PRIVACY NOTICE
This Privacy Notice will be effective from August 28, 2023.
Introduction
This Playtika Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “Playtika” refers to Playtika Ltd., 8 Hachoshlim St., Herzliya Pituach 4672408 Israel, the data controller, and its affiliates, which shall mean subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership. We may also refer to Playtika as "we" or "us".
This Privacy Notice applies whenever you play Governor of Poker 3 (”Services”). 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”.
By using the Services, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want Playtika to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not play Playtika’s games or use our Services.
Personal Data We Collect
When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, under current law in most countries, the personal data we collect is not considered sensitive personal data.
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 directly.
When you use our Services, you may provide or be asked to give us certain information, including:
· Age information: 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: When you create an account on our Services, 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 User ID. Please note that you can use our Services as a visitor. In that case, we only require your nickname and device identifier which will be combined with your User 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.
· Data provided in response to surveys or another research we conduct;
· Data submitted by participating in group communications or chats.
· Other information that helps us make sure it’s you who is accessing your account, including as necessary for us to provide the support you request.
Personal Data you generate when using 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: The information we obtain from your device(s) includes the type of your device, 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.
· 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. Part of this information will be stored in your account (such as your friends list and your progress). Furthermore, we collect information about the websites that led you to our Service.
Personal Data we get from third parties
In certain scenarios, we will also obtain your Personal Data from third parties. For example, 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 your credit card information) but may receive basic information which is related to your transaction, for example the payment amount 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, 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 those third-party platforms where you receive our Services 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. For example, Playtika may collect and store some or all of the following information shared by the third-party:
· your first and last name;
· your profile picture or its URL;
· your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
· your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
· the login e-mail you provided to the third-party application;
· your approximate physical location (the country/state you are located in) and that of the devices you use to access our Service;
· your gender;
· your birthday and/or age;
· information about your activities on or through the third-party application;
· other information you have shared on the third-party application;
· any other information that you or the provider of the third-party application share with Playtika.
· 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.
Cookies and Automated Information Collection
Playtika, our service providers, and third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as improving the quality of Playtika’s Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies.
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.
How We Use Personal Data
Depending on which Service you are using and which privacy settings you have selected, Playtika may use personal data for a variety of business purposes as described in this Privacy Notice such as:
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
· to provide you with a more personalized game experience
Marketing and analytics
· to show you advertisements for our Services on other websites or apps
· to measure the effectiveness of advertising and optimize it
· to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers
· to acquire new users including 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
· to authenticate and/or verify individual identities.
· to protect the safety and well-being of our players.
· to protect Playtika's rights and property in connection with our Service including to enforce our policies and Terms of Service.
· to address technical issues and maintain and/or enhance network and information security.
· to conduct audits, ensure internal quality control, and take safety precautions.
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 right
· to comply with our legal obligations (e.g. tax and accounting obligations) to inform you about any changes to this Privacy Policy
Finally, we may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) artificial intelligence to evaluate personal data that we collect including, for example, to create user segments, based on in-game activity (e.g. in-game purchase activity, the level reached in the game) for legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.
For specific information about the user segments we create, see the section with service specific information below.
We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.
LEGAL BASIS
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, we ask for your consent for the data processing in the context of our newsletter. 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. For example, we process your Personal Data for improvement of the Service provided to you, to provide you with a better user experience.
Please see for additional information the section with service specific information below.
HOW WE SHARE PERSONAL DATA
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 may share your personal data with our group companies including Playtika Holding Corp. 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 would 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 may 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 may 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. In addition, we may also disclose information to protect the rights or property of Playtika and other applicable third parties, including to enforce our Terms of Service.
· Sale, Merger or Changes in Structure: We may 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). We will make reasonable efforts as described in this Privacy Notice to let you know of the business transition before transferring personal data to the extent required by law.
You can find a list of third parties your Personal Data may be shared with for each Service by clicking on the following link.:
Please note that the information on the above link may be changed or updated from time to time.
Children’s Privacy
In accordance with the Terms of Service, you may not use the Service if you are under 21 years old.
Playtika is committed to complying with laws protecting children. If you believe that your child has submitted personal data to Playtika, please contact us at [email protected]. Playtika will take reasonable steps to delete such information as soon as possible.
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.
International Transfers
Playtika may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice.
Laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise make efforts to ensure that such transfers meet applicable local legal requirements.
Playtika may send, access, use, and/or store personal data outside of the country or region where you live including, for example, to the United States and Israel. By using the Service, you consent to the transfer of personal data outside of the country or region where you live. If you do not consent to such transfer, please do not use our Service.
Security
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.
We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.
Retention
We may retain personal data for as long as you use the Services and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.
Afterwards, we will delete or anonymize 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.
YOUR RIGHTS
Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Playtika processes about you, for example to request:
• information.
• access.
• correction (or rectification) of personal data that you think is incorrect;
• erasure (or deletion).
• an electronic copy (or portability).
Object to certain processing activities.
You may 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 in the place (country and/or state) where you live.
A. Manage Information We Get from Platforms
To manage the information Playtika receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon, etc. you will need to follow the instructions for the relevant third-party application(s) for updating your information and changing your privacy settings.
B. Choosing not to receive Promotional Communications
If you want to stop receiving Promotional Communications, you can click on the "unsubscribe" link in any promotional email from Playtika. If you want to stop receiving texts or SMS messages from us, you can also use the “unsubscribe” link or reply “STOP” to any promotional message. Please note that it may take us some time for your opt-out to become effective.
D. Choosing not to receive Facebook messages.
If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.
E. Choosing not to receive Push Notifications
When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings”.
G. Choosing not to apply Cookie Tracking
On Playtika websites that use cookies, you can use the cookie banner or click on the “Cookies Settings” link, to choose your preferences.
You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow.
If you disable cookies, you may lose some of the features and functionality of our Service.
H. Do Not Track
Note that Playtika does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
HOW CAN YOU CONTACT US?
If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact Playtika’s DPO office at [email protected] or Chief Privacy Officer, 8 Hachoshlim St., Herzliya Pituach 4672408 Israel.
If you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live
Updates
Playtika reserves the right to amend the Privacy Notice from time to time, and Playtika encourages you to consult the Privacy Notice regularly for changes.
If we make material changes to our Privacy Notice, we will tell you by placing a notice on this website or its equivalent in-game, or, if and as required by law, by sending you a notice to the e-mail address we have on file for you, prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Playtika websites. You should periodically check this privacy page for updates.
Links to Other Sites/Apps
The Services may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app, and Playtika is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review the terms and privacy policy of any site or app that you access.
Supplemental U.S. State Laws Notice ("Supplemental Notice”)
The information below supplements the Privacy Notice and is intended for consumers from select U.S. states, including California, Virginia, Connecticut, Utah, and Colorado in accordance with applicable state laws.
Collection and Use of Personal Information
"Personal Information" in this Supplemental Notice refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a certain consumer or household or as otherwise defined under applicable law.
The following chart lists the categories of Personal Information we collect about players, the source of collection, and the business purposes for collection. These are also the categories of Personal Information we collected in the past 12 months and their business purposes.
A more detailed description of the particular pieces of information we collect, and their purposes is provided in this Privacy Notice.
|
Category of Personal Information |
Categories of Sources |
Commercial or Business Purpose |
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Identifiers, such as picture, account name, device ID, email address, IP address, etc. |
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California Customer Records (Cal. Civ. Code § 1798.80(e)) such as telephone number and payment information |
|
|
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Protected Classification Characteristics, such as age and gender |
|
|
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Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
|
|
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Internet/electronic Network Information, such as website or application or advertisement browsing history |
|
|
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Location Data, device shared location, and Wi-Fi connection location |
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Inferences such as derivation of information, data, assumptions, or conclusions from any of the above categories of personal information |
|
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The following describes the categories of personal information we have shared for a business purpose in the past 12 months.
To the extent this practice is interpreted to constitute a “sale” and/or “sharing” under relevant state laws, Playtika permits, subject to legal and technical limitations, certain third-party advertising partners to collect information about our players through our games and our website for purposes ad campaign measurement and analytics, and for ad fraud detection and reporting.
To Whom We Disclose Personal Information
As described in this Privacy Notice, we disclose personal information within the Playtika group of companies and with a variety of recipients for business purposes.
In addition to the categories of recipients identified in the How We Share Personal Data section of this Privacy Notice, we disclose personal information to, or allow access to personal information by, the following categories of recipients:
• Cloud Storage Providers
• Payment and Auditing Processors
• Security Safety Vendors and Service Providers
• Customer Service Vendors
• Advertising and Marketing Partners
Playtika provides opportunities, where appropriate, for players to opt-out of the use and sharing of personal data about them for this purpose.
You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device as mentioned above.
Additional Rights
As referenced in Section 4 (“Your Rights”), you may submit a request to exercise certain rights via email or through the Support page within the game you play. We will respond to your request in consistent with applicable laws and subject to adequate verification. We will verify your request by asking you to provide information necessary to verify your account.
You will not be discriminated against for exercising any of your rights. Please understand that, if the exercise of your rights limits our ability to process personal data (such as a deletion request), we may no longer be able to provide you with the Service.
You may appeal our decision regarding your rights request by sending an email to [email protected]. We will review and arbitrate the appeal based on applicable laws.
Minors
As described in our Privacy Notice, we do not knowingly collect or share personal data about children.
Authorized Agents
You may be allowed to use an authorized agent to submit requests on your behalf, if you provide sufficient information to show that the requestor is an authorized agent with written permission to act on your behalf and you verify your identity with us.
Service Difference
In each of the following instances, which we occasionally offer on some, but not all games, we may grant you virtual currency or other virtual items within the game:
|
Service Difference |
Categories of Personal Information Collected |
How to Opt-In to the Service Difference, if and when offered |
|
In-game videos |
Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn |
Watch in-game videos that may be presented to you |
|
In-game tailored ads |
Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn |
Consent to be served with ads that are tailored to your personal information and to sharing your personal information with ad networks, social media companies and other third-party businesses in the ad ecosystem |
|
In-game surveys |
Identifiers, protected classification characteristics, commercial information, Internet or other electronic network activity information, location data, inferences drawn |
Complete a survey that may be presented to you about you and your game experience |
|
Reviews about the game |
Identifiers, location data, inferences drawn |
Follow the instructions that may be presented to you to submit a review about the game, or rate the game, in an application store such as Google Play |
|
Facebook connect |
Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn |
When offered to you, connect to our games through your Facebook account |
|
In-game friend invitations |
Internet or other electronic network activity information, commercial information, location data, inferences drawn |
Invite your friends to download and play the game by sending an invitation from within the game, if prompted to do so |
|
Connect to our game |
Identifiers, Internet or other electronic network activity information, commercial information, location data, inferences drawn |
Connect to play the game at the frequency indicated to you |
|
Join our Facebook bot |
Identifiers, Internet or other electronic network activity information |
Connect with us through our Facebook bot |
|
Mailing list |
Identifiers |
Subscribe to our mailing list when promoted |
You have a right to withdraw from the service difference at any time. To do so, please submit a request through the Support section in the game settings or contact us via email to [email protected].
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.
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. We use your age data to ensure that only adults 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. Data about your exact age is not stored in this context.
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. 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 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.
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 by email to [email protected].
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. 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 may store and share your request based on legal obligation. 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 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
We may 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 behavior (such as your in- game purchases, your sharing activity, and the level you have reached within the game). For this purpose, your Personal Data, including your in-game behavior, your country, game language, segmentation, 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 certain segments and give a list of these users' Facebook IDs and Advertisement IDs 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, 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 basic information related to your transaction such as: 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.
Please be aware that when you use the chat function, the information you disclose may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.
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’s 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 could 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.