Pokerload Legal Policies

What is the purpose of this document?

Our company VERNAS ENTERPRISES LTD (hereinafter the “company”), owner of the website www.pokerload.com (hereinafter the “website” or the “POKERLOAD website”) and POKERLOAD mobile application (hereinafter the “mobile application” or the “POKERLOAD application”), is committed to protecting the confidentiality and security of your personal data under the EU General Data Protection Regulation 2016/679 (“GDPR”) and the Law on Protection of Individuals Against the Processing of Personal Data and the Free Movement of this Data of 2018 (Law 125 (I) / 2018). For the purposes of the present Privacy Policy the POKERLOAD website and the POKERLOAD application shall be jointly hereafter referred to as the “POKERLOAD platform” or the “platform”, as the context may permit. This Privacy Policy describes how your personal information is collected, managed, used and processed during use and browsing of the POKERLOAD website or the POKERLOAD application, including processing of any information which may be provided through the POKERLOAD website or the POKERLOAD application, such as for example the purchase of services through our mobile application or the express on your interest in providing your services through of our mobile application or to subscribe to our newsletter. Our company is a “controller”. This means that we are responsible for deciding how your personal data is used, stored and processed. We are obligated under the current legislation for the protection of personal data, to provide you with the information included in this privacy and confidentiality policy. This policy applies to every user of our website or our mobile application, as well as to any user who provides personal data through our website or our mobile application. This policy is not part of any service contract or any other contract. We may modify, update and / or replace the present policy at any time. It is important that you read this Privacy Policy as well as any other data protection declarations we may provide in certain cases for collecting or processing personal information, in order to be informed as to when, how and why we use this information.

Data protection principles

Our company undertakes to comply with the principles related to the processing of personal data provided by the GDPR. These principles state that the personal information we hold about you must: 1. Be subject to lawful and lawful processing, in a transparent manner. 2. Be collected only for specified, explicit and lawful purposes, which we have clarified to you and are not processed in any way that is not in line with those purposes. 3. Be related to the purposes we have informed you of and are limited to those purposes only. 4. Be accurate and up to date. 5. Be maintained for as long as necessary for the purposes we have informed you. 6. Be kept safe.

Contact Details

If you have any questions regarding this Privacy Policy, please contact our company in any of the following ways: • By post at the following address: Mystras 4, 1055 Nicosia, Cyprus • By telephone: [ ] • By email: contactus@pokerload.com

Personal information we collect and why we collect it

The POKERLOAD website and the POKERLOAD application collect and use personal information for the following reasons:

Monitoring of users’ interaction

The POKERLOAD platform uses Google Analytics (hereinafter “GA”) to monitor the user’s interaction with the platform. We use this data to determine the number of people using our platform, to understand better how they use our platform, and to see their navigation through the platform. Even though GA records data such as your geographical location, device, web browsers, and operating system, none of this information identifies you personally. GA also records the IP address of your computer or mobile device, which could be used for your personal identification, but Google does not give us access to it. It is considered that Google is a “processor” of personal date on our behalf. GA uses cookies, details of which can be found in the Google Developer Guides. More information regarding the cookies used on our platform may be found at our Cookies Policy. Disabling cookies on your internet browser will prevent GA from tracking any part of your visit to web pages of our platform.

Registered Users

Regarding the registered users of the POKERLOAD platform, several information is collected in order to enable the user to use our mobile application and/or to purchase services through the POKERLOAD application. To be able to purchase the provided services for poker games via our mobile application, a user is required to be registered as a registered user on our mobile application and when a user applies for registration on our mobile application, personal data is required to be submitted thereon and will be stored. Such personal data may include the following information: name, gender, date of birth, citizenship, passport number, telephone, e-mail, address, postal code as well as city and country of residence. The personal data of the registered user which have been submitted upon his/her registration on the POKERLOAD application, will be sent to the service provider / casino every time a purchase/reservation of services provided via our platform is completed, for user’s assessment and registration on the provider’s/casino’s system, in advance of arrival of the user at the selected game. When we share information of registered users to providers / casinos, this is done via our CRM secured platform to safeguard the security of this information. In addition to the above-mentioned, personal information of registered users may be received by us for communication, complaint handling and/or investigation by our company.

Database of Banned Persons

Our company VERNAS ENTERPRISES LTD, in association with our associated casinos/providers, maintains a ‘Database of Banned Persons’ which contains information regarding POKERLOAD registered users, who have been banned and/or excluded for any reason from casinos, for protecting the credibility of our mobile application and the integrity of the game. Such information may include the registered user’s name and surname, identification document number, reason for ban and other relevant information. For the purposes of protecting the credibility of our mobile application and the integrity of the game, information included in the ‘Database of Banned Persons’ is safely stored in a database on our CRM secured platform and is shared via our CRM secured platform to our associated casinos/providers. The ‘Database of Banned Persons’ is regularly updated to, either include a banned person thereon or delete a person in relation to whom a ban has been lifted. It must be noted that information regarding registered users which have been included in the ‘Database of Banned Persons’ is not deleted, upon deletion and/or deactivation by a registered user of his/her POKERLOAD account.

Targeting and Promotional material

The personal data of a registered user which has been provided upon registration may also be used, if the user consents, for the receipt of promotions generated from the platform, for the benefit of the service providers and/or advertisers.

Newsletter

The following personal information concerning registered users in the POKERLOAD application may be used, if the user consents, to receive newsletters which will be sent regularly: Name, Sex, Date of birth, E-mail, Telephone, Geographic location.

Statistical surveys

For statistical surveys, the following personal information concerning registered users may be used: Sex, Date of birth, E-mail, Telephone, Geographical location.

IMPORTANT NOTICE REGARDING MINORS: The POKERLOAD platform is not intended for minors under the age of 21. For this purpose, we will not permit access to the services we provide via our platform to users which are under the age of 21.

Legal basis of GDPR for the use of your personal information

We will use your personal data only in accordance with the legal bases of the GDPR listed below. We will usually use your personal information in the following cases: 1. Where action is taken before the conclusion of a contract via the POKELOAD application at your request or when the processing is necessary for the performance of the contract to which you are a party. 2. When the processing of personal information is necessary for complying with our legal obligations. 3. Where the processing of personal information is absolutely necessary for the purposes of our legal interests or those of a third party, to which the data is disclosed, only if such interests do not override your rights and freedoms. 4. In case you have explicitly requested us to do something or when you have given us your consent to process your personal data (eg. answering a question you may have asked us or subscribing to our newsletter). We may also use your personal data in the following rare cases: 5. Where it is necessary to protect your vital interests or those of another natural person. 6. When it is required for the public interest.

Special purposes for which we may use your personal data

The circumstances in which we may process your personal data are listed below. The following list indicates the circumstances that may involve the processing of personal data, and also mentions the legal basis of the GDPR Regulation based on which we can process your personal data (the legal basis is indicated by the number next to each possible circumstance and the number corresponds to one of the legal bases provided by GDPR). • Concluding an agreement with you on the terms on which we work. [1] • Providing contractual benefits to you. [1] • Business management and planning, including bookkeeping and auditing. [1], [2], [3] • Performing performance audits, managing performance and setting performance requirements. [1] • Education, training and development requirements. [1], [2] • Compliance with health and safety obligations. [1], [2] • Fraud prevention. [1], [2], [3] • Monitoring of equal opportunities. [1], [2] • Sending you informative material in relation to our services. [4] • Submission of a query or any other request (eg. for the provision of services) through the website. [1], [4] • Monitoring the use of your information and communication systems to ensure compliance with our information technology (IT) policies. [1], [2], [3] • Presenting or submitting ads or promotional material. [4] Some of the above cases overlap and there may be various bases which may justify the use of your personal data.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive further information as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Right to withdraw consent

In case you may have given your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent regarding this particular processing at any time. To withdraw your consent, please send us a written request to contactus@pokerload.com. After receiving notice that you have withdrawn your consent, we will no longer process your information for the purpose or purposes for which you originally agreed, unless we have another legal basis for such doing so.

Information about criminal convictions

We may only use information relating to criminal convictions where it is permitted by law. This will usually be where such processing is necessary to carry out our obligations and provided it is in accordance with our Privacy Policy. Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We envisage that we may hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of our relationship and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the user assessment process or we may be notified of such information directly by you in the course of you working for us. We may use information about criminal convictions and offences to consider your suitability for using our services or to be registered as a user on our mobile application.

Automated decision-making

Automated decision making occurs when an electronic system uses personal information to make a decision without any human intervention. We can use an automated decision-making process in any of the following cases: 1. When it is necessary to conclude or perform a contract with you. 2. When permitted by law which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests. 3. In limited cases, with your explicit written consent and where appropriate measures are in place to protect your rights. If we make an automated decision on the basis of any special category data, we must either have your explicit written consent, or it must be justified in the public interest, and we must also take appropriate measures to safeguard your rights. You will not be subject to decisions that have a significant impact on you based solely on automatic decision making, unless we have a legal basis for doing so and we have notified you in advance.

Data sharing

We may need to share your data with third parties, including any service providers. We require our third parties, where possible, to secure your data and treat it in accordance with the law.

Why we might share your personal information with third parties?

We may disclose your personal information to third parties, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third party service providers process my personal information?

“Third parties” include third-party service providers (including consultants and authorized representatives) and public or local authorities. The following activities are performed by third party service providers: poker games, IT services, accounting, audit, tax and legal services.

How secure is my data with third party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal data in accordance with our policies. We do not allow third party service providers to use your personal data for their own purposes. We only allow your personal data to be processed for specific purposes and in accordance with our instructions.

What about other third parties?

We may disclose your personal information to other third parties or you may disclose information to a third party because you have visited us or interacted with our POKERLOAD website and/or POKERLOAD application. For example, in the context of your interaction with certain functions which are integrated in our application, such as the “Like” and “Share” button of Facebook and similar functions of other social media e.g. Instagram, Twitter, etc., you may share your personal information with these third parties. We may also need to share your personal information in the context of a possible sale or restructuring of the business or to a regulatory authority or to comply with the law.

International data transfer

Some of our third-party service providers are located outside the European Economic Area (EEA), thus the processing of your personal data will involve the transfer of data outside the EEA. Whenever your personal data is transferred outside the EEA, we ensure that a similar degree of protection is provided, ensuring that when using specific service providers, we may use specific contracts approved by the European Commission, which provide for the processing of personal data with the same protection offered within EEA. Please contact us if you would like to receive more information about the specific mechanism we use when transferring your personal data outside the EEA.

Data Security

We have implemented measures to protect the security of your data, for example to backup and to protect the integrity of electronic communications and data storage systems. Third parties may only process your personal data on our instructions and where they have agreed to treat the information confidentially and to maintain the security of the information.

Data retention – How long will you use my data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and any applicable legal, regulatory, tax, accounting or other requirements. In some circumstances, we may encrypt your personal information so that it can no longer be associated with you, so we may use this information without further notice to you. As soon as the purposes for which we collected your data disappear, we will retain and/or safely destroy your personal data in accordance with applicable laws and regulations.

Access, correction, deletion and restriction rights

Your rights in relation to personal data

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below more details about your rights: • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. • Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. To review or update this information you may simply sign in to your POKERLOAD account and review and update your information accordingly. • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have legitimate grounds to process your information. • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: • If you want us to establish the data’s accuracy. • Where our use of the data is unlawful but you do not want us to erase it. • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent to us or where we used the information on another legal basis. • Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the above rights, please contact us at contactus@pokerload.com.

Data Protection Officer (DPO) and complaints

Given the scale, nature, scope and purposes of our company VERNAS ENTERPRISES LTD, we have not appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy. However, if you have questions about this Privacy Policy or how we handle your personal information, please contact us at contactus@pokerload.com. You also have the right to file a complaint at any time with the Office of the Personal Data Protection Commissioner, the supervisory authority for the protection of personal data of the Republic of Cyprus.

Data breaches

We will report any illegal data breach of the POKERLOAD platform, within 72 hours of the breach, if it is obvious that the personal data stored in an identifiable form has been stolen.

COOKIES

POKERLOAD platform uses “cookies”, a technology that stores data on your computer using the functionalities of your web browser, to collect statistics regarding visitors of its website and/or mobile application to display relevant ads. More information regarding our Cookies Policy can be found here.

Password Use Policy

Our company pays great attention to the confidentiality of our platform accounts and to the confidential content contained therein. Therefore, we have developed rules that apply to the use of passwords in the accounts of registered users of our platform. We urge you to refer to the Password Use Policy, here, before registering on our platform.

Changes to this Privacy Policy

This Privacy Policy may change from time to time in accordance with legislation or industry developments. We will not explicitly notify our customers or users of the POKERLOAD platform of these changes. Instead, we encourage you to periodically check the POKERLOAD platform for any policy changes.

Recognition and Acceptance

By continuing to use the POKERLOAD website and/or POKERLOAD application, you acknowledge that you have read, understood and agree to the contents of this Privacy Policy.

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