1.

1. The purpose of this Privacy Notice is to inform You of how the Company collects, processes, uses, stores and protects Your Personal Data as well as the rights You have with respect to the processing of Your Personal Data. “Personal Data” as defined in the GDPR, means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. By visiting Our Website and using Our Services, You acknowledge reading and fully considering this Privacy Notice.
3. The Company acknowledges that in collecting Your Personal Data We are bound by the Data Protection Act 2018 and the Applied GDPR of the Isle of Man (“IOM Data Protection Laws”) and will process Your Personal Data in accordance with the IOM Data Protection Laws.

2.

The Data Controller of Your Personal Data is Uptick Entertainment IOM Limited, an Isle of Man Company with registration number 134823C having its registered address at Park House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2SA, Isle of Man (the “Company” “We” “Us” “Our”). Uptick Entertainment Isle of Man Limited is part of the 4Group.

3.

For any further information about this Privacy Notice and how We use Your Personal Data or for any request you may have, you can contact our Data Protection Officer through the following email address: [email protected] or by certified post to our registered address at Park House, Isle of Man Business Park, Douglas, Isle of Man, IM2 2SA, Isle of Man.

4.

Capitalised terms in this Privacy Notice shall have the meaning assigned to them under the IOM Data Protection Laws and shall be construed accordingly. Furthermore, the following definitions shall apply:

• Account – an account provided to You by the Company upon Your registration and acceptance of the Terms and Conditions for use of the Services on Our Website.
• Applied GDPR - the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced, or superseded and in force from time to time. In the form contained in the Annex to the GDPR Order.
• GDPR Order - Data Protection (Application of the GDPR) Order 2018.
• Services – the Services provided by the Company through the Website, Games or Software, as defined in our Terms and Conditions.
• User – any person who registers an Account or accesses and browses the Website (“You”, “Your”).

5.

1. This Privacy Notice describes our approach to data protection in relation to Our Users and sets out the basis upon which any Personal Data We collect from You or that You provide to Us, will be used by Us.
2. Please read this Privacy Notice carefully to understand our practices regarding the management of Personal Data we collect from You.

6.

1. We fully respect Your fundamental rights and consider the protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We
   respect the following basic principles:
   1. We submit Your Personal Data only to lawful and fair processing, and We maintain full transparency about the way We handle Your Personal Data.
   2. We collect and process Your Personal Data only for specified, explicit, and
      legitimate purposes as outlined in this Privacy Notice, and We do not process
      it further in any manner incompatible with these purposes.
   3. We process Your Personal Data only to the extent that it is necessary and
      appropriate to purposes for which it is collected.
   4. We make reasonable efforts to ensure that Your Personal Data is accurate
      and updated, taking all reasonable steps to correct it in case of inaccuracy.
   5. We process Your Personal Data by using appropriate technical and organizational measures.
2. In general, We comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.

7.

The Company collects Your Personal Data from the following sources:

• When You visit our Website, register an Account, and use Our Services;
• From third party professional advisors: such as fraud prevention companies and ID verification providers;
• Through the use of Cookies: for more information about how we use Cookies, see Our Cookie Notice at www.4poker.com/cookie-policy.

8.

The Company collects and processes the following types of Personal Data:

1. Personal Data for Account registration and use of Our Services, including but not limited to:
   1. Name and Surname;
   2. Username and password;
   3. E-mail address;
   4. Residential address and country;
   5. Date of birth;
   6. Phone number;
   7. Proof of identity (e.g. National ID card, Passport or Driving License, digital photo);
   8. Proof of address (e.g. Utility bill, lease agreement etc);
   9. Proof of payment (e.g. copies of cards, bank statement etc)
   10. Source of wealth information (e.g. pay slips, annual tax returns etc.).
       
       
2. Operational data relating to Your use of the Services, including but not limited to:
   1. Transactional data (e.g. payment Method details);
   2. Game activity data (e.g., gameplay, logins);
      
      
3. Technical data relating to Your use of the Website, Our Services and Our use of cookies, including but not limited to:
   1. IP Address;
   2. End user device data;
   3. General communication data;
   4. Service usage data.
   5. Browsing data;
   6. Information on user preferences regarding the Website.
      
      
4. Photo image and video data relating to Your participation in Poker tournaments, competitions and events:
   1. Photo image data;
   2. Video image data.
      
      
5. Depending on the circumstances of the relationship, we may collect additional Data, including Personal Data relating to any third parties involved in your Account activities.

9.

1. Contract:
   The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions which form a contract with you, for the following purposes:
   • Administration and development of the Website and the Services;
   • Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Services;
   • Fulfillment of Your requests and queries in relation to the Services;
   • General improvement and maintenance of the Website/Application and the Services;
   • Notification of important updates to our Website/Application and the Services and
   • Verifying compliance with the Terms and Conditions of the Website.
2. Legal Obligation:
   The Company may process Your Personal Data to comply with its legal obligations, for the following purposes:
   • Detection, investigation and prevention of fraudulent behavior and other illegal activities and protection of Your rights and the rights of the Company; and
   • Implementation of responsible gaming measures as well as any other measures under the applicable regulatory requirements.
3. Legitimate Interest:
   The Company may process Your Personal Data based on Our legitimate interest to promote our Services and develop our business, for the following purposes:
   • Development of new products, utilities and offerings;
   • Conduct market research; and
   • Commercial communication, marketing and advertising of Our Services.
   • To run our competitions on our social media platforms.
   • To post players' reviews on our website.
4. Consent:
   The Company may process Your Personal Data only with Your lawful consent for the following purposes:
   • Commercial communication, marketing, and advertising of Our Services which includes posting on our social media platforms.
   • To run our competitions on our website.
   • You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your data prior to its revocation.

10.

1. For the execution of the purposes mentioned in this Privacy Notice, We may provide access or transmit Your Personal Data to the following recipients (“Data Processors”), including but not limited to:
   • Internet and data hosting providers for storage and hosting purposes;
   • Game providers for gameplay purposes;
   • Third-party providers for the smooth operation of Website and Our information and communication systems; and
   • Third-party providers and consultants for data analysis, ID verification and regulatory monitoring purposes;
   • Payment providers for payment facilitation purposes
   • Marketing providers and suppliers for marketing and promotional purposes,
   • Group Companies for operational purposes,
   • Third party professional advisers for legal and compliance purposes.
   • Player Agents on the player agent portal when you register an Account with Us through a player agent.
2. The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.
3. If We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities such as money laundering and in any other case that We are legally bound to do so, the Company may transfer Your Personal Data to public authorities to the extent specified by law.

11.

We make use of certain Data Processors which are located outside of the European Union. In such cases, We take all reasonable steps possible to ensure that Your Personal Data is treated as securely as it is within the European Union and in accordance with this Privacy Notice and applicable legislation. These measures include entering into the Standard Contractual Clauses issued by the European Commission.

12.

1. In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies internal policies and takes all appropriate organizational, technical, and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations. The Company cannot promise or guarantee protection from unauthorized or accidental access, processing, deletion, alteration or other use of your Personal Data, however all appropriate measures are taken at all times to protect and help prevent your Personal Data being compromised.
2. The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance
3. Your Personal Data is processed solely by authorised personnel of the Company, bound by strict obligations of confidentiality.

13.

1. We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Notice, in accordance with the Data Minimisation and Storage Limitation principles.
2. Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes for the following reasons:
   • In case We have a legal obligation to retain Your Personal Data under a relevant statutory provision.
   • Based on Our legitimate interest to defend the Company against any potential legal claims, before any competent court or public authority.
3. After the period of retention, Your Personal Data is erased or anonymized from Our databases and systems.

4. For more information about data retention terms in relation to specific Personal Data, please contact Us at [email protected].

14.

1. You have the right:
   • To request access to Your Personal Data and information related to its processing and obtain a copy thereof.
   • To request for the rectification of any inaccuracies or any missing Personal Data of Yours.
   • To request the erasure of Your Personal Data.
   • To request the restriction of the processing of Your Personal Data in cases explicitly provided for by law.
   • To request the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format.
   • To object to the processing of Your Personal Data in cases explicitly provided for by law.
   • To object to a decision taken solely on the basis of automated processing, including profiling, which has impact on You or significantly affects You
2. If you have any requests relevant to the above Section 14.1, please send an email in writing to [email protected].
3. If You feel that Your rights are infringed, You have the right to file a complaint with the Isle of Man Information Commissioner at the following website https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/.

15.

1. By using Our Website and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate and complete data as requested by the Company. Furthermore, we request that You inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.
2. We retain the right to reject Your application for registration or to suspend or terminate Your Account immediately without notice if you do not adhere to your obligations. Please be aware, in such case, You have no right to any compensation due to the rejection of Your application, or the suspension or termination of Your Account.

16.

Our Website uses cookies. For more information, please review Our Cookie Notice https://4poker.com/cookie-notice.

17.

We will post any changes on the Website and when doing so will change the effective date at the top of this Privacy Notice. Please make sure to check the date when You use Our Services to see if there have been any changes since you last used those Services.

In some cases, We may provide you with additional notice of changes to this Privacy Notice, such as via email. We will always provide You with any notice in advance of the changes taking effect where We consider the changes to be material.