1.INFORMATION WE COLLECT

1.1.We collect the following types of information.

• (a) Information provided to us directly from the Services whether submitted by you or others;
• (b) Your username, password and e-mail address when you register for a PokerNex account;
• (c) Profile information that you provide for your user profile (e.g., first and last name, picture, phone number, gender, age or birthday, profile photo, game username, approximate physical location information, links to your profiles on various social networks etc). This information allows us to help you or others be “found” on PokerNex;
• (d) User Content (e.g., all the data that you upload, transmit, create, or generate on or through the use of our Services. This includes things like your profile picture, your in-game text or video chat, and your in-game art or other content authored or designed by you);
• (e) Communications between you and PokerNex. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.

1.2. In some circumstances it may be necessary for us to collect information from a third-party source. If you play PokerNex or connect our Services to any third-party applications, including social networks like Facebook, PokerNex may receive certain information about you from the provider of the third-party application. The information we receive depends on your privacy settings and, if applicable, your friends’ privacy settings on that third-party application. For example, PokerNex may collect and store some or all of the following information shared by the provider of the connected third-party application:

• (a) your profile picture or its URL;
(b) your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
• (c) the user ID number and other public data of your friends;
(d) the login e-mail you provided to that third-party application when you registered with it;
• (e) your gender;
• (f) your birthday;
• (g) whether you like our Facebook page; and
• (h) any other information that you or the provider(s) of the third-party application share with PokerNex. If you access/connect to our Service(s) to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy. If you are unclear about what information a third-party application is sharing with us, please approach the third-party application’s customer care to find out more about their privacy practices.

1.3.Payment Information

• (a) PokerNex may obtain the billing and payment information that you provide when your purchase is processed by our payment partners. Our Terms of Service explain our policies and conditions relevant to our charges, billing practices and Virtual Items.
• (b) If you purchase Virtual Items in the PokerNex, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.
• (c)PokerNex does not collect or store your financial information, like credit card numbers. However, PokerNex’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfill your order.

1.4.Cookies and Automated Information Collection

• (a)PokerNex and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as “cookies” to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of PokerNex’s Service, tailoring recommendations to interests, and making the Service easier to use.
• (b)Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting a cookie from the websites you visit or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. If you do not accept cookies, however, you may not be able to use all features, portions or functionalities of the Service.
• ©We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
• (d)We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.
• (e)We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently and effectively by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.
• (f)We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:
  • (i)the type of device you are using;
  • (ii)your operating system version;
  • (iii)your location;
  • (iv)your IP Address;
  • (v)your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
  • (vi)your browser types;
  • (vii)your browser language;
  • (viii)referring and exit pages, and URLs;
  • (ix)platform type;
  • (x)the number of clicks on a page or feature;
  • (xi)domain names;
  • (xii)landing pages;
  • (xiii)pages viewed and the order of those pages;
  • (xiv)the amount of time spent on particular pages;
  • (xv)game state and the date and time of activity on our websites or games. In some cases, we will connect this information with your social network ID or PokerNex user ID.

1.5.Log file information

• (a)Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
• (b)When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

1.6.Device identifiers

• (a)When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by PokerNex.
• (b)A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

1.7.Metadata

• Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

2.HOW WE USE YOUR INFORMATION

2.1.We use your information under several legal basis, including to establish and perform our contract with you, for our legitimate interests, to comply with our legal obligations, to establish, use and protect PokerNex’s rights, or otherwise with your consent.

2.2.The main use of the information we collect and store is to provide our Services and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

• (a)to operate, improve and optimize our Services and our users’ experiences;
• (b)to create your game accounts and allow you to play our games;
• (c)to identify and suggest connections with other PokerNex players and personalize our Services to you;
• (d)to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
• (e)to enable users to communicate with each other;
• (f)to provide technical support and respond to users’ inquiries;
• (g)to protect the safety and well-being of our users;
• (h)to protect PokerNex’s rights and property in connection with our Services;
• (i)to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
• (j)to manage and deliver contextual and behavioral advertising;
• (k)to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• (l)to comply with our legal obligations, resolve any disputes we may have with you or other users, and to enforce our agreements with third parties; and/or
• (m)to conduct research.

2.3.One important use of your information is communication. If you have provided your e-mail address to PokerNex, we will use it to respond to Customer Support inquiries, and keep you informed of your in-game activity, including messages from friends, let you know about in-game status and promotions. Some messages, like private messages to friends, may include your name and profile photo. We may also send promotional e-mail messages (“Promotional Communications”) directly, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages. Receipt of such communications depends on PokerNex having certain contact information from you.

3.SHARING OF YOUR INFORMATION

3.1.We may disclose or publish aggregated information (information about you and other players collectively that is not intended to specifically identify you and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

3.2.Parties with whom we may share your information:

• (a)We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that PokerNex is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences);
• (b)We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”), including but not limited to processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms. We contractually require these Service Providers to maintain the confidentiality of the information we share with them, and we contractually require them not to use your information for anything other than to provide services on our behalf;
• (c)We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you;
• (d)We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information;
• (e)Any other users will see your game profile if you are playing at the same table or if they are watching a replay of a poker hand you participated in.

3.3.Parties with whom you may choose to share your User Content

• (a)Any information or content that you voluntarily disclose to us, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set;
• (b)If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the PokerNex API have copied or saved that information.

3.4.What happens in the event of a change of control

In the event that PokerNex undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know of the business transition before transferring your personal information.

3.5.Responding to legal requests and preventing harm

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

4.HOW WE STORE YOUR INFORMATION

4.1.Your information collected through the Service may be stored and processed in any country in which PokerNex, PokerNex Affiliates or Service Providers maintain facilities.

4.2.PokerNex, its Affiliates, or Service Providers, to the extent permissible by the applicable law, may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Hong Kong law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

4.3. By registering for and using the Service you consent to the transfer of information to any country in which PokerNex, PokerNex Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

4.4.We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, PokerNex cannot ensure the security of any information you transmit to PokerNex or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

4.5.You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and PokerNex, at all times. Your privacy settings may also be affected by changes the social media services you connect to PokerNex make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization. While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.

5.YOUR CHOICES ABOUT YOUR INFORMATION

5.1.Your account information and profile/privacy settings

• (a)Update your account at any time by logging in and changing your profile settings.
• (b)By clicking on the Unbind Email Button, we will not send further email communications.

5.2.Managing your information with us

If you want to review, delete, or change the information PokerNex has about you or have additional questions,you may send an e-mail to care@pokernex.net

5.3.Stopping Use of Your Information

If you no longer want PokerNex to make active use of your information, you may send an e-mail to care@pokernex.net Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.

5.4.Managing your information with third-party applications

You will need to follow the instructions from the third-party application for updating your information and changing your privacy settings. Once PokerNex receives your information from a third-party application or your mobile device, that information is stored and used by PokerNex in accordance with this Privacy Policy.

5.5.How long we keep your User Content:

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. Following termination or deactivation of your account, PokerNex, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, audit and/or legal purposes.

6.CHILDREN’S PRIVACY

We do not knowingly collect, use or share any personal information about children (generally, under the age of 16 or depending on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.

7.OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another application, website or service, our Privacy Policy does not apply to those third-party application, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party application, website or service, you should consult their privacy policy before providing any personal Information and if you allow them to access your User Content you do so at your own risk.

8.DATA PROTECTION

• 8.1.PokerNex has encrypted and stored players’ data, and will not process them.
• 8.2.We will not distribute any users’ data to third party organizations and will not use the data for any commercial purposes.
• 8.3.PokerNex has made reasonable technical and organizational measures designed to secure your information both online and offline from accidental loss and from unauthorized access, use, alteration or disclosure, and we are committed to the protection of customer information. We will take reasonable steps to ensure that your data is treated securely and in accordance with our Privacy Policy.
• 8.4.Also please note that email and messaging systems are not considered secure, so PokerNex discourages you from sending PokerNex personal information through these media. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use.

9.ACCOUNT DELETION

9.1.PokerNex has a feautre that allows users sto delete their account. In order to do so, please follow the steps listed below:

• 1.Quit from all the Clubs your account belongs to.
• 2.Tap your avatar in the top left corner of the app's main screen.
• 3.Select Account Deletion.
• 4.Enter your PlayerID and press Continue.
• 5.Enter and then re-enter your password. Press the Continue button
• 6.Read the warning and confirm your decision withe the checkbox next to it. Then press the Continue button again. Remember that this action is irreversible. Once the account is deleted, it's impossible to restore it. Login information (email address and password) associated with deleted Player account will be removed immediately. Operational records such as playing history (betting, call, fold, raise, etc) will be removed in 6 days after the account deletion. No information is retained past the day period.

10.HOW TO CONTACT US ABOUT A DECEASED USER

In the event of the death of an PokerNex User, please contact us. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.

11.HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us by sending email to care@pokernex.net All notices given by you or required from you under this Privacy Policy shall be in writing and addressed to: care@pokernex.net

12.CHANGES TO OUR PRIVACY POLICY

PokerNex may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of PokerNex or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.