Poker Club HQ Privacy Policy

Effective Date: October 6, 2024

Poker Club HQ (“Poker Club HQ,” “we,” “us” or “our”) develops software for planning and running poker tournaments for poker clubs and leagues.

This Privacy Policy explains how we collect, use, and share the personal information that we gather when you use our applications (“App(s)”), any websites operated by Poker Club HQ, that link to this Privacy Policy (“Sites”), and all other products, services, events, or interactive features operated by Poker Club HQ (collectively, with Apps and Sites, “Services”).

Please click the following links to learn more about our Privacy Policy:

1. Information We Collect

Information You Give Us

You may give us information by signing up for an online account, entering information through our online forms or surveys, inputting information while using our Services, contacting us through a chat service, or contacting us by phone or email for information or customer service.

The categories of information include:

The categories of sensitive information include:

Information We Automatically Collect

We also may collect certain information automatically when you access our Services, including:

Information We Collect from Third Parties

If you access our Sites through third parties (e.g., Facebook or Google), or if you share content from our Services to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

2. How We Use Your Information

We may use information that we collect through our Services for a variety of purposes, including to:

Marketing

We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

3. How We Share Your Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may disclose the information we collect. We disclose your personal information in the following instances:

In addition, we may allow third parties to place and read their own cookies, web beacons and similar technologies to collect information through the Services. For example, our third-party service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics.

External Service Providers

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

4. Security & Retention

We maintain a variety of security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information you provide through our Services. However, no data transmitted over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction or inadvertent disclosure of your information.

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

Data Deletion Requests

We delete your data upon request. To submit a request to delete your data, please email us at support@pokerclubhq.com. We will respond promptly to each request.

5. How We Respond to “Do Not Track”

Do Not Track (“DNT”) is a web browser setting that requests a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. However, because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. You can learn more about Do Not Track here.

6. Cookies

To make our Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy.

Google Analytics

We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Sites may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

7. Children’s Privacy

Our Services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16 unless we have received sufficient parental consent. If you become aware that a child has provided us with personal information without sufficient parental consent, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with personal information without sufficient parental consent, we will take steps to delete such information.

8. International Transfers of Information

Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail the transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally.

9. Privacy Rights & Additional Disclosures for EEA & UK Individuals

If you are a resident of or located within the European Economic Area (EEA) or the United Kingdom (UK), you have the right, under certain circumstances, to:

Legal Bases for Processing Personal Information Under the GDPR

If you are from the EEA or UK, Poker Club HQ’s legal bases for collecting or processing your personal information are as follows:

In some limited cases, we may also have a legal obligation to collect Personal Data from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.

Right to Lodge a Complaint

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

Exercising Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

10. Privacy Rights & Additional Disclosures for Brazilian Individuals

If you are located in the national territory of Brazil, you have certain additional data protection rights. These rights include:

Legal Bases for Processing Data Under the LGPD

Poker Club HQ’s legal bases for collecting or processing your personal information are as follows:

Duration of Processing

Poker Club HQ will process and retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Poker Club HQ will also retain personal information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.

Exercising Your Rights Under the LGPD

If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Information section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days.

11. Privacy Rights & Additional Disclosures for Certain U.S. Residents

Several states within the United States grant their residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at legal@pokerclubhq.com.

Request for Information

Residents of certain U.S. states have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

In addition, you may have the right to request we delete your personal information.

Request for Correction

Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.

Request for Portable Data

Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information

Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s personal information for targeted or personalized advertising. We do not sell your personal information, nor do we share your personal information for targeted or personalized advertising.

Limiting the Use of Sensitive Personal Information

Residents of certain U.S. states have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and Services to you, or as otherwise minimally permitted under applicable law.

Third Party Marketing

If you are one of our customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. However, we do not disclose your personal information to third parties for the third parties’ direct marketing purposes.

Automated Processing & Profiling

Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price

You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights

To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process

If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

12. Change of Control

Your information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal information.

13. Policy Updates

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the policy in the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change.

14. Contact Information

If you have any questions about this Privacy Policy, please contact us at:

Email: legal@pokerclubhq.com