PERSONAL DATA PROTECTION POLICY

As part of its activities and in accordance with current legislation, particularly in France and Europe, SAS A-Game TECHNOLOGY, the Publisher of the Live Poker Application, is committed to ensuring the protection, confidentiality, and security of the personal data of its service users, as well as respecting their privacy.

This Policy informs you about how LIVE POKER, its subcontractors, and potential partners process your personal data.

 This Policy applies to users of the services available on the Live Poker application.

 

It may be supplemented with specific information provided to the user regarding a particular service.

 We comply with the current regulations applicable to data protection, including the EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter GENERAL DATA PROTECTION REGULATIONS or"GDPR") and the amended Data Protection Act of January 6, 1978.

When SAS A-GAME TECHNOLOGY, acting as the data controller within the meaning of the aforementioned regulations, commits to:

 

• Use your data only for explicit, legitimate, and necessary purposes.

• Not retain your data beyond the necessary duration for the operations for which they were collected or as provided for by the standards and authorizations of the CNIL (French Data Protection Authority) or by legal and regulatory provisions.

 • Not sell your information to any third parties. • Allow you to access your data and facilitate the exercise of your rights.

 

The present Personal Data Protection Policy (hereinafter referred to as "the Policy") describes the conditions under which SAS A-GAME TECHNOLOGY (hereinafter referred to as "Live Poker" or "We"), acting as the data controller, collects and processes personal data. Its purpose is to inform you about the personal data concerning you that we collect, the reasons for which we use them, with whom we share them, how long we retain them, how we protect them, what your rights are, and how to exercise them.

 

Article 1. Definitions

For the interpretation and execution of this Policy, the terms used below are defined as follows:

• "Personal Data": refers to any data that directly or indirectly identifies a natural person, such as surname, first name, email, postal address, telephone number.

 

• "Data Protection Officer" or "DPO": person responsible for advising and overseeing the Data Controller regarding the protection of personal data. Live Poker has appointed a DPO whom you can contact via email at: contact@live-poker.com

 

• "Data Controller": refers to the person, department, or organization that determines the purposes and means of processing personal data, namely SAS A-Game Technology, the publisher of the LIVE POKER application.

 

• "Processing": refers to any operation on personal data, including recording, collection, organization, storage, adaptation or modification, retrieval, consultation, use, transmission by communication, dissemination or any other form of making available, alignment or combination, as well as restriction, erasure, or destruction.

• "User": refers to the natural person who benefits from the services provided by the application.

The terms beginning with a capital letter used in this Personal Data Protection Policy (hereinafter referred to as the "Policy") are defined in the "Definitions" Appendix.

 

Article 2: Why Live Poker collects and processes your data?

 LIVE POKER processes personal data exclusively for specific, explicit, and legitimate purposes. These purposes are as follows:

 

• Enable the creation and management of user accounts on the Application.

 • Verify eligibility for the services offered on the Application and enable their use.

 • Manage the identity of Application users and authenticate them.

 • Process account cancellations and suspensions.

• Handle complaints.

 • Handle reports.

 • Address operational anomalies reported to the support service.

 • Communicate for customer management and contract execution purposes.

 • Send you our modifications, updates, or any other news related to the application, the Terms of Use, and the Personal Data Protection Policy.

 • Provide technical support and maintenance to ensure the proper functioning and security of our Application.

• Improve the various functionalities and services offered by the Application.

 • Combat fraud by Application users, manage any claims and disputes regarding the use of the services offered by the Application.

• Send newsletters, special offers, and personalized recommendations. We provide you with the option to give your consent to this when collecting your email address. You have the ability to change your mind at any time in your account settings under "Notifications" or via the unsubscribe link at the end of the message.

• Respond to your requests for information and feedback sent to us via our contact addresses or through the various forms available on the application.

• Geolocate Application users to offer them local offers if they expressly give their consent.

• Conduct email and telephone prospecting operations for our own account or on behalf of our Partners.

• Develop usage and performance statistics for the various functionalities and services offered by the Application.

• Ensure the security of the application. •Organize events, contests for the users of the Application.

• Follow us on social networks.

 • Evaluate and train employees.

 

Or additionally:

• Fulfill our legal and regulatory obligations.

• Respond to requests from authorities and judicial decisions.

 • Respond to authorities' right to access information.

 • Manage requests to exercise the rights of data subjects.

• We may also process your data for statistical purposes. In this case, all data is anonymized beforehand.

 

LIVE POKER may also conduct data processing for statistical purposes. In this case, all data is anonymized beforehand

 

Article 3: On what legal bases does Live Poker collect your data?

 We collect and process your Personal Data in compliance with the Regulation and only within the framework of the following legal bases:

• When necessary for the performance of a contract concluded with you.

 • When necessary for us to comply with our legal obligations.

 • When necessary to safeguard our legitimate interests.

 • When you have expressly consented to the processing of your Personal Data.

 

Article 4: What is the origin of the processed data?

Depending on the case, LIVE POKER processes your personal data either directly collected from you or resulting from the use of the services.

Data is directly collected from the User

This is notably the case for account data, understood as the data you provide when creating an account by filling out the registration form or the data you make public, meaning all the information you voluntarily display on your newsfeed such as comments, photos, discussions, and your account profile information.

In cases where a personal data collection form must be completed by a User, mandatory fields are indicated by the symbol "*".

When you fill out forms available on the Application, we inform you, during the collection of your personal data, whether the data must be provided or is optional.

Mandatory data is necessary for the operation of the various functionalities and services offered on the Application.

Regarding optional data, you are entirely free to provide it or not.

We also indicate the potential consequences of not responding regarding the use of the various functionalities and services offered by the Application.

 

Automatically Collected Data

In addition to the information provided directly by you, we may automatically collect a certain amount of data on our Application and during your interaction with our services.

• Technical data used for the security needs of the Site (the device used, the network through which you access our services, IP address, connection data, types and versions of internet browsers used, types and versions of your browser's plugins, operating systems, and platforms).

• Interaction data with Customer Service or support: when you contact us by phone, postal mail, or email. We may retain the date, reason for your request, and the content of your exchanges with Customer Service or Support to ensure effective follow-up of your needs. If you contact us by phone, please note that your call may be recorded for training and service improvement purposes.

Indirectly Collected Data

LIVE POKER may also receive data that has been collected from you by a third party.

In the event of indirect collection of your data, especially public data on the Internet, we will ensure to inform you at the first communication, and in any case within one month following the collection of the data, of the intended use and your ability to object to the processing of your data for commercial purposes.

If you connect to our services using the Apple or Google features provided to you, we will have access to certain data (including your first name, last name, photograph, email address) from your account in accordance with the terms of use of the respective provider.

 

Article 5: What data and categories of data are collected?

In all cases, LIVE POKER only processes data or categories of data if they are strictly necessary for the intended purpose. The following data is thus processed:

• All data necessary for your registration and the management of your user account on the Application, namely your name, first name, username, date of birth, nationality, phone number, password, and email address.

 • Data that you make public, meaning all the information you voluntarily display on your newsfeed such as comments, photos, discussions, and your account profile information.

 • Data related to your eligibility for a certified account, a copy of your identity card or passport, or residence permit.

• Data related to your geolocation if you agree to provide it to us.

 • Data related to your inquiries when you contact us via our forms on the application, such as identification data and contact information, questions, comments, and requests sent to the Support service.

• Responses to our surveys and questionnaires.

• Data related to your connection to the Application (IP address, connection data, types and versions of internet browsers used, types and versions of your browser's plugins, operating systems, and platforms).

• Data that we may request from you in case of complaint or report: queries, questions, and information sent/formulated to our customer service, the reason for the complaint or report, the intervention report.

 

Article 6: How long is your data kept?

Your Personal Data is only kept for the time strictly necessary to achieve the purposes pursued and in accordance with the Regulations and applicable laws. After this period, the data will be kept in archived form if a legal obligation requires it or for the satisfaction of our legitimate interests, and failing that, your Personal Data will be deleted.

The retention period of Personal Data varies depending on the purposes for which they are collected and processed:

 

            (Spreadsheet in separate attachment)

 

 

Concerning the listening of voice recordings by the Support service: the data is kept for 6 months from the date of the recording.

Concerning the management of opt-out lists for receiving marketing communications: Information allowing the consideration of your opt-out right is kept for a minimum of three (3) years from the exercise of the opt-out right.

Concerning data related to participation in events and contests: The information will be kept for as long as the account is active plus an additional period of three (3) years.

Concerning data automatically collected during visits to our Application: Connection data will be kept for 6 (six) months.

Concerning cookies: The retention period of cookies varies depending on the type of cookies and has a maximum duration of 13 (thirteen) months. Information regarding your consent for the use of cookies, if applicable, is kept for a duration of 6 (six) months.

 

Article 7: Who are the recipients of your data?

The following will have access to your personal data:

• The personnel of the Publisher,

• The users of the Application,

• Our subcontractors.

Your personal data may be communicated to subcontractors, service providers, suppliers, and/or technical partners, to achieve certain aforementioned objectives on our behalf. In this regard, it is specified that these:

• Have been selected for the guarantees they provide in terms of security and compliance with the Regulations.

•  Have limited access to your personal data, only for the performance of their services.

•  Have a contractual obligation to use them in accordance with our instructions and with legal provisions regarding the protection of personal data.

• May be located outside the European Union, especially in countries that do not provide an adequate level of data protection. These data transfers are covered by appropriate safeguards, as mentioned in Articles 46 and 47 of the GDPR.

 

Live Poker may also be required to communicate your Data to Third Parties when such communication is required by law, regulatory provisions, or a judicial decision, or if this communication is necessary to ensure the protection and defense of our rights.

We may communicate certain of your data at the request of legally authorized judicial, police, or administrative authorities. The recipients of your personal data may include:

 

. Financial, judicial, and public authorities, upon request within the limits permitted by regulations and exclusively to meet our legal and regulatory obligations.

•  Certain regulated professions such as lawyers, auditors, legal assistants, and ministerial officers.

 

You can obtain the list of subcontractors by simply requesting it at the address: contact@live-poker.com

 

Article 8: How are your data secured?

 

LIVE POKER is committed to protecting your personal data against any loss, destruction, alteration, unauthorized access, or disclosure. To achieve this, LIVE POKER implements appropriate technical and organizational measures, considering the nature of the data and the risks involved in their processing, to preserve the security and confidentiality of your personal data and, notably, to prevent them from being distorted, damaged, or accessed by unauthorized third parties.

These measures may include practices such as limited access to data by authorized personnel due to their functions, contractual guarantees when using an external service provider, privacy impact assessments, regular reviews of our privacy practices and policies, and/or physical and/or logical security measures (secure access, authentication process, backup copies, antivirus software, firewall, etc.).

 

Article 9: What are your rights, and how can you exercise them?

In accordance with applicable regulations, you have the right to access and rectify your personal data, as well as the right to request their deletion (right to be forgotten), the right to object to their processing, and to obtain limitation or portability of your data in accordance with the conditions and limits set by applicable data protection regulations.

You also have the right to define guidelines regarding the fate of your personal data and how you wish your rights to be exercised after your death.

When processing is based on your consent, you can withdraw your consent to the processing of your data at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

The processing carried out does not involve automated decision-making.

Details:

 Right of access and information

You have the right to be informed in a concise, transparent, intelligible, and easily accessible manner about how your data is processed. You also have the right to obtain (i) confirmation that data concerning you is being processed and, where applicable, (ii) to access this data and obtain a copy of it.

 

Right to Rectification

 

You have the opportunity to contact us at any time to request the rectification of your personal data when it is found to be inaccurate or incomplete. To do this, you can provide us with a supplementary statement by email or postal mail to the addresses mentioned below. In the event of exercising this right, we undertake to communicate any rectification to all recipients of your data.

 

Right to Object

 

 You have the right to object at any time to the processing of your data for processing based on our legitimate interest, a task of public interest, and those for commercial prospecting purposes. This is not an absolute right, and we may refuse your request for opposition for legal or legitimate reasons.

We will then no longer process your personal data, unless:

• There are compelling legitimate grounds for processing.

 • Processing is necessary for the performance of reciprocal contractual commitments binding us, or for the establishment.

 • Processing is necessary for the exercise or defense of legal rights.

• You have consented to the processing of your personal data and have not withdrawn your consent, which you can do at any time.

 

You may also object at any time to the processing of your personal data when processed for prospecting purposes. If you no longer wish to receive our emails, follow the instructions provided in these emails to unsubscribe.

 

Processing Limitation

 

You have the right to obtain the processing limitation of your personal data in the following cases:

• During the verification period that we implement when you contest the accuracy of your personal data.

• When the processing of this data is unlawful, and you wish to limit this processing rather than erase your personal data.

 • When we no longer need your personal data for processing purposes, but they are still necessary for the establishment, exercise, or defense of a legal claim during the verification period of legitimate grounds when you have objected to the processing of your personal data.

 

Data Portability

 

You have the right to data portability for the personal data that you have provided to us, understood as the personal data that you have actively and consciously provided in accessing and using the Application, as well as the personal data generated by your activity in using the Application. You have the right to receive your data that you have provided to us in a structured, commonly used, and machine-readable format. We remind you that this right does not apply to personal data collected and processed on a legal basis other than consent or the performance of the contract binding us. This right can be exercised free of charge at any time, particularly when closing your account on the Application, in order to retrieve and retain your personal data or, where technically feasible, to transfer them to a third party for certain processing purposes.

 

Right to Erasure (right to be forgotten) and Definition of Directives After Death

You can request the erasure of your personal data at any time. However, please note that certain information may need to be retained to comply with legal obligations or to fulfill a public interest task.

Additionally, you have the option to define directives regarding the storage, erasure, and disclosure of your personal data after your death.

Please be aware that when exercising your rights, if there is reasonable doubt about the identity of the requester, proof of identity may be required. In such cases, you must provide a copy of an identity document (front/back) along with the request.

Our Data Protection Officer processes your personal data for the purpose of managing your request (title, name, surname, copy of the identity document, nature of the request, response provided). This data is kept for a period of three (3) years, except for the copy of your identity document, which is kept for one (1) year if your request concerns the exercise of a right of access or rectification, and for 3 years in case of exercising your right of opposition or deletion.

These rights can be exercised.

By postal mail to the following address:

 

Through our request form for exercising rights

LIVE POKER undertakes to respond to any request as quickly as possible, and in any case within one month of receiving the complete request. However, this period may be extended by two months due to the complexity and number of requests.

In any case, you have the possibility to lodge a complaint with the National Commission for Information Technology and Civil Liberties (CNIL) if you believe that the processing of your data is not carried out in accordance with the applicable legal and regulatory provisions.

National Commission for Information Technology and Civil Liberties - CNIL

3 Place de Fontenoy

TSA 80715, 75334 PARIS CEDEX 07

To submit a complaint to the CNIL, you can follow this link: https://www.cnil.fr/fr/plaintes

 

Article 12: Update of this Policy

This policy is subject to change at any time. In such a case, you will receive communication of the updated policy by email and/or by any means to attest to its proper receipt.

 

Article 13: Additional Information for California Residents

In accordance with the California Consumer Privacy Act ("CCPA"), this Article 13 applies to certain personal data collected about individuals from California when Live Poker controls how and why personal data is processed (what the CCPA calls a "business") and supplements the rest of our Policy above.

a. Additional Information on Data Processing:

We have not, within the meaning of the California Consumer Privacy Act, "sold, shared, or disclosed to third parties" any personal data that we have collected.

We have not "sold" or "shared" personal data for monetary consideration in the past 12 months. We do not knowingly sell or share any personal data of minors under the age of 16. We do not collect or process "sensitive personal information," as defined by California law.

Financial Incentives: We do not offer any benefit or offer in exchange or in consideration of the disclosure of your personal data, such as a discount or coupon to individuals who respond to a survey.

If we were to offer any type of financial incentive, we would provide you with the material terms of each offer when we ask you to participate.

 

b. Your Data Protection Rights:

Subject to legal limitations, certain California residents may have the following rights:

• Right to Know: You have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting the personal data, the categories of third parties to whom we have disclosed your personal data, and the purpose for which we disclosed your personal data ("Category Report"). You may also request information about the specific pieces of personal data we have collected about you ("Specific Pieces Report").
• Right to Deletion: You have the right to request that we delete the personal data we have collected from you.
• Right to Correction: You have the right to request that we correct any inaccurate personal data we hold about you.
• Right to Opt-Out of Sale or Sharing: We do not sell personal data to third parties for monetary consideration. We do not share information with advertising partners that would allow them to collect information from our digital properties.

 

Article 14: Additional Information for the EEA, Switzerland, and the UK

The following conditions supplement the Policy regarding our processing of personal data from the European Economic Area (EEA), which includes the member states of the European Union, Iceland, Liechtenstein, and Norway, as well as Switzerland and the United Kingdom. In the event of a conflict or inconsistency between other parts of the Policy and the terms of this article, this article shall govern and prevail concerning the processing of personal data from the EEA, Switzerland, and the UK.

 

a. Legal Bases for Processing:

b. Your Data Protection Rights:

. Right to Not Be Subject to Automated Decision-making: The types of automated decision-making referred to in Article 22, paragraphs 1 and 4, of the EU/UK General Data Protection Regulation ("GDPR") do not occur in relation to your personal data. If this were to change, we would inform you of the reason and how this decision was made, its significance, and any potential consequences. You will also have the right to human intervention, to express your point of view, and to contest the decision.

You can exercise these rights by contacting us at the contact details provided in Article 9 above. Please note that we may refuse to comply with requests to exercise data protection rights in certain cases, for example, when providing access could infringe on the privacy rights of another person or impact our legal obligations.

c. International Transfer of Personal Data: Some of the recipients mentioned in Article 7 of the Policy may be located in countries outside the EEA, Switzerland, or the UK, which do not offer an adequate level of data protection as defined by data protection laws in the EEA, Switzerland, and the UK. Transfers to third parties located in these third countries are made using a valid data transfer mechanism, such as EU Standard Contractual Clauses and/or the UK, Addendum to these clauses, or any other valid data transfer mechanism issued or approved by EEA, Swiss, or UK authorities. Some third countries have been officially recognized by EEA, Swiss, and UK authorities as offering an adequate level of protection, and no further protective measures are required. Please contact us using the contact details provided in Section 9 above if you would like to receive further information on how we transfer personal data or, if applicable, a copy of the relevant data transfer mechanism.

Data Protection Officer: The contact details of our Data Protection Officer are as follows: [Insert contact details].

Article 15: Additional Information for Other Regions

Australia: Personal data collected, stored, used, and/or processed by Live Poker, as described in this Policy, is collected, stored, used, and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth) and the Australian Privacy Principles. If you are not satisfied with how we handle your requests or wish to dispute the resolution we propose, you may lodge a complaint with the Office of the Australian Information Commissioner ("OAIC") by contacting the OAIC through the methods listed on their website. You may also request that we transmit information regarding your request and complaint directly to the OAIC.

• Brazil: Personal data collected, stored, used, and/or processed by Live Poker, as described in this Policy, is collected, stored, used, and/or processed in accordance with the Lei Geral de Proteção de Dados ("LGPD"). Individuals who access our services or use them expressly agree that we collect, use, store, and process their personal information for the purposes described in this policy.

• Canada: Personal data (as defined in the Personal Information Protection and Electronic Documents Act of Canada, "PIPEDA") will be collected, stored, used, and/or processed by Live Poker in accordance with its obligations under PIPEDA.

• Japan: Data collected, stored, used, and/or processed by Live Poker, as described in this policy, is collected, stored, used, and/or processed in accordance with the Act on the Protection of Personal Information ("APPI") of Japan.

• Nevada: Currently, we do not sell personal data as defined by Nevada law. If you are a resident of Nevada, however, you may still email us using the information above to exercise your right to opt-out of sales under the Nevada Revised Statutes (NRS)

Article 16: Priority of the French Version

Translations of this Policy other than the French translations are provided for convenience and reference only. In case of ambiguity or discrepancy between translations, the French version shall prevail.

 

Recipient:

A natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether a third party or not.

 

Personal Data:

Any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes sensitive personal data.

 

Sensitive Personal Data:

• racial or ethnic origin, political opinions, religious or philosophical beliefs
• membership in a trade union
• physical or mental health
• sexual orientation or sexual life
• genetic and biometric data
• data concerning criminal convictions, offenses, or related security measures

 

Applicable Law:

Refers to the set of regulations concerning the protection of personal data and applicable to the processing of personal data carried out by LIVE POKER, including notably the European Regulation No. 2016/679 on the protection of personal data (GDPR), the amended Data Protection Act, and any other related regulations applicable to Live Poker.

Data Subject/Individual:

Refers to a natural person on whom personal data is focused and who can be identified or identifiable, directly or indirectly, by means of such personal data. This includes, within the scope of this policy, Live Poker's Clients and Prospects who are Professionals.

Data Controller:

Refers to a natural or legal person who, alone or jointly with others, determines which personal data are collected, why they are collected, and how they are collected and processed.

 

GDPR:

Abbreviation for the European Regulation No. 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Subcontractor:

Refers to any natural or legal person, public authority, agency, or other body that processes personal data on behalf of the Data Controller and according to their instructions (for example, service providers or suppliers).

Third Party:

Refers to any natural or legal person, public authority, agency, or any other body other than the Data Subject, the Data Controller, the Subcontractor, and the persons who, under the direct authority of the Data Controller or the Subcontractor, are authorized to process data.

Processing:

Refers to any operation or set of operations performed, whether or not by automated means, and applied to personal data, such as collection, access, recording, copying, Transfer, storage, crossing, modification, structuring, provision, communication, recording, destruction, whether automatic, semi-automatic, or other. This list is not exhaustive.

 

Data Transfer:

Refers to any communication, copying, or movement of data through a network, or any communication, copying, or movement of this data from one medium to another, regardless of the medium, of personal data to a Third Country outside the European Union or to an international organization, which are or are intended to be subject to Processing after such Transfer.