PRIVACY POLICY

Introduction

This Privacy Notice informs you about how we process your Personal Data and Information and about the rights you have with respect to your Personal Data and Information shared with us. Please ensure to go through and familiarize yourself with this Privacy Notice. Please note that unless specifically defined in this Privacy Notice, capitalized terms shall have the meaning ascribed to them in our Terms of Service (Terms). Please read this Privacy Notice in conjunction with our Terms of Service.
This Privacy Notice applies to your use of PokerStars, including without limitation the https://www.pokerstars.in/ Website and the PokerStars mobile application (“Mobile App”) (collectively referred to as “Services”) and outlines our practices in relation to the storage, use, processing, and disclosure of your Personal Data and Information that you chose to share with us when you use our Services. We primarily process your Personal Data and Information to create and maintain a User Account for you and offer you our Services.
We will comply with all applicable legal, regulatory, and administrative/governmental requirements, including, but not limited to, the terms of the Information Technology Act, 2000 and the rules and regulations framed thereunder, as amended from time to time.

Who is the fiduciary controller?

The fiduciary (also known as controller) of your Personal Data and Information is Sachiko Gaming Private Limited (hereinafter referred to as "Sachiko Gaming," “we,” “us,” or “our”). We are committed to protecting your principal personal information (personal data) and respecting your privacy. We strive to maintain the privacy of your Personal Data and Information.

Contacting us

If you have any queries related to your Personal Data and Information and your rights thereof, please contact our customer support. If you require additional support, please contact our Grievance Officer.

How will we use your Personal Data and Information?

The purpose of this Privacy Notice is to enable you to understand how we collect, store, use, and safeguard your Personal Data and Information and for you to understand your rights in relation to that information.

• As part of our User Account opening process across the Services and to allow us to make the Services available to you, we will ask you to provide us with certain Personal Data and Information, including, but not limited to, your name, date of birth, Permanent Account Number (PAN), postal address, your transaction, and behavioural data, contact number, email address, and password (collectively “Personal Data and Information”) as well as to verify that you are at least 18 years old.
• You are reminded that you can only use the Services if you are physically present in India and are not located in any of the Restricted States. In compliance with our regulatory requirements for you to access and use our Services, you hereby consent and permit us, and all third parties acting on our behalf of us, to: (i) use location-based services (LBS) to detect your geographic location from your personal computer/mobile phone/electronic device/mobile application (“Devices”), which may include but not be limited to your IP address, GPS coordinates, cell tower data (such as cell ID and location area code), Wi-Fi connection (such as MAC address), and cookies data; and (ii) undertake the collection, storage, processing, retrieval, and transmission of your Personal Data and Information (which will include but not be limited to your location data) and/or such other data or information that may be derived from your Devices, all in accordance with the purposes described in this Privacy Notice.
• We and our third party service providers may also use any or all of your Personal Data and Information to verify your credentials through third parties, including financial institutions, identification verification agencies, and credit reference agencies, for the purposes of providing our Services to you. In addition, when you use our Services, we also store and share certain Personal Data and Information, including information about your activity on the Services and information held on or derived from Devices that you use, to allow us to enhance our Services as well as to ensure that you are not using any prohibited third party software or tools that may in any way affect our Services. We will take all reasonable efforts to ensure that the information shared by us with third parties is protected in a manner that is consistent with this Privacy Notice.
• If requested by you at initial registration or by checking your marketing preferences in the “My Account” section on the Services, we may send you information by email, text message or post (as selected by you), or by any other electronic modes, or by any contact details you provide directly to us, about our existing and new services, products, and promotions and offers in accordance with this Privacy Notice. We may also share your email address and mobile number with our marketing partners for the purpose of providing you with our promotions and offers in relation to our services. If you do not wish to receive any information about our existing and new services, products, promotions, prizes, and special offers from us, you can tell us not to contact you for marketing purposes at initial registration or by updating your marketing preferences in the “My Account” section of the Services or by clicking on the “Unsubscribe” link in any marketing email that you receive from us. If you request to discontinue receiving marketing communications about our offers and promotions, we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you may need to unsubscribe separately from marketing offers sent by our partners who have received your contact details from us prior to your request to be removed from these lists.
• We may use, share, or disclose your data and information including your personal, transaction, and behavioural data, and/or aggregated and/or anonymized data and information to provide you with marketing and promotional content of third parties, including that of our Affiliates. This includes sharing your Personal Data and information with contracted third-party service providers and partners who assist us or the third parties (to whom we share, disclose your data and information) on our or their behalf to deliver marketing or promotional services, both on our platform (such as in-app messages, banners) and outside our platform (such as through SMS, email, WhatsApp, push notifications, or other digital channels). These Affiliates, third parties and partners will be contractually obligated to handle your Personal Data and Information in accordance with applicable data protection laws.
• Consent to the Use of Other Personal Data and Information for Marketing and Promotions
• By using our services, you consent to our use of your name (full or partial), likeness, tournament wins, and other attributes, whether in an aggregated, anonymized, or identifiable form, for our marketing and promotional purposes. This may include, but is not limited to, showcasing user achievements, testimonials, and other promotional content in our advertisements, social media, leaderboards, and other communication channels.
• We may use your Personal Data and Information for inter-platform gameplay.
• We may disclose or share your data and information, including your Persona Data and Information, transaction, and behavioural data, with one or more of our Affiliates including for the reasons to support platform operations, marketing, analytics, product improvement, fraud prevention, due diligence, and other business purposes, including developing or operating products and services similar or related to us. Our Affiliates will have the right to use and handle this Personal Data and Information for these purposes, in compliance with applicable data protection laws, to ensure a seamless and consistent experience across our services.
• In the event we undertake or subject to (either voluntary or under any legal process) a strategic transaction, sale (either of business or of assets), merger, acquisition, other change in control, your data and information, including your personal, transaction, and behavioural data, may be transferred to another affiliate or successor entity, in accordance with applicable data protection and data localization laws.

Confidentiality

We make substantial efforts to protect the confidentiality of your Personal Data and Information and will not knowingly allow access to your Personal Data and Information to anyone other than to the User or as described in this Privacy Notice. You should also do your part to protect your Personal Data and Information. Your Login Credentials are confidential and you are obligated to keep your Login Credentials secret and confidential at all times and to make the best efforts to protect their secrecy and confidentiality.

Limits of confidentiality

Legally Required Disclosures: Due to the legal, regulatory, and security environment in which we operate, we may be required, as applicable, under certain circumstances, to disclose your Personal Data and Information to third parties, and they may not be permitted to inform you that they have received your Personal Data and Information from us. They, as applicable, will make their reasonable effort to limit such disclosure to the following requirements:

• Where they believe in good faith that it is required to do so in response to a subpoena, warrant or other legal process;
• Where it is reasonably necessary to identify, contact, or initiate legal action against the person(s) or entities to preserve and/or enforce their rights.

Your rights in relation to your information

We aim to keep the information about you as accurate as possible. You can write to us at any time to review, change, obtain a copy of your information, or have your details changed or corrected in accordance with your rights under applicable legislation, and in such an event we may require the evidence of your identity. To contact us regarding your information, please email our customer support in the first instance. We may in certain circumstances levy a small charge to cover the cost of administration related to any request made by you in this regard if the information is given to you in writing. Please note that if you request us to close or deactivate your User Account for any reason, your Personal Data and Information will be retained for such period as may be required under the applicable anti-money laundering regulations or other regulatory requirements and all other applicable laws in India. Once your account is deactivated, you will not be able to access your account.

Cookies

In this Privacy Notice, we use the term “cookies” to refer to cookies and similar technologies (such as web beacons) we use to store information. A cookie is a simple text file that is stored on your computer, mobile or any other device by a website's server, and only that server is able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and characters.
We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited our Website/Services, and to show you advertisements that are more relevant to your interests. We may use the data generated from cookies to compile statistical data on your use of our Services. You are not obliged to accept cookies from us, and you have the ability to accept or decline cookies by modifying the settings in your browser.

Telephonic Communications

We may record telephone conversations between you and our customer support representatives for purposes including quality assurance, employee training, dispute resolution, and service improvement. By contacting our support team via phone, you acknowledge and consent to such recordings, in accordance with applicable laws.

Privacy Measures for Minors

Our Services are meant only for persons aged 18 or above. If you are under 18 years of age, you are not permitted to use our Services. If you are a parent and/or guardian and believe that we may have inadvertently collected any Personal Data and Information from your child, you can notify us immediately by emailing at [email protected].

Limitation of liability

Sachiko Gaming confirms that this Privacy Notice is only a description of its operation regarding user information. This Privacy Notice is not intended to create, and does not create, any legal rights in your favor or in favor of any other person or party. Sachiko Gaming reserves the right to change this Privacy Notice at any time without giving you prior notice. The liability of Sachiko Gaming shall be limited to the removal of Sensitive Personal Data and Information from the system of the Services and the removal of personally identifiable elements of other Personal Data and Information. Notwithstanding anything to the contrary contained in this Privacy Notice and elsewhere, the aggregate liability of Sachiko Gaming for all claims for damages pursuant to the provisions of the Services, including claims in respect to the violation of this Privacy Notice, shall be limited to the aggregate maximum amount of liability as provided in the Terms of Service. Your continued use of the Services constitutes your agreement to this Privacy Notice and any amendments hereof.

Account Deletion

Users are entitled to delete their PokerStars accounts, along with their Personal Data and Information, by using the account deletion option provided on the PokerStars app available on Google Play Store.
If you proceed with the permanent deletion of your account, you will lose access to PokerStars and all the Services, including all user data and Personal Data and Information associated with your PokerStars account.
When you request the deletion of your data, we follow a deletion process that ensures that your data is removed from our servers. The deletion of your account and data from our active and backup systems may take time and sometimes there may be a delay as well. Please note that some user data may be retained for the purposes of security, fraud prevention, and regulatory compliance.

Grievance Officer

Sachiko Gaming currently appoints Mr. Jai Sharma as its Grievance Officer. All complaints related to your Personal Data and Information must be made to our Grievance Officer at [email protected].