Privacy Police
2018-05-25 00:00
1. Introduction
Welcome to the services of AA Poker and its affiliates ("AA Poker", "we", "us"). We are committed to protect and respect your privacy. This Privacy Policy (together with our Terms of Use https://www.aapoker.com/terms and any other referred documents in it) applies to AA Poker, mobile applications, services and websites, including https://www.aapoker.com/ and any of its subdomains (the "Site") , and sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled by us. In this Privacy Policy, the term "personal data" means information that relates to an identified or identifiable natural person.
This Privacy Policy applies whenever you use our "Services," which means our games, products, services, content, aapoker.com, and/or other domains or websites operated by AA Poker. It describes how we collect, store, use, and disclose your personal information when providing these Services to you, and your rights and choices concerning your information.
If you do not want AA Poker to collect, store, use, or share your information in the ways described in this Privacy Policy, you may not play AA Poker or use AA Poker's other Services, or opt-out from data collection and keep on using AA Poker Services.
2. Information We Collect and How We Collect It
Information About You That You Share With Us Directly
When you use our Services, you may give us information directly (like when you're setting up your account), and we'll store that information on our systems and use it for the purposes described in this Privacy Policy.
Some games or parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us information like:
your first and last name;
your username;
your gender;
your age or birthday;
your e-mail address;
other information that help us make sure it's you accessing your account or help us improve our services.
Payment Information
If you purchase in-game virtual currency, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address, and financial information. AA Poker's payment processors do not share your financial information, like credit card numbers, with AA Poker, but they may share non-financial information with us related to your purchases, like your name, billing address, and the items purchased.
When you play AA Poker or access any of our other Services on connected third-party applications or platforms (like Facebook, Apple, Google), any purchases you make will be processed by that third-party application and subject to that third-party application's terms of service and privacy policy. For these purchases, AA Poker does not receive your financial information, but may receive non-financial information related to your purchases, like your name, approximate physical location, and the items purchased. The information AA Poker receives depends on the game you're playing and the third-party application
Customer Support Correspondence
When you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your user ID number. We will also store the communications you have with our Customer Service team and any additional information in those communications in order to provide support and improve the Services.
Information About You That We Get From Connected Third-Party Applications, Including Social Networks
If you play AA Poker or access any of our other Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, AA Poker may receive certain information about you from the provider of the third-party application. The information we receive depends on the game you're playing, the third-party application, your privacy settings, and, if applicable, your friends' privacy settings on that third-party application.
For example, AA Poker may collect and store some or all of the following information from the provider of the connected third-party application:
Device data: We collect information on the device you use to access the Service (including the Games). This device data includes, without limitation, device manufacturer and type, time zone, information about the operating system of your device, the name of your carrier / internet service provider, connection type, device language, unique device identifiers, iOS device name, Android ID, Advertising ID, IDFA (unique identifier for iOS), GAID (unique identifier for Android), country, locale, and the Internet Protocol (IP) address from which you access the Service. In particular, we may use the device data for automatically creating an account for you to be used when you play the Games, so that we will recognize your device when you play the Games. Moreover, the logging technology used in the Service may automatically collect the URL of the site from which you came and the site to which you are going when you leave the Service. We may also use device data to identify the device throughout different Games.
If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application's terms of service and privacy policy.
If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.
Cookies and Other Automated Information Collection
We use cookies to recognize you and/or your device(s) on, off, and across different Services and devices. You can control or opt out of the use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising.
We, our service providers, and our business partners use these cookies and other similar technologies to collect and analyze certain kinds of technical information, including:
IP address;
the type of computer or mobile device you are using;
platform type (like Apple iOS or Android);
your operating system version;
your mobile device's identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (GAID)
application performance and de-bugging information;
your browser type and language;
referring and exit pages, and URLs;
the number of clicks on an app feature or web page;
the amount of time spent on an app feature or web page;
domain names;
landing pages;
pages viewed and the order of those pages; and/or
game state and the date and time of activity on our Services.
In some cases, we will connect the above information with your social network ID or AA Poker user ID.
If you play AA Poker on a mobile device, in addition to your device identifiers (described above), we may also collect:
the name you have associated with your device;
your country;
your specific geolocation (with your permission);
information about the AA Poker games and other third-party apps you have on your device.
Other Sources
We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.
3. How We Use Information We Collect and Our Legal Bases for Processing It
The main use of the information we collect and store is to provide you with the Services you request from us and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:
to improve and optimize our Services and our players' experiences;
to create your game accounts and allow you to play our games;
to identify and suggest connections with other AA Poker players and personalize our Services to you;
to communicate with you about the Services you're using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;
to provide technical support and respond to player inquiries;
to protect the safety and well-being of our players;
to protect AA Poker's rights and property in connection with our Services;
to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
to manage and deliver contextual and behavioral advertising;
to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and/or
to conduct research.
If you are located in the European Countries, our legal basis for collecting and using the information described above depends on what the information is and the context in which we collect it.
However, we'll normally collect information from you only where we need it to perform our contract with you (i.e., our Terms of Service), where the processing is in our legitimate interests (provided that these aren't overridden by your interests or rights), or if we otherwise have your consent.
In some cases, we may also have a legal obligation or need to collect information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, another player).
If we ask you to provide information to comply with a legal requirement or to perform a contract with you, this will normally be clear from the context in which we are asking you to provide your information (for example, when we ask you to provide a username to access our Services, this will be to create an account for you in accordance with our Terms of Service), and, if not, we will provide an explanation to you at the relevant time. We will also make clear whether providing information is mandatory.
Similarly, if we collect and use your information in reliance on our legitimate interests (or those of any third party), it will be made clear to you at the relevant time what those legitimate interests are (such as personalizing our services and marketing, for example).
If you have questions or need further information about the legal bases on which we collect and use your personal information, please email us at aapoker@memoriki.com
4. How We Share Information
We may share your information, including personal information, with third parties or allow third parties to collect this information from our Services in the following circumstances:
Friends and Other AA Poker Players
AA Poker and Services support and often encourage you to interact with other players. In AA Poker, if you play through a social network or connect to a social network (for example, Facebook), your social network friends who also play AA Poker will see your name, photo, player profile (which may include the information described above in Information About You That You Share With Us Directly), and descriptions of your in-game activity.
In addition, in AA Poker, other players, regardless of whether they are your social network friends, will be able to see your player profile (as described above); view descriptions of your in-game activity and send you game requests or friend requests through our Services or the related social network. For example, in AA Poker, when you are playing at a table, all the other players at the same table can see your player profile.
Safety, Security, and Compliance with Law
Your information, and the contents of all of your online communications in our Services and between you and AA Poker may be accessed and monitored as needed to provide our Service and may be disclosed:
to satisfy any laws or regulations that apply;
when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
to protect the rights or property of AA Poker or applicable third parties, including to enforce our Terms of Service.
Third-Party Service Providers
We will share your information with third-party companies who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing, and advertising optimization. We will also share your information with our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (Apple, Google, Facebook, etc.). Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information (as required by applicable data protection laws).
Other Third Parties
In addition to the sharing described above, we may share your information with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so.
5. Your Rights and How to Access, Update, and Manage Your Personal Information
European Countries' Users' Rights
If you are located in the European Countries, you have the following data protection rights:
You can access or request deletion of your personal information by submitting a request by email us at aapoker@memoriki.com.
You can correct or update your personal information, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
You can opt-out of marketing communications we send you by following the instructions in "Opting Out of Promotional Communications from AA Poker" below.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
To exercise your rights to access or deletion, please submit a request by email us at aapoker@memoriki.com. If you would like to exercise any of your other rights, you can also email us at aapoker@memoriki.com. We respond to all data protection requests we receive in accordance with applicable data protection laws.
Accessing and Deleting Personal Information Held by AA Poker
Click " Avatar Pictures " at upper left corner of the lobby to review and update your personal information regarding AA Poker player profiles in a specific game.
If you want to review or delete personal information associated with your game account data, please submit a request by email us at aapoker@memoriki.com.
For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We'll also keep information in order to exercise, defend, or establish our rights.
Managing Personal Information We Receive From Third-Party Applications / Platforms And From Your Mobile Device
To manage the information AA Poker receives about you from a third-party application or platform where you play our games, like Facebook, Apple, Google, you will need to follow the third-party application instructions for updating your information and changing your privacy settings.
You also can manage many aspects of information collection and use from your mobile device by visiting the "settings" page of your mobile device or web browser and reviewing the access permissions of AA Poker.
To the extent that one of our games is collecting information about non-AA Poker applications you have on your mobile device, the game will provide you with an option to stop making that information available to us in the game's "settings" page.
Once AA Poker receives your information from a third-party application / platform or your mobile device, that information is stored and used by AA Poker in accordance with this Privacy Policy. You may access and update that information as described above.
Opting Out of Promotional Communications from AA Poker
If you want to stop receiving promotional e-mails from AA Poker, click on the "unsubscribe" link at the bottom of any promotional email from AA Poker. Your unsubscribe request or e-mail preferences change will be processed promptly, and in no event longer than thirty business days. During that processing period, you may receive additional promotional emails from us.
If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device's "settings" page. Many of our games also offer the ability to turn off push notifications in the in-game "settings" page.
Please note that if you opt out of receiving promotional communications from us, we may still communicate with you from time to time if we need to provide you with information about the Services you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service.
6. Privacy Policies of Linked Third-Party Services and Advertisers
Our websites and games may contain advertisements from "Third-Party Services," meaning companies other than AA Poker, that may link to their own websites, online services, or mobile applications. We are not responsible for the privacy practices or the content of these Third-Party Services. If you have any questions about how these Third-Party Services use your information, you should review their policies and contact them directly.
7. Our Policies Concerning Children
Generally speaking, most of our Services are not intended for children under the age of 13 (or under 16 for children located in the European Countries) (collectively, "Children"). Children are not permitted to use these Services, and we do not knowingly collect any personal information from Children.
Though our Services do not target Children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as Children in our age-gate on such Services, if we allow Children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose "personal information" (as defined in the Children's Online Privacy Protection Act ("COPPA")), except as permitted by COPPA, or obtain legally valid parental consent.
If we learn that we have inadvertently gathered personal information that is not subject to a COPPA exception from a Child, we will take reasonable measures to promptly remove that information from our records.
8. International Operations and Transfers Out of European Countries
IMPORTANT: When you use our Services, your personal information may be sent to the South Korea and possibly other countries.
As part of our international operations, we may transfer personal information to our "Affiliated Entities," which are any other corporate entities under common ownership with AA Poker., or to our business partners and service providers from time to time for our legitimate business purposes.
We store personal information about players and visitors to our sites on servers located in the South Korea, and we may also store this information on servers and equipment in other countries. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, one of our Affiliated Entities, or one of our business partners or service providers. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details, or (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully, and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.
9. How Long We Keep Your Information
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.
We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
10. Security of Your Information
We implement reasonable and appropriate security measures to help protect the security of your information both online and offline and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.
If you have an account registered directly with AA Poker, your profile information is protected by your AA Poker account. It is important that you protect and maintain your AA Poker account's security and that you immediately tell us of any unauthorized use of your account. If you forget your AA Poker account, please email us at aapoker@memoriki.com. If you access our Services through a social network and your social network account is hacked or otherwise compromised, this may lead to someone accessing or deleting your AA Poker game accounts without your permission. So, be careful to keep your social network account information, including your social network account password, secure as well.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk. If you have questions about the security of our websites, please contact us via e-mail us at aapoker@memoriki.com
11. Changes to Our Privacy Policy
If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice in-game or on https://www.aapoker.com, or by sending you a notice to the e-mail address we have on file for you before the change becomes effective (and we will ask for your consent where required by law). We may supplement this process by placing notices on game blogs, social network pages, and/or player forums. You should periodically check https://www.aapoker.com and this Privacy Policy for updates.
12. Contact Us
Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data we hold about you, please contact us via e-mail at aapoker@memoriki.com. We seek to promptly resolve any concerns you may have.