PRIVACY POLICY

1.- Purpose

The objective of this personal data protection policy is to disclose the way in which POKER PEEK SOFTWARE, S.L. (hereafter “POKER PEEK”) gathers, processes and protects personal data that is provided or that we collect, in accordance with Regulation (EU) 2016/679 of the European Parliament and Council of 27th April 2016 (on the protection of natural persons with regard to the processing of personal data and on the free movement of such data), organic Law 3/2018, of 5th December, on the protection of personal data and the guarantees of digital rights, and other regulations on personal data protection.

2.- Data Controller

The party responsible for the personal data that is provided or collected through other means is POKER PEEK, with C.I.F. (Fiscal Identity Code) nº B02690808, based in c/ Saragossa, 95, Entreplanta (Mezzanine) 3, email legal@pokerpeek.com and contact telephone number +34 654 365 720.

3.- Website

POKER PEEK’s “Website” is comprised of the website (www.pokerpeek.com) and its applications.

The “Website” is owned by POKER PEEK and may contain links to other third-party websites with protection policies that are different to POKER PEEK’s. When accessing these third-party websites, the user can decide whether to accept their data protection and cookie policies, in accordance with current regulations.

4.- Platform users, Clients and Potential clients

Platform users, clients and potential clients are hereby informed of the personal data that can be collected, of its purpose and of the legal grounds for processing data.
DATA:

• Identification data: name, nickname, date of birth, gender, country of residence, language.
• Credentials: passwords
• Contact details: email.
• Voice data: voice data, such as search queries o voice commands, which may include background sounds.
• Images: Images and related information.

PURPOSE OF PROCESSING PERSONAL DATA:

• The purpose of personal data processing is to create elaborated user profiles that will make it possible to create, manage and administer groups or player clubs, which will also have an elaborated profile, and to organize poker tournaments on the platform offered by POKER PEEK.
• Provided we are given express prior consent by the user, processing can also consist of participation in promotions, competitions, the reception of communications, etc.
• It also aims to ensure a secure service and to manage queries, information requests or claims, as well as asking for reviews with regard to our services.

LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA:

• In general, the legal basis that legitimizes the processing of personal data by POKER PEEK is our compliance with legal obligations or public interest or exercising of public powers conferred on POKER PEEK.
• Some processing may require the consent of the interested parties (participation in promotions, competitions, receiving communications). This consent will have to be provided through clear affirmative action and it can be revoked at any time by the interested party.
• Other types of processing are based on the legitimate interest we have to manage and respond to information requests at POKER PEEK, as well as the feedback provided with regard to our services and functioning or sending users communications of interest related to procured services.

5.- Tenderers, subcontractors and providers, commercial partners, collaborators and administrations.

Tenderers, subcontractors and providers, commercial partners, collaborators and administrations are hereby informed of the personal data that can be collected, of its purpose and of the legal grounds for processing data.

DATA:

• Identification data of our contact persons in these companies.
• Contact details: address, telephone and email.

PURPOSE OF PROCESSING PERSONAL DATA:

• We will process the collected contact details through our Websites’ contact channels, emails or forms in order to manage your requests, claims, information and collaboration requests, as well as to manage public tenders that have been submitted by yourself.
• In order to manage the contractual relationship that unites us, in other words, to contact you.

LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA:

• In general, the legal basis that legitimizes the processing of personal data by POKER PEEK is the compliance with the legal obligations derived from our business, commercial or administrative relationship.
• Other types of processing are based on the legitimate interest we have to manage and respond to your requests, such as when you contact us to offer a commercial service or request information with regard a tender.

6.- Personal data collection and processing registry

POKER PEEK processes your personal data in a fair, lawful and transparent manner and limits the purposes for which it was collected.

Personal data collected from interested parties are incorporated to the processing owned by POKER PEEK and form part of our Processing Activities Registry.

This personal data will be kept confidential and in a way that guarantees a security that is suitable for the protection of this data.

7.- Processing of deposits and reimbursements

The platform is temporarily in its test phase and the services are free of charge for all users, which means that no payment mechanism is in effect.

8.- Communication of personal data

POKER PEEK will not communicate any personal data without the consent of the interested parties, unless it is under the circumstances specified in the current legislation, as well as in Law Enforcement Bodies and State Security Forces, Courts and Tribunals and Public Administrations with the competence in this matter.

9.- Data retention

Generally, the data processed by POKER PEEK will be kept for the time needed to fulfil the purpose for which it was collected, taking into account the time limits set by the general regulation and, specifically by Law 10/2001, of 13th July, and Decree 13/2008, of 22nd January, without prejudice, in any case, of it being made available to the relevant authorities or to address complaints. In this case, the data will be blocked and kept until the statute of limitations has expired, at which time it will be deleted.

10.- Confidentiality

At POKER PEEK we process your personal data confidentially, committing ourselves to maintain secrecy and adopt the necessary measures to prevent any unauthorized alteration, loss, processing or access, in accordance with the legal obligations that are applicable to us as the responsible party in processing your personal data.

For this reason, we commit to maintaining and applying the necessary levels of security, taking into account the state of technology, the type of data stored and the risks. All of this is to ensure personal data is protected against accidental loss and unauthorized access, processing or disclosure, and to avoid disclosure of information, provided that it does not obey the strict performance of an order or the fulfilment of a legal obligation. To sum up, we process your data in accordance with the current legislation relevant to data protection.

11.- Transfers of personal data outside the European Economic Areas (EEA)

In general, international transfers of data are not planned, notwithstanding those cases where it is required to do so, the interested party will be informed and the necessary measures will be adopted to ensure they are carried out with all the required legal guarantees.

However, if the data had to be given to entities outside the EEA, POKER PEEK will ensure that these third parties have sufficient guarantees, as established by the current regulations on data protection.

12.- Data Protection Rights

Access to your Personal Data: It is your right to request and obtain information with regard to your personal data that are held by POKER PEEK, as well as their processing, for what purpose and what specific use is made of them.

Right of rectification: It is your right to rectify your personal data when it is incorrect or incomplete.

Right to erasure: It is your right to request the removal of access to your personal data when they are inappropriate, excessive or unnecessary, when they are kept for a longer period of time than required or if they infringe any Regulations.

Right to object: It is your right to request that your personal data are not processed in any way.

Right to restrict processing: It is a right that consists in marking your personal data that is held by POKER PEEK with the purpose of processing them in the future.

Right to data portability: It is your right to receive the personal data provided by POKER PEEK in a structured format, one which is commonly used and machine-readable, and to transfer them to another data controller, if the processing is based on consent or under a contract or tis done through authorized means.

Right not to be subject to automated individual decisions: It is the right that consists in not being subject to a decision solely based on the automated processing of the data, including profiling, which have legal implications for you and affect you in a significant manner.

Information on exercising rights can be found at Ejercicio de derecho RGPD (Exercising GDPR rights).

You also have to right to issue a complaint, at any time, to the Catalan Data Protection Agency with regard to the processing of your personal data.

13.- Changes to our notice

If we change the way in which we process Personal Data, we will update this Policy and the relevant Privacy and Data Protection Legal Notice/Disclaimer. We reserve the right to make changes at any time to our practices and to this Policy and therefore ask you to consult it frequently to check if there are any updates or changes.

14.- More information

We will be delighted to provide more information with regard to how we protect and use your personal information. Contact us at the following email address legal@pokerpeek.com.

You can also find useful information with regard to privacy and data protection in the office of the Spanish data Protection Agency.