Our Commitment to Our Players’ Privacy. We are the owner and operator of the application called “Play Along” which is made available to you for download from the Google Play store on the Android platform and the Apple App Store on the iOS platform (the “Application”). We are committed to maintaining the confidentiality of the personal information collected by us by utilising ‘best in class’ information security technology and procedures, all in accordance with European Union standards of data protection and the requirements of our gambling regulatory authorities.
Our Legal Obligations. We will comply with the terms of the Isle of Man’s Data Protection Act 2002 (the “Act”) when processing your personal information. Your personal information may be also processed by us, other members of our group of companies, our affiliates, our agents and third parties providing services to us, in jurisdictions outside of the Isle of Man and the European Economic Area. In this event we will comply with the terms of the Act which ensure that personal data is only transferred to such jurisdictions which comply with the various ‘adequacy’ requirements for data protection set out in the Act.
2. What Information Must You Give Us and For What Purpose
2.1Details Provided on Opening the Application. If you open the Application via your Facebook account, you will be asked to click the “Allow” button (the “Request for Permission”) which will enable us to access certain personal information from your Facebook profile. The information you allow us to access is affected by the privacy settings you and your friends chose with respect to your Facebook accounts. Accordingly, we may access and store any of the following information regarding you: your Facebook user ID, name, login e-mail you provided to Facebook, gender, birthday, current city, profile picture and a list of your Facebook friends. If you open the Application via a guest account, you will not be asked to provide any personal information at this initial stage but please note that you may still be required to provide certain personal information should you wish to redeem your “chips” earned via the Application.
2.1Details Provided on Redemption of Chips. If you wish to redeem your “chips” earned via the Application and receive a ticket enabling you to enter into a freeroll on the applicable Site, we will ask you to provide us with either your email address or your PokerStars username, depending on whether you already have an account on the applicable Site.
2.1Changes to Personal Information. You must advise us of any relevant changes to your personal information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personal information that you have provided to us.
2.1Ongoing Data Capture. In addition, when you use the Application we capture and store certain personal information, including information on your activity on the Application and information held on the Devices (defined below) or systems that you use, to allow us to enhance the services that we provide to you. We also use ‘cookies’ and our ‘cookie’ policy is explained below.
2.1Purposes. We, members of our group of companies, our affiliates and third parties providing services to us or to you on our behalf will use your personal information for the purpose of conducting our business and providing services to you. Specifically, this includes the following purposes, but we also reserve the right to use your personal information for any other purposes that are reasonably ancillary to the business of providing you with electronic gambling services:
- to confirm financial transactions;
- to analyse your credit and fraud risk and verify your credentials using third parties, including financial institutions, identification verification agencies and credit reference agencies;
- to provide services to you;
- identification and vetting purposes;
- statistical analysis and research;
- research and development;
- marketing, market research and customer profiling;
- data analysis; and
- to comply with licensing and regulatory requirements.
3. Information Sharing, Disclosures and Recipients
3.1Specific Disclosures. We may disclose your personal information as follows:
- to any recipient if required to do so by law or by regulatory authority;
- to any regulatory body or licensing body or authority;
- to third parties who provide services to us or on our behalf;
- to any payment management or debt collection company engaged by us to handle payment and collection processes to and from our users;
- to any third party that purchases us or our business or any part of us or our business;
- to credit reference agencies;
- if we believe in good faith that such action is necessary:
- to comply with any law or comply with legal process served on us;
- to protect and defend our rights or property;
- with your consent;
- for the purposes of disaster recovery; or
- as set out in Section 5 below.
General Disclosures. In addition to the specific examples of disclosures listed above we may disclose your personal information to our employees, employees of other companies in our corporate group, our agents and to third party service providers who use your personal information to provide services to us in respect of your being a user of the Application and/or a user with PokerStars (if applicable).
Disclosure on the Application. Please note that in the event that you have opened the Application via your Facebook account, your Facebook name and profile picture may appear on the Application leader board which is visible to other users of the Application.
5. Limits of Confidentiality
5.1Legally Required Disclosures. Due to the legal, regulatory and security environment in which we operate, PokerStars may be required, under certain circumstances, to disclose personally identifiable information about you and we may not be permitted to inform you that we have done so. PokerStars will use reasonable endeavours to limit such disclosure to the following: (a) where PokerStars believes in good faith that it is required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce PokerStars’ rights. Further, we can, and you authorise us to, disclose your user identification, name, street address, city, county, post code, country, phone number and email to third party agents of PokerStars or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.
6. Direct Marketing
6.1We may use your email address for the purpose of providing you with news, promotions and other marketing offers (including where our group companies provide such communications on our behalf) if you have provided us with your consent to such use. You may opt-out of receiving these communications by following the ‘opt-out’ instructions included in each such communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications from us and you may do this by emailing us at: firstname.lastname@example.org. If you request not to receive marketing communications from us, we will remove your details from our marketing distribution lists and from any future lists that we may share with third parties. However, you will need to unsubscribe separately from marketing communications sent by third parties who have previously received your contact details from us, in addition to your request to be removed from our lists.
6.1Publicity. We will only use your name in publicity materials with your consent.
7. Your Rights in Relation to Your Information
7.1We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered or corrected in accordance with your rights under the Act. In this event we may require evidence of your identity. To contact us regarding your information please email email@example.com. We may in certain circumstances levy a small charge to cover the cost of administration regarding any request made by you in this regard.
8.1Cookies are text-only strings of information that are downloaded to your mobile device (a “Device”) when you visit the Application. Please see www.allaboutcookies.org for information about what cookies are and what they do.
9. Further Information
9.1We are happy to provide you with further information on how we protect and use your personal information. Please contact us at: firstname.lastname@example.org. You can also obtain much useful information on data protection and privacy from the office of the Isle of Man Data Protection Supervisor at: www.gov.im/odps.