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PRIVACY NOTICE

We at Youda Games Holding B.V. (“GoP 3”, ”we”, ”us” or ”our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (”Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, ”Personal Data”) when you play our games that are part of our gaming platform. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you play Governor of Poker 3 (”Services”). In the General part of this Privacy Notice, we generally use the term ”Services” for the respective game, the game’s website or app. However, if certain processes apply only to your use of the game’s website (without accessing the game), we refer to the respective website as ”Service Website”.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes that specifically apply to a certain Service.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities on the respective Service, please see the specific information below.

Who is responsible for the processing of your Personal Data?

Youda Games Holding B.V., Boeing Avenue 30 1119 PE, Schiphol-Rijk, The Netherlands is responsible (the data controller) for the processing of your Personal Data in Governor of Poker 3.

What types of Personal Data do we process and how do we collect it?

When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to

provide any” special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation. The information we collect depends on which of our Services you use and how you use them. We may process the following types of your Personal Data:

Personal Data provided by you

When you use our Services, you may provide or be asked to give us certain information, including:

Age: When you use our Services for the first time or sign up for an account, we ask you to enter your age for the purposes described below.

 

Your account information: In order to use our Services, you need to create an account. This will also allow you to use our Services on different devices. When you create your account, we collect your log-in data (your nickname/avatar name and/or your email address and password) and may collect additional profile information (entry of this information is entirely voluntary and not necessary to sign up for an account. You can edit or delete your profile information at any time) provided by you to personalize your profile (such as your first name, your selection of the avatar’s gender, and your avatar). This information will be combined with your account ID. Please note that you can use our Services as a visitor. In that case, we do not ask for an email address, we only require your nickname and device identifier which will be combined with your account ID.

 

Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details.

 

Personal Data we receive or generate from your use of our Services

When you use our Services, we may also process device-related information and information about how you interact with our Services, including:

Technical information: We collect information about your device/device settings and combine this information from different devices you use for the purposes described below. The information we obtain from your device(s) includes the type of your device, online identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address), browser settings, screen resolution, battery status, free storage, and other technical information.

 

Cookie data: As further described in our Cookie Policy (”Cookie Policy”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Policy.

 

Your usage: We collect information about how you use our Services. This information includes the actions you take within the game (e.g. if you win or lose a game, your achievements (such as the level reached), the items purchased within our Service, the amount you spent in the game, your friend list), the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Service. Part of this information will be stored in your account (such as your friends list and your progress).

 

Personal Data we collect from third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:

Payment Providers: If you make an in-app or website payment, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any specific financial information (such as the payment option used or your credit card information) but may receive information which is related to your transaction, for example the payment status and payment date.

 

Social Networks and connected third-party platforms: If you choose to connect our Service with your e.g. Facebook, Apple, Plinga, Google, Microsoft, Steam, Samsung Galaxy or Huawei account by using your e.g. Facebook, Google, Microsoft, Steam, Samsung Galaxy or Huawei credentials within our log-in process, we may receive certain information about you like e.g. your name, you profile picture, your email address, and your friends list. If you enter our Services from a third-party platform (Plinga, Apple, Facebook, Microsoft Store, Huawei Appgallery, Samsung Galaxy Store, Steam or Google), and you have created an account on the third-party platform or connected your game account with that platform, your username and your avatar may be shared with us to create your Service account. Furthermore, the third-party platform provider may share with us e.g. the platform ID, the avatar url, your email address, and your friends list. To manage the information we receive about you from a third-party platform where you receive our Services (Plinga, Facebook, Apple, Microsoft Store, Huawei Appgallery, Samsung Galaxy Steam or Google), you will need to follow the instructions for each such third-party platform for updating your information and changing your privacy settings. Any personal data that will be processed by that third-party platform are subject to that third-party platforms’ terms of service and privacy policy.

 

User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about installs of our Services, your country and language, and technical identifiers (Advertisement Device ID) from our user acquisition partners.

 

Other third parties: We may also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google).

 

We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

To learn more about which data is processed when you use a certain Service, please see the section with service specific information below.

For what purpose do we process your Personal Data?

Depending on which Service you are using and which privacy settings you have selected, we may process your Personal Data for the following purposes:

Provision and improvement of our Services

to allow you to use our Services

 

to facilitate in-game communication via chat or web forum to create and manage your account

 

to restore your account if you ever lose access

 

to communicate with you in context of account activation and password management, to simplify the registration process

 

to facilitate your purchase, to verify and confirm your payment to facilitate content sharing on social networks

 

to provide technical support and respond to your requests

 

to identify and correct any bugs/errors

to indicate the popularity of our Services to assess the quality of our Services

 

to understand and improve your online experience

 

to pay our business partners for the promotion of our Services

 

to understand usage of our Services across all our group companies to support strategy and growth

 

Personalization of your game experience

to remember your preferred game settings

to remember you next time you visit one of our Services

to show you more engaging in-game promotions and offers

 

Marketing and analytics

to deliver (targeted and non-targeted) advertising in our Services

 

to show you advertisements for our Services on other websites or apps

 

to measure the effectiveness of advertising

to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers

 

to acquire new users on social media platforms

 

Prevention of fraud and illegal activity

to investigate fraud and illegal behavior in our Services and reporting it to relevant authorities

 

 to enforce our policies and Terms of Use

 

Compliance with our legal or regulatory obligation

to determine the legal requirements for processing of your Personal Data (based on your location and your age)

 

to maintain records related to purchases

 

to respond to your requests related to your data subject rights

 

to comply with our legal obligations (e.g. tax and accounting obligations) to inform you about any changes to this Privacy Policy

 

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data per Service.

Do we engage in profiling activities?

We may use tracking mechanisms to track your Personal Data for profiling purposes. Profiling means any form of automated processing of Personal Data to evaluate certain personal aspects relating to you. This includes the creation of user segments, based on, for example, your in-game behaviour (e.g. your in-game purchase activity, how often you share our Service on social media platforms, the level you reached in the game). For specific information about the user segments we create, see the section with service specific information below. This helps us to find new users for our Services, based on the information we have about you, and to target users who were already interested in our Services on websites or in apps of our business partners. Our Services use the ”Lookalike Audience” and ”Custom Audience” remarketing features of Facebook Inc. (Facebook) and Snap Inc. (Snapchat). This allows us to find new users on Facebook and Snapchat who are likely to be interested in our Services. Learn more about the Lookalike and Custom Audience features in the service specific section below. You have the right to object to this type of processing. You can also go to your in-game settings to review and amend your privacy choices related to this type of processing at any time.

On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in the context of personalized advertising and remarketing. We may also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-game settings. Please note that this will not affect any processing carried out before you withdraw your consent.

 

Performance of a contract: We process your Personal Data for the performance of a contract to which you are party, for example, where it is necessary for the creation and administration of your account, to process your in-game purchase and the associated payment, to support the operation of our games or facilitate the delivery of requested services.

 

 Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.

 

Legitimate interests: We may also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the Service provided to you, to provide you with a better user experience or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services.

 

Please see for additional information the section with service specific information below.

With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorized to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we may disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

External service providers: We may share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, data management services, user notification and marketing services, analytics services and forum hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.

 

Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.

 

Payment providers: If you make in-app or website purchases, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.

 

Social networks and connected third-party platforms: If you wish to share certain content on social media, you will be asked to log-in with your social media platform credentials. In this case, the content you want to share (e.g. a screenshot from the game) will be sent to the respective social network or third-party platform. If you signed up with your third-party platform account, we will send your account identifier and request data (e.g. user name, e-mail, profile picture) from the third-party platform provider.

 

We have included a Google Play Games and Apple Game Center login on our mobile Services to enable you to integrate with your gaming profiles as and when they see fit to do so. Such parties may capture some of your data once you logged-in. Please note that logging-in to these services is not mandatory but available in order to offer you more interaction in the mobile environment. For example, when you accomplish Google Play Games or Apple Game Center achievements, this will be visible on your Google or Apple profile and you earn “experience” points and can increase your level to compete with other Google or Apple users. These parties are controllers of the data for their own purposes so we strongly advise you to review their privacy policies.

Furthermore, your Facebook ID and/or the advertisement ID may be shared with Facebook Inc. (Facebook) or Snap Inc. (Snapchat) in connection with Facebook’s and Snapchat’s ”Lookalike Audience” and ”Custom Audience” (re)marketing features which we may use for our Services. Learn more about our marketing activities in the service specific section below.

User acquisition companies: We provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third- party website or in a third-party network, you will be redirected to the app store where you can install our Service. The information about the installs of our Service, your country and language, the campaign ID, your user ID, and post install events (such as session time, reached level), including any purchase events and the purchase segment), may be shared with the user acquisition company.

 

Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.

 

Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

 

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with for each Service by clicking on the following links:

Governor of Poker 3

 

How do we protect Minors?

 

When we refer to minors, we mean persons under the age of 16.

 

Registration: When you use our Service for the first time, we will ask you to provide your age. For the Governor of Poker 3 game, you must be at least 18 years old to create an account and play the game. Only if you indicate being at least 18 years of age, you will be able to proceed with your registration and to provide your consent for our advertising, and profiling activities, obtained via a consent pop-up. The data related to your age is not stored and not shared with other parties. Only the information whether you are at least 18 years of age, and whether and to which purposes you gave your consent will be stored, based on our legitimate interests.

Cookies: While you cannot use our Services without registration, you can still enter the Service Websites which may allow us to collect your Personal Data through the use of cookies. When you access our Governor of Poker 3 game for the first time via Service Websites, you will be asked to confirm your age. For this age-confirmation method, we will also use your device or browser language data for presenting the age-gate in the correct language.

 

Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside  the  EU  /  EEA.  We  have  implemented  appropriate  safeguards  to  protect  your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Standard Contractual Clauses) to provide safeguards for your Personal Data.

How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations. Afterwards, we will delete or anonymize your Personal Data. Please see below for service specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period.

 

Request the update or correction of your Personal Data so that it is always accurate.

 

Receive your Personal Data in a structured, commonly used and machine- readable format, including the right to transmit your Personal Data to another controller.

 

Request the deletion of your Personal Data if you think that it is no longer needed for the purposes indicated above. If you have created a Service account, you can delete your account at any time by submitting a deletion request. To submit this request, contact our support team or our Data Protection Officer.

Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy.

Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the processing based on consent before its withdrawal.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example the Autoriteit Persoonsgegevens        in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer:

For Governor of Poker 3: [email protected]

 

How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your account, we will inform you with a banner on our Service Website.

This Privacy Notice was last updated on:

Version        Last updated

 

1. 1.0 Thursday, 7 November 2019 

2. 2.0 Monday, 27 February 2023 

 

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice. We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

Category H – Audio, electronic, visual, thermal, olfactory, or similar information. The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

You have the right to data portability which enables you to request to transfer your personal data to another data controller.

Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

ADDITIONAL INFORMATION FOR BRAZIL RESIDENTS

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

ADDITIONAL INFORMATION FOR CHINA RESIDENTS

This section for China residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the People's Republic of China. We provide this section to comply with the Personal Information Protection Law of the People's Republic of China (PIPL) and the regulations issued under it. To the extent we process any Personal Data subject to PIPL, we will process such Personal Data in accordance with PIPL.

Under PIPL, you have the following rights:

Right to be informed: You have the right to know the details of processing of your Personal Data.

Right to access and copy: You can request access to your Personal Data or obtain a copy of your Personal Data.

Right to delete: You can request the deletion of your Personal Data in certain circumstances (for example when you withdraw your consent, or the purpose of Personal Data processing has been achieved, it is impossible to achieve such purpose, or it is no longer necessary to achieve such purpose). Please note that you can delete your account at any time by submitting a deletion request.

Right to transfer: You can transfer your Personal Data to a personal information processor designated by you when it meets the conditions stipulated by the authorities.

Right to make decisions, restrict and refuse: You can make decisions on the processing of your Personal Data, and restrict or refuse us to process your Personal Data.

Right to withdraw your consent: Where processing of your Personal Data is based on your consent, you can withdraw your consent at any time. Please understand that each service needs some basic Personal Data to be processed. After you withdraw your consent, we will not process the relevant Personal Data, and cannot provide you with the corresponding services as a result. However, withdrawal of consent by you will not affect the previous Personal Information processing based on your authorization

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes, please see above.

Governor of poker 3

Hosting and content delivery

Governor of Poker 3 is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Age gating and consent

When you visit Governor of Poker 3 for the first time, we will ask you to fill in your age. Only if you indicate being at least 18 years of age, you will be able to proceed with your registration and to provide your consent for our advertising and profiling activities, obtained via a consent pop-up. We use your age data to ensure that only users of at least 18 years of age play Governor of Poker 3 and that no personal data belonging to minors is processed except for that data that is strictly necessary to make the Service Websites work. This data is not stored and is not shared with other parties. Only the information whether you are at least 18 years of age, and whether and to which purposes you gave your consent will be stored, based on our legitimate interests.

For iOS applications, with iOS 14.5 update, Apple introduced App Tracking Transparency Framework (ATT) which requires apps to ask for the permission of users if the app will access IDFA (“The Identifier for Advertisers”) of the users for the purposes of tracking including showing personalized advertising. Such permission is requested from users via a pop-up (ATT pop-up). When you start the Governor of Poker 3 iOS app for the first time, you will see the ATT pop-up. Based on your choice we can receive your IDFA from Apple or not. The pop-up is managed by Apple and we can only change the information you see on the ATT pop-up. Therefore, if you would like to learn more about how ATT pop-ups work, we recommend you to read Apple's policies. Please note that we still show our own consent pop-up in the iOS app after the ATT pop-up in order to ask your consent for additional purposes and to inform you in a more detailed way about our data collection practices.

Creation/administration of your account

In order to play Governor of Poker 3, you have to create an account. We store your log-in data (your nickname, email address and password) to allow you to log in on different devices, based on the performance of a contract. If you choose to register using your e.g. Facebook, Plinga, Apple, Google, Microsoft, Samsung Galaxy or Huawei account, or enter our game from a third-party platform (e.g. Plinga, Facebook, Steam, Microsoft Store, Huawei Appgallery, Samsung Galaxy Store or Google), we may receive certain information about you from the respective third-party provider like e.g. your name, your authentication token, you profile picture, your email address, and a list of your friends that also play the game. This information will be stored in your Governor of Poker 3 account. If the third-party platform has an achievements system to measure and show you your achievements in the games you play, and only if you have provided your consent to the third-party platform provider, we will send event data (for example, that you reached a certain level in Governor of Poker 3) to the third-party platform provider so that this information will also be stored in your profile on the third-party platform. Please note that you can use our Services as a visitor. In that case, we do not ask for an email address, we only require your nickname and device identifier which will be combined with your account ID.

Your account data will be stored for as long as your account exists. You can delete your Governor of Poker 3 account at any time, for example by submitting a deletion request to our support team using the contact feature within the game, use the account deletion button made available in the iOS application or support page on our website or by contacting our Data Protection Officer.

Customer service

If you contact us for customer support using the contact feature within the game, an external customer service provider will process the content of your request. As a first step, we will try to provide you with general information from our “Frequently Asked Questions” feature (FAQ), based on the keywords from your request. For example, if you have asked for information related to your account (e.g. on how to make changes in your account settings), we will suggest articles from our FAQ which contain account-related information (e.g. on why your account was blocked or on how to disconnect your Governor of Poker 3 account from Facebook). If the suggested articles from our FAQ do not contain the information you were looking for, we may ask you to provide your name and your email address in order to help you with your request.

This information will be processed together with your user ID (including segment), the last steps taken within the game, and device data (such as device model, battery status, free storage, device language, operating system version, carrier and platform). The request history will be stored in order to solve newer requests based on the information related to your previous request (generally for account lifetime). Please note that if the request and correspondence with customer support is considered to be necessary for prevention of a crime, facilitation of an investigation related to public safety, protection of the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights, we can store your request history based on statutory period in the Netherlands. We process this data on the basis of the performance of a contract in order to provide you with our customer service.

Analytics

We use analytics services to understand which features you like in Governor of Poker 3 and how you use them. For this purpose, we process purchase events (the amount spent within the game), the purchase segment, the level you reached within the game, your session time, which saloons you played in, how many hands you played, whether you won or lost the game, the features you used (e.g. teams or chats), and how many friends you have in the game. We combine this information with campaign data (including the advertisement device ID, install data, your country and language, the campaign ID, and your user ID) to get an insight into campaign results and to create user segments for new user acquisition and remarketing purposes.

The use of analytics services also helps us to improve the game for you, to find crashes and issues in the game, and to improve the performance of our websites/apps. For this purpose, we process crash information, ANR information (the situation if the game freezes), and device information (battery, Wifi situation, CPU, memory). When you play Governor of Poker 3 from Microsoft Store, Microsoft can provide us data about the performance of the game and any problems you experience, including error reports. Error reports (also known as “crash dumps”) can include details of your software or hardware related to an error. This data will be used solely for finding and fixing bugs and errors and improving the game overall. Please note that we receive crash dumps from other platforms that our game is offered (e.g. Apple App Store and Google Play Store).

We also use Facebook Insights, an analytics service provided by Facebook and implemented through the Facebook SDK (SDK is a collection of software programs for the purpose of creating applications across web and/or mobile platforms for a particular operating system) which allows Facebook to collect your Personal Data when you play Governor of Poker 3. Facebook’s analytics service combines your in-game data (such as the level you reached and the amount you spent within the game), the purchase segment, campaign data (creative views of and clicks on advertisements, advertisement Device ID, installs, your country and language, the campaign ID and your user ID), the session amount and session time, with Facebook's data about demographic data (for example your age, gender, country or language and likes) that Facebook knows from your Facebook profile. Facebook Insights provides us with aggregated information about our users which help us to improve our game and to adapt our services and ads to our target audience.

We process this information based on your consent, provided in the consent pop- up which will be shown to you when you access Governor of Poker 3 for the first time.

We also process your IP address and user id to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.

Social media sharing service

You may share content from Governor of Poker 3 with your friends via social media by clicking on the social media share button and using your social media platform credentials. Following your request, a screenshot from the game will be shared with the social media platform you wish to share your content with. We process this data based on your consent, which you provide by choosing to use the option to share content from Governor of Poker 3 via social media.

Data management service

Based on your consent you provided for ”Profiling”, we create user segments and use these user segments for new user acquisition and remarketing purposes. The user segments are created based on your in-game behaviour (such as your in- game purchases, your sharing activity, and the level you have reached within the game) and by determining the spending behaviour for each segment. For this purpose, your Personal Data, including your in-game behaviour, your country, game language, purchase segmentation, the highest price point ever spent in Governor of Poker 3, and the advertisement ID are collected and sent to a data management service provider.

New user acquisition, remarketing and campaign tracking

The following processes help us to find new users, remarket existing users and measure the effectiveness of our advertisements:

New user acquisition: In order to acquire new users, we create advertisements (banners/videos) for Governor of Poker 3 and provide our advertisements to third-party user acquisition companies which show our ads in their apps or on their websites. If you click on the banner/video shown to you in a third-party app or on a third-party website, you will be redirected to the app stores (Google, Steam, Microsoft, Samsung Galaxy, Huawei, Apple or web version of Governor of Poker 3) where you can install and/or play Governor of Poker 3. The information that you have clicked/viewed the advertisement (campaign information) will be sent from the user acquisition companies to an attribution platform provider (Appsflyer) and will then be passed by Appsflyer to the app store. If you install Governor of Poker 3, the campaign information will also be passed from Appflyer to us and will be processed to measure the effectiveness of our advertisements. The described data processing activities help us prevent fraud, to track and optimize our campaigns, and to reward our user acquisition partners. This is based on consent obtained from you by the third-party app or the third-party website.

 

When you start playing Governor of Poker 3, we collect and share post install events (for example, the level you reached within the game and purchase segments) either through the Appsflyer SDK or directly with the user acquisition companies which helps them to optimize their services. Post install events also help us to optimize our Services. We share these post install events based on our legitimate interest.

Furthermore, we use Facebook’s ”Lookalike Audience” feature to find new users based on the user segments we have created for our user base. In order to allow Facebook to search for a ”lookalike audience”, we select the segments that have a good spending behavior and give a list of these users' Facebook IDs and Advertisement IDs (IDFA from the device, which users can reset) to Facebook. Facebook processes this information to check the Facebook profiles of the respective users for common characteristics of these users (for example, hobbies or the user’s location, using data available only to Facebook and which is not shared with us) and to find similar new users ('lookalikes') which are likely to be interested in our game. These similar users will be shown advertisements (banners/videos) for Governor of Poker 3 to encourage them to click the advertisements and install Governor of Poker 3 through the app- store.

Remarketing: We also provide our advertisements to third-party user acquisition companies to show advertisements for Governor of Poker 3 to existing users and to encourage them to come back to the game. For this purpose, if you are a registered user and if you have provided the relevant consent, we will share your user ID, your country, your device identifiers and language information with third-party user acquisition companies. Furthermore, we will share in-game data (for example, the level you reached within the game and purchase events and segments) either through the Appsflyer SDK or directly with the user acquisition companies to help them to optimize their campaigns.

Campaign validation and fraud prevention: In order to prevent fraud and analyze our campaigns we send campaign data we receive from our user acquisition partners in connection with the acquisition of new users (views, clicks and installs, campaign ID) together with analytics reports relating to the game usage to our internal user acquisition service.

 

This processing is based on our legitimate interest.

Affiliate system

Third-party website owners can participate in our affiliate program to earn a revenue share of the purchases made by the users they brought into Governor of Poker 3. After having registered for the affiliates program, third-party website owners can promote Governor of Poker 3 by showing an advertising banner of the game which directs users to relevant platform when clicked (mobile or web based on the device) on their platforms or by enabling their users to play Governor of Poker 3 within their website by using a web version iFrame. If you have accessed Governor of Poker 3 from a third-party platform participating in our affiliate program, this information will be available to us via a custom script in our game and it will be stored in our backend as part of your in-game profile. We will send the following Personal Data to our affiliate marketing solution in order to pay the revenue share of third-party website owners for implementing Governor of Poker 3 within their platforms: the transaction ID, your country, currency, price, and device-type.

This process is based on our legitimate interests to reward third-party website owners for promoting Governor of Poker 3 on their platforms.

Push notifications

Based on our legitimate interests, we may show you push notifications on your device to inform you of new content and offers in Governor of Poker 3. For this purpose, a user notification service will process information about the status of the push notification (notification received/viewed) and device information. You can turn off the push notifications in your account settings or device settings at any time.

Newsletters

When you sign up for an account in Governor of Poker 3, you will be asked to provide your consent for the delivery of newsletters. In this context, we may process the following Personal Data such as your email address, your last log-in, your name, language, country, your user ID and information about your in-game behavior. You can cancel your subscription to our newsletter at any time over the corresponding link which appears at the end of every newsletter (or opt out through the in-game settings).

Payments

If you make in-game purchases, you will be redirected to an external payment provider for the transaction of your payment. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers the following information related to your transaction: the quantity of the product you purchased, the product name, your user ID, the payment ID, the price, the currency symbol, your country, the receipt, product ID (sku), and the operating system. When you play Governor of Poker 3 on a third-party platform (e.g. Facebook, Apple, Google, Steam, Microsoft, Huawei or Samsung), any purchases you make will be processed by that third-party platform and subject to that third-party platform’s terms of service and privacy policy. For these purchases as well, we do not receive your financial information, but may receive non-financial information related to your purchases as listed above.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.

Forum and chats

If you post a message in the forum made available to you on our website, your message will be processed by our forum service provider, together with your nickname, email address and password. If you use the chat feature within the game, your messages will be stored in the game database and in our log system where it will be deleted after 2 months from our logs whereas your message history within the game database will be stored unless it is overwritten by newer messages.

This process is based on the performance of a contract in order to provide the forum and chat features within Governor of Poker 3.

 

Logging of all in-game actions

In order to help you with any issues you might have with our game, we store all the steps you take within Governor of Poker 3 in our logs which will be deleted after 21 days.

This process is based on our legitimate interest to be able to analyze and solve any potential issue with our game.

Fanpage Administration on Social Media Platforms

We have social media pages on Facebook and Instagram to publish posts, updates and events to increase the engagement with our players. We do not collect, receive or process any personal data for this process as any interaction such as likes and shares are collected by Facebook or Instagram. Based on the type of the post on social media, you may be able to comment on the post. Please be aware that such comments may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.

Avatar creation and character customization

When you create an account, Governor of Poker 3 asks you to choose one of the two available avatars (to play the game as a cowboy or cowgirl). Once chosen, you can customize these avatars with clothing to your liking (e.g. hats, pins and outfits) and other in-game accessories to create your in-game persona. Please note that your avatar will be visible to other players on a poker table when you play a poker session. When you connect Governor of Poker 3 with your Steam or Facebook account, your profile picture  in those platforms will be in your in-game profile and on poker sessions.  This process is based on the performance of a contract. Your avatar will be stored as long as your account exists.

Team creation and selection

As Governor of Poker 3 is a social game, we enable users to interact with each other by teaming up. In this regard, you can create your own team or join an existing one. Your team includes your team name, team logo (can only be chosen from the ones made available by the game), your location (derived from your IP address), your username, your avatar and list of members of the team. Please note that teams are searchable and can be found by all players. In other words, if a player knows the name of your team, she can search and find your team. Accordingly, Governor of Poker 3 teams are visible to all players. This process is based on the performance of a contract.

In-Game Statistics and Tagline

In order for you to see your history of playing Governor of Poker 3, we make available detailed statistics on your profile. In-game statistics include username, location (Derived from IP address) in the form of country flag, last week score, total points, challenges completed, team information, achievements unlocked, badges obtained, date started playing, poker results and number of chips. We also offer you a speech balloon on your profile to express yourself with one-liners. Please be aware that your Tagline will be visible to all players. Never share information or personal data that is harmful for yourself or others. Your in-game statistics are also visible to all players who visit your in-game profile and are stored as long as your account exists. This process is based on the performance of a contract.

Inviting and adding friends

You can invite your friends to play the Governor of Poker 3 together and you can also be added by other players as a friend. This increases interaction between players, providing a more social environment and increases the total number of players playing the game. We also believe that players will enjoy the game more by playing with their friends. Players can add friends via different channels including social media. In order to ease this process, we generate a random friends code for each player which can be used by other players to add as a friend. Please note this friend code is unique and your in-game account can be identified via this friend code. If you log-in to our game via Facebook, we receive your Facebook friends list and they are automatically added as your friend. When you add another player as your friend, we receive friend_id, referral code, channel (channel that was used to get the friend connection), Facebook friends list (if Facebook log-in is used) and friend_push_send_time (date and time of adding friend). Your friends list is stored as long as your account exists. This process is based on the performance of a contract.

Leaderboard functionality

Other than competitive features provided via Google Play Games or Apple Game Center, Governor of Poker 3 also offers in-game leaderboards to compare high scores with other players and reward playtime of our players. For providing and organizing leaderboards we collect user ID, username, avatar, Facebook profile photo (if logged-in via Facebook), in-game points and date and time. Players are visible on leaderboards as long as their accounts exist. This process is based on the performance of a contract.

If you logged-in via Facebook, you can also compare your high scores with your Facebook friends, provided that they play Governor of Poker 3.

In-game penalties

In order to ensure that Governor of Poker 3 has a safe environment for all players to enjoy, we have the right to apply in-game penalties or sanctions for users that acted against our Terms of Use. We collect reported_user_id, username, user_report.reason (nickname, spam, harassment, foul language), timestamp, moderator notes, user_sanction.action and user_sanction.timestamp for sanctioning players. We store information regarding in-game penalties as long as the account exists and for the statutory period envisaged in the Netherlands for any potential legal disputes. Please be aware that, if the in-game action is also considered as a crime, we can report you to law enforcement after conducting an assessment on the issue.

In-game missions

In order to incentivize players to play the game more and assist them to set in-game goals, we offer in-game missions for players to complete. For this purpose, we collect mission progress (including in-game actions and behaviour) and date and time of the reward claimed (mission completed). This process is based on the performance of a contract.

Daily challenges and rewards for daily login

For rewarding our loyal players who consistently play the game, we offer daily rewards that can be collected via log-in and completing certain actions in game (e.g. by winning a certain amount of chips). For this purpose, we collect the information on log-in (whether the user has logged-in or not and date and time of the log-in). This process is based on the performance of a contract.

In Game Progress Transfers from Facebook

We allow players to transfer their Governor of Poker 3 account to their Facebook account (when they want to continue playing the game via Facebook) or vice-versa. With this transfer , players are able to keep all their in-game progress. If there are different accounts for different platforms, players can choose to keep one account for all platforms which would end-up with the deletion of other accounts. We collect user ID, migration date (date_redeemed) and authentication token from Facebook to complete the migration. This process is based on the performance of a contract.

Governor of Poker Club Membership

Governor of Poker Club is a membership feature which has certain advantages such as daily chips for free, early access to events and additional challenges. It is offered to players with different purchasing periods starting from 30 days to 90 days. Users who become a member can have a special badge visible on their profile which can be toggled on and off from the account settings at any time. Since Club Membership is essentially an in-game purchase, we collect the same data as listed above under the ‘Payments’ section.

Governor of Poker Donation Packs

From time to time, we can release special packs whose purchases will be donated to victims of certain events (such as COVID pandemic). If you purchased a donation pack, you are awarded with a pin that is visible on your avatar’s hat. Since donation packs are an in-game purchase, we collect the same data as listed above under the ‘Payments’ section. Please note that we make a donation to the designation charity under the form of one total donation and thus we do not share any information about purchasers.

Third parties

If you click here, you will see an overview of the third parties we may share your Personal Data with, or that may share your Personal Data with us.