Online Poker

Privacy Policy

This Privacy Policy was updated on 4th September 2024.

1. Introduction

Replay Digital Ltd (“Replay”, “we”, “us”, “our”) develops and operates the Replay Poker social poker game. Replay is committed to protecting the privacy of its users and provide them a better social Digital experience ("users" or "you").

This Privacy Policy applies whenever you play Replay Poker or otherwise access any of our other products, services, content or webpages provided by Replay, together referred to as “Services”.

This Privacy Policy has been created to inform you about how Replay manages, collects, stores, shares, uses and protects the information you provide whenever you play our games or otherwise access any of our Services.

Replay Digital Ltd is the data controller in respect of personal data processed when you access any of our Services.

This Privacy Policy describes:

  • what information we collect, how we collect it
  • how we use that information and with whom we share it
  • how you can access and update that information and means of communications
  • how we protect children’s privacy
  • how we protect the information we store and share about you

By using the Services, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want Replay to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play Replay’s games or use our Services. Replay may amend the Privacy Policy from time to time, and Replay encourages you to consult the Privacy Policy regularly for changes.

Users in certain jurisdictions have a right to access Personal Information held about themselves. Your right of access can be exercised in accordance with applicable law. For more information on this and other rights, please see below.

2. Information We Collect and How We Collect It

Replay only collects personal information to the extent necessary to fulfil one or more of its functions and activities and will do so only by fair and reasonable means. Generally, we will collect personal information directly from the individual to whom the personal information relates, but in some circumstances (including as outlined below), we may collect information from a third party source.

Information About You That We Get from Third-Party Applications, Including Social Networks (like Facebook)

If you play Replay’s games or connect our Services to any third-party applications, including social networks like Facebook or via Google, Replay may receive certain information about you from the provider of the third-party application. The information we receive depends on your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

For example, Replay may collect and store some or all of the following information shared by the provider of the connected third-party application:

  • your profile picture or its URL;
  • your user ID number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo;
  • the user ID number and other public data of your friends;
  • the login e-mail you provided to that third-party application when you registered with it;
  • your gender;
  • your birthday;
  • whether you like our Facebook page;
  • any other information that you or the provider of the third-party application share with Replay.

If you 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 Information Collection

Like many websites, Replay and service providers acting on our behalf, like Adobe Analytics, store log files and use tracking technologies such as "cookies", or other similar technologies such as pixels or web beacons, to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of Replay’s Services, tailoring recommendations to interests, and making the Services easier to use.

We give you the option to select which cookies you are happy to use, prior to using the Service. You can update these preferences at any time. If you do not accept cookies, however, you may lose some of the features or functionalities of the Services.

The Replay website is hosted on a third party domain, so the cookies that are used will appear on your browser settings under the host domain, not Replay. Please note that no cookie data in respect of your use of the Replay services will be accessed by the operator of the third party domain. For more information on the specific types of cookies that we use, please contact us at legal@replaypoker.com or submit a ticket via the applicable support channel of the game.

We and our service providers use log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:

  • the type of device you are using;
  • your operating system version;
  • your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
  • your browser types;
  • your browser language;
  • referring and exit pages, and URLs;
  • platform type;
  • the number of clicks on a page or feature;
  • domain names;
  • landing pages;
  • pages viewed and the order of those pages;
  • the amount of time spent on particular pages; and
  • game state and the date and time of activity on our websites or games.

In some cases, we will connect this information with your social network ID or Replay user ID.

Some traffic data is proxied through the host domain to Replay. For the avoidance of doubt, no data is accessed by the operator of the host domain, which serves purely as a conduit for Replay traffic data.

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 will store that on our systems and use it for the purposes described in this Privacy Policy.

During the account set-up process you will be asked for the following information:

  • your e-mail address;
  • a username;
  • a password;

We also enable you to create a Replay player profile, separate from your social networking site profile (for example, your Facebook profile), that other Replay players can see. Your player profile may include information like:

  • a profile picture;
  • your real name;
  • your gender;
  • your date of birth;
  • your city;
  • a biography about yourself;
  • the country where you last accessed the Service from;

We will also collect information about your marketing preferences, including how we can communicate to you about promotions or offers we think you might be interested in.

Communications Features

You can take part in certain activities on our Service that let you communicate or share information not just with Replay, but also with other Replay players. These include:

  • participating in player forums and message boards;
  • posting public comments to hand replays and our blog;
  • sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts; and/or
  • chatting with other players

You acknowledge and expressly agree that we may access in real-time, record and/or store archives of these communications and comments on Replay's servers to make use of them to protect the safety and well-being of our players and Replay’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver contextual advertising.

Payment Information

Replay may obtain the billing and payment information that you provide when your purchase is processed by our payment partners (like Paddle). Our Terms of Service explain our policies and terms relevant to our charges, billing practices and virtual currencies.

If you purchase virtual curency in a Replay game, 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.

Replay does not collect or store your financial information, like credit card numbers. However, Replay’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased in order to fulfil your order.

Message Boards and Chat Rooms

You may be able to take part in certain activities on our websites or games that give you the opportunity to communicate or share information not just with Replay, but also with other users of our Service. Note that certain information you post and communicate through a Service or a third party site or service is public information for which you have no expectation of privacy.

You may choose to disclose information about yourself in the course of contributing user generated content to Replay Services or in its chat rooms, blogs, message boards, hand replays, user “profiles” for public view or in similar forums on its sites through mobile services and/or through third party sites or services, posting public comments to other users' profiles or gameboards, sending private messages or invitations to other users, either directly on our websites or to their email accounts. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality.

You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. Replay is not responsible for the personally identifiable information you choose to make public in any of these forums. We may also record and store archives of these communications to protect the safety and wellbeing of our users and Replay's rights and property in connection with the Services. You acknowledge and consent to the recording and storage of such communications for these purposes.

If you post a video, image or photo hrough a Service for public view, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. Replay is not responsible for the videos, images or photos that you choose to post through a Service. Please see Replay’s Terms of Service on this point and for other guidelines about posting content through any Service.

Customer Support Correspondence

Except as provided herein, 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 Replay player and ID number. We will also store the communications you have with the Customer Service team and any information in those communications in order to provide support and improve the Services.

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.

We may also receive information from other companies, for example where we have an existing commercial relationship with them or if they are an Affiliate. Such information could include, but is not limited to, analytics data, profile data or market research information. Any information we receive from third parties will be processed in accordance with this privacy policy.

If you would like to learn more about how we secure your information, please see Security of Your Information section below.

3. Legal Basis

We will only collect or use your personal data where we have a legal basis to do so in line with data protection law. These include:

Performance of a contract with you

Where we need to perform the contract we are about to enter into or have entered into with you, such as when you purchase virtual currency or take out a subscription.

Legitimate interests

We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligation

We may use your persona data where it is necessary for compliance with a legal obligation that we are subject to.

Consent

We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example when you sign up and opt in to receive marketing communications.

4. How We Use the Information We Collect and With Whom We Share It

How We Use Your Information

The main use of the information we collect and store is to provide a better Digital experience, but there are other uses as well. Where we use information to provide or improve the Services, our legal basis for processing such data is that we have a legitimate interest to do so. The uses for which we collect and store your information include:

  • to create your game accounts and allow you to play our games;
  • to operate, improve and optimize our Services and our players’ experiences;
  • to identify and suggest connections with other Replay players and personalize our Services to you;
  • to enable players to communicate with each other;
  • to provide technical support and respond to player enquiries;
  • to protect the safety and well-being of our players;
  • to protect Replay's rights and property in connection with our Services;
  • to prevent fraud or potentially illegal activities, and to enforce our Terms of Service;
  • to notify players of in-game updates, new products or promotional offers;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us;
  • 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
  • to conduct research.

One important use of your information is communication. If you have provided your e-mail address to Replay, we will use it to respond to Customer Support inquiries, and keep you informed of your in-game activity, including messages from friends or let you know about in-game status. Some messages, like private messages to friends, may include your name and profile photo.

We may also send promotional messages ("Promotional Communications") to you directly, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages from us or opting out. Receipt of such communications depends on Replay having certain contact information from you.

How We Share Your Information

We may disclose or publish aggregate information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 30 and 40 who live in London) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

Aggregated and Analytical Information

We use anonymous, statistical or aggregated nformation and may share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your identifiable information only subject to the terms of this policy, or subject to your prior consent.

Friends and Other Replay Players

The Service supports and often encourages you to interact with other players. If you register through a social network (for example, Facebook Connect), your social network friends who are registered on Replay Poker will automatically be added as Friends. Other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any Replay Poker games you have played), communicate with you within our Services, and view your game profile, which will include your username and your profile picture, if you have one. Any other player will see your game profile if you are playing at the same table or if they are watching a replay of a poker hand you participated in. Other players may also be able to send you friend requests through the related Replay’s communication channels.

Commercial Partners

To the extent that Replay Poker is currently hosted on a third party website, as set out in our Terms Of Service, some traffic data will be proxied through the host domain (solely as a conduit) but will only be processed by Replay. In a similar way, cookies that Replay wishes to use on its webpages (subject to your cookies preferences) will appear on your browser settings under the host domain but no cookie data in respect of your use of the Replay Services will be accessed by the operator of the host domain. For more information on how the operator of the host domain processes data, please refer to its own privacy policy, available: here.

We may also share data with other companies, where we have a legitimate interest in doing so to help improve the Services and this interest isn’t overridden by your rights and freedoms under data protection law. Such information could include, but is not limited to, analytics data, profile data and information provided in player forums and messages.

Whenever we share data with other companies, this will always be subject to a data sharing agreement, affording you the same assurances and protections as when Replay processes your data.

Third-Party Service Providers

We will share your information with third-party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third-party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.

Sale or Merger

In the event that Replay undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part of its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know (in the way described in Changes to Our Privacy Policy) of the business transition before transferring your personal information.

5. How to Access, Update and Manage Your Information and Means of Communication

Accessing and Updating Your Information Held by Replay

If you want to review, delete, or change the information Replay has about you or have additional questions, you may send an e-mail to legal@replaypoker.com. Place "Review My Account" in the subject line and include your username and e-mail address in the body of the e-mail. We will respond to your request within thirty days.

Stopping Use of Your Information

If you no longer want Replay to make active use of your information, you may send an email to legal@replaypoker.com. Place "Delete My Account" in the subject line and include your username and e-mail address in the body of the e-mail. We will respond to your request within thirty days. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.

Opting Out of Promotional Emails from Replay

If you want to stop receiving Promotional Communications from Replay, click on the "unsubscribe" link in any Promotional Communication from Replay or visit the notifications settings page. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. Your unsubscribe or e-mail preference change will be processed promptly, and in no event longer than ten business days.

Manage Information We get from a Third-Party Application

To manage the information Replay receives about you from a third-party application where you play our games, like Facebook, you will need to follow the instructions for the third-party application for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. To review and update information associated with your Replay game profile in certain games, visit the “settings” page in that game. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.”

Once Replay receives your information from a third-party application or your mobile device, that information is stored and used by Replay in accordance with this Privacy Policy. You may access and update that information as described below.

6. Children Policy

Policy Regarding Persons Under 18

Our games are intended for use by persons aged 18 or older for amusement purposes only. As per our Terms, you must be at least 18 years of age (or the minimum legal age to play Replay Poker where you reside, if higher) to play Replay Poker. Please refer to our Terms for more information on this.

Replay does not knowingly collect personal information from persons under the age of 18. Persons under the age of 18 should not use our websites or games at any time. If Replay Digital Ltd learns that a person under the age of 18 has provided it with personal information, Replay will take reasonable steps to delete such information as soon as possible.

7. How we protect the information we store and share about you.

Security of Your Information

Replay has made reasonable technical and organizational measures designed to secure your information both online and offline from accidental loss and from unauthorized access, use, alteration or disclosure, and we are committed to the protection of customer information. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

When you sign into your Replay account or enter payment information, we or our third-party payment processor use secure socket layer technology ("SSL") to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure, and Replay cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur and that third parties will never be able to overcome those measures or use your personal information for improper purposes.

Also please note that email and messaging systems are not considered secure, so Replay discourages you from sending Replay personal information through these media. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If you access our Services through a social network and your social network account is hacked, this may lead to unauthorized play of your Replay games without your permission. So, be careful to keep your Account Information secure.

Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access. If you have questions about the security of our websites, please submit a ticket via the applicable support channel of the game.

Safety, Security and Compliance with Law

Your information, and the contents of all of your online communications in our Services and between You and Replay may be accessed and monitored as needed to provide our Service and may be disclosed:

  • when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
  • to satisfy any laws or regulations that apply;
  • where we believe in our sole discretion that the Service is 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
  • to protect the rights or property of Replay and other applicable third parties, including to enforce our Terms of Service.

International Operations and Transfers Out of the UK or EEA

When you use Our Services, your data may be sent to the United States and possibly other countries.

As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures and other corporate entities from time to time for our legitimate business purposes.

We store information about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal data collected within the UK or European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the UK or EEA.

The data we hold may also be processed by employees operating outside of the UK or EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (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, and 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.

If you are a resident in a jurisdiction, where transfer of your personal information to another jurisdiction requires your consent, then by using our services you acknowledge and agree that Replay may transfer your data in order for us to provide you with our services.

How Long We Keep Your Information

How long we retain your information depends on why we collected it and how we use it. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.

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 on the Replay Poker website, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums. You should periodically check the Replay Poker website and this privacy page for updates.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at legal@replaypoker.com

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

If you wish to find out more information regarding the specific cookies we use in each of the above categories, please contact us at legal@replaypoker.com and we can answer any questions you may have.

Contact Us

VeraSafe has been appointed as Replay’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to legal@replaypoker.com only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative. Alternatively, VeraSafe can be contacted at: VeraSafe United Kingdom Ltd. Suite 1, 3rd Floor 11-12 James Square London SW1Y 4LB United Kingdom

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or another relevant supervisory authority in your home jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

For any questions, comments or concerns about our Privacy Policy or any other issue please contact Replay at: legal@replaypoker.com or submit a ticket via the applicable support channel of the game. All notices given by you or required from you under this Privacy Policy shall be in writing and addressed to: Replay Digital Ltd and by email to legal@replaypoker.com.