our records.
It is important that you read this Privacy Policy together with any other Privacy Policy or disclosures we may provide on specific occasions when we collect or process Personal Data about you so that you are fully aware of how and why we use your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Controller
Poker Central LLC dba PokerGO® is the data controller with respect to the Personal Data described under this Privacy Policy.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our Privacy Policy under regular review and may modify this policy from time to time. If we make any changes to this Policy, we will post the amended terms and change the "Last Revised" date above.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Third Party Links
The websites and services may include links to third party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites or services, we encourage you to read the Privacy Policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal Data, or personal information, means any information about an individual from which that person can be identified (directly or indirectly) or to which the person can reasonably be linked. It does not include Anonymized Data (as explained below).
We may directly or indirectly through our service providers collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together as follows:
We also collect, use, and share Anonymized Data such as statistical, demographic, aggregated, deidentified, or technical data for any purpose. Anonymized Data could be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate Internet and Other Network Data to calculate the percentage of users accessing a specific website or service feature. However, if we combine or connect Anonymized Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which we use in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offenses.
Cookie Policy
We may automatically collect information using "cookies," which are small files placed on your hard drive that may uniquely identify your browser and collect certain information about you. Among other things, cookies help us analyze our web page flow, customize our site and services, measure promotional effectiveness, and promote trust and safety. Certain features are only available through the use of cookies, and generally we need to use cookies to help identify you and maintain your signed-in status. You are always free to decline cookies via your browser settings, although doing so may interfere with your use of the site or services. You may accept or decline the use of any cookies that are not essential for the functioning of the site or services.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this could affect certain features of our Service. For further information about cookies, please consult your browser’s help menu.
The following is a list of the cookies that may be used and installed on your computer or device depending on your engagement with our sites or services:
Cookie Name |
First-Party or Third-Party? |
If Third-Party, who? |
If Cookie, how long does it reside on device? |
Essential? |
Purpose |
unifiedDashboardAuth |
Third Party |
JW Player |
Session |
Yes |
Video Player |
_ga |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_ga_L9VNY0RY8L |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_fcdscst |
Third Party |
JW Player |
Session |
Yes |
Video Player |
_uetvid |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_gid |
Third Party |
JW Player |
1 month |
Yes |
Video Player |
_fbp |
Third Party |
JW Player |
3 months |
No |
Video Player |
_mkto_trk |
Third Party |
JW Player |
2 years |
No |
Video Player |
_biz_nA |
Third Party |
JW Player |
1 month |
Yes |
Video Player |
_biz_uid |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
OptanonConsent |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_biz_flagsA |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_biz_pendingA |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
_uetsid |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
OptanonAlertBoxClosed |
Third Party |
JW Player |
1 year or until user clears |
Yes |
Video Player |
optimizelyEndUserId |
Third Party |
JW Player |
6 months |
No |
Video Player |
locale |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
docs.prefs |
Third Party |
Stripe |
1 year or until user clears |
Yes |
Website experience optimization |
user |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
recent-views |
Third Party |
Stripe |
1 year or until user clears |
Yes |
Website experience optimization |
merchant |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
lang |
Third Party |
Stripe |
1 year or until user clears |
No |
Website experience optimization |
site-auth |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
cid |
Third Party |
Stripe |
Session |
No |
Website experience optimization |
stripe.csrf |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
session |
Third Party |
Stripe |
Session |
Yes |
Website experience optimization |
private_machine_identifier |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Link to Credit Card Payment gateway |
__stripe_orig_props |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Link to Credit Card Payment gateway |
machine_identifier |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Credit Card Payment Gateway |
__stripe_mid |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Credit Card Payment Gateway |
_gcl_au |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Credit Card Payment Gateway |
_ga |
Third Party |
Stripe |
2 years or until user clears |
Yes |
Credit Card Payment Gateway |
at_test |
First Party |
PokerGO® |
Session |
No |
Marketing Purposes |
__smToken |
First Party |
PokerGO® |
1 year |
No |
Marketing Purposes |
__smVID |
First Party |
PokerGO® |
1 month |
No |
Marketing Purposes |
_fbp |
First Party |
PokerGO® |
3 months |
No |
Marketing Purposes |
__smListBuilderShown |
First Party |
PokerGO® |
Until user clears |
No |
Marketing Purposes |
_ga |
First Party |
PokerGO® |
2 years |
No |
Marketing Purposes |
__qca |
First Party |
PokerGO® |
1 year |
No |
Marketing Purposes |
_gid |
First Party |
PokerGO® |
1 year |
No |
Marketing Purposes |
Please consult the privacy policies of the sources of these cookies for additional information regarding their collection, use, and disclosure of Personal Data. Also note that Session cookies expire at the end of each browser session.
Google Analytics
We use a web analytics tool from Google called "Google Analytics" that uses cookies to help us understand how you use the websites. The information generated by the cookies will be transmitted to and stored by Google on servers in the United States. Google Analytics does not provide us with any Personal Data. It tells us things like how users arrived at our websites, if users have visited before, how long users stay on the websites, and which pages on the websites users have visited. It can also provide us with general information about where in the world a user may be located. This information is anonymized or deidentified and not tied by us to individual visitors. To learn more about Google Analytics and your privacy, visit http://www.google.com/analytics/learn/privacy.html.
Our sites have integrated the Facebook pixel that allows us to better understand how effective our advertising campaigns are. If you are a European resident, we will obtain your consent before sending the Facebook pixel signals to Facebook. Any Personal Data obtained by Facebook as a result of the Facebook pixel will be subject to Facebook’s privacy policy.
Single Sign-On
If you sign-in to our sites or services using a feature like Facebook, Google, or Apple single sign-on, the applicable third-party company may receive Personal Data and process it subject to their privacy policy. These third-party companies may also share your Personal Data with us. We are not responsible for data collection, use, or disclosure by these third-party companies.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or need it to fulfill our obligations under a contract or prospective contract with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case.
4. HOW WE USE YOUR PERSONAL DATA
We use Personal Data in connection with our business operations when the law allows us to. We will use/process Personal Data for the purposes outlined in this section. Our processing of your Personal Data may require sharing it with third parties in order to accomplish the stated purpose.
Purposes for which we will use your Personal Data
“Legitimate Interest”, for processing of European residents’ data, means the interests of our business in conducting and managing our business to enable us to give you the best sites and services possible and protect our reasonable business concerns. We make sure to consider and balance any potential impact on you (positive and negative) and your rights under applicable law before we process Personal Data of European residents for our Legitimate Interest. We do not process the Personal Data of European residents for our Legitimate Interests if we determine that our interests are overridden by the impact on your rights (unless we have consent or the processing is otherwise permitted by law). If you are a European resident and would like more information about how we assess our Legitimate Interests, you may contact us.
If you are a European resident and the lawful basis for processing your Personal Data is consent, we will obtain consent from you prior to processing your Personal Data for the purpose for which consent is required and you may revoke your consent at any time by contacting us using the contact information below.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose after we have acquired your Personal Data, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your Personal Data with service providers, including affiliated entities, for any of the same purposes for which we may use or process your Personal Data. We do not allow our service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. During the past twelve months, we shared each of the categories of Personal Data identified in Section 2 with one or more service providers.
The types of service providers we use to whom we may share one or more categories of Personal Data include:
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may also share Personal Data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or to businesses controlling, controlled by, or under common control with us. If a change happens to our business, and you are a European resident, then the new owner of your Personal Data may use your Personal Data in the same way as set out in this Privacy Policy.
Please be aware that Personal Data you share publicly such as via a social media account linked to your use of our services or in public-facing areas of our services will be visible to other users and may be collected by them. We are not responsible for, and this Privacy Policy does not apply to, the collection of your Personal Data by any third party.
We do not sell Personal Data to third parties for their use in marketing their own products or services to you or for any other purpose.
6. INTERNATIONAL TRANSFERS
Your Personal Data will be processed in the United States of America.
If you are a European resident, whenever we transfer your Personal Data out of the EEA we ensure that we have your consent or adequate safeguards are in place as required by the GDPR by either (i) transferring your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission or (ii) using standard contractual clauses approved by the European Commission which give Personal Data a similar amount of protection as it has in Europe, including additional safeguards as needed. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
By providing Personal Data to us, you consent to the transfer to and processing of your Personal Data in the United States. Please note that the laws of the United States provide less protection for Personal Data compared to the laws of the EEA.
7. DATA SECURITY
We have put in place reasonable security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach when we are legally required to do so.
8. DATA RETENTION
We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or regulatory inquiry in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. YOUR LEGAL RIGHTS
Depending on your location you may have additional legal rights related to your Personal Data. We will never discriminate against any person for exercising their legal rights with regard to their Personal Data.
European Residents
Your Rights
If you are located in the EEA, Switzerland, or the United Kingdom, under certain circumstances, you have rights under data protection laws in relation to your Personal Data. You have the right to:
Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data when there is no legally valid reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data when you have successfully exercised your right to object to processing (see below), when we may have processed your information unlawfully, or when we are required to erase your Personal Data to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data when we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it infringes your fundamental rights and freedoms. You also have the right to object when we are processing your Personal Data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to Personal Data that you provided to us.
Withdraw consent at any time when we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain sites or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at:
Email address: [email protected]
Postal address: 3993 Howard Hughes Parkway, Suite 450, Las Vegas, Nevada 89169, United States of America
No fee usually required
You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints or Concerns
You have the right to make a complaint at any time to the supervisory authority for data protection issues in country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our sites and services do not respond to “do not track” signals.
10. JURISDICTION
We are a company located in the United States. All matters relating to privacy issues are governed by the laws of the United States. Nothing in this policy will be construed as an admission that we are subject to the laws or jurisdictions of any national or international jurisdiction or governmental entity, or to non-US law.
11. CONTACT US
If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at the contact information below:
PokerGO®
Attn: Privacy
3993 Howard Hughes Parkway
Suite 450
Las Vegas, Nevada 89169