Privacy Policy

This Privacy Policy was updated on July 22, 2020.

1. Introduction 

Replay Digital Ltd develops and publishes the Replay Poker social poker game for the web (the "Service"). Replay Digital Ltd is the data controller of the website ReplayPoker.com.
Replay Digital Ltd is committed to protecting the privacy of its users and provide them a better social Digital experience ("users" or "you"). This Privacy Policy has been created to inform you about how Replay Digital Ltd manages, collects, stores, shares, uses and protects the information you provide in connection with any Replay Digital Ltd game or application whenever you play our games or otherwise access any of our Services, products, content, ReplayPoker.com and/or the other domains provided by Replay Digital Ltd. 

This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content, ReplayPoker.com and/or the other domains provided by Replay Digital Ltd, together referred to as “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 do we protect children privacy
  • how we protect the information we store and share about you
By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want Replay Digital Ltd to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play Replay Digital Ltd’s games or use our Services. Replay Digital Ltd may amend the Privacy Policy from time to time, and Replay Digital Ltd encourages you to consult the Privacy Policy regularly for changes.

We do not share personal information with third parties for direct marketing purposes.

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.

2. Information We Collect and How We Collect It

Replay Digital Ltd 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), it may be necessary for us to 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 Digital Ltd’s games or connect our Services to any third-party applications, including social networks like Facebook, Replay Digital Ltd 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 Digital Ltd 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 Digital Ltd.
If you access 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 Automated Information Collection

Like many websites, Replay Digital Ltd and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as "cookies" 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 Digital Ltd’’s Service, tailoring recommendations to interests, and making the Service easier to use.

Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting a cookie from the websites you visit or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. If you do not accept cookies, however, you may not be able to use all features, portions or functionalities of the Service.

We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently and effectively by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.

We and our service providers use these 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 Digital Ltd user ID.

For more information on how to limit the types of cookies you allow, please see Opting out of Cookie Tracking section..

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 create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other Replay Digital Ltd 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;

Communications Features

You can take part in certain activities on our Service that let you communicate or share information not just with Replay Digital Ltd, but also with other Replay Digital Ltd 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 Digital Ltd's servers to make use of them to protect the safety and well-being of our players and Replay Digital Ltd’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 Digital Ltd may obtain the billing and payment information that you provide when your purchase is processed by our payment partners (like PayPal and Stripe). Our Terms of Service explain our policies and terms relevant to our charges, billing practices and virtual currencies.

If you purchase virtual currency in a Replay Digital Ltd 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 Digital Ltd does not collect or store your financial information, like credit card numbers. However, Replay Digital Ltd’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 fulfill 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 Digital Ltd, 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 Digital Ltd sites or 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 Digital Ltd 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 on Replay Digital Ltd's servers to protect the safety and wellbeing of our users and Replay Digital Ltd's rights and property in connection with the Service. You acknowledge and consent to the recording and storage of such communications for these purposes.

If you post a video, image or photo through 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 Digital Ltd is not responsible for the videos, images or photos that you choose to post through a Service. Please see Replay Digital Ltd’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 Digital Ltd 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.

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

3. 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. 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 Digital Ltd players and personalize our Services to you;
  • to enable players to communicate with each other;
  • to provide technical support and respond to player inquiries;
  • to protect the safety and well-being of our players;
  • to protect Replay Digital Ltd'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 Digital Ltd, we will use it to respond to Customer Support inquiries, and keep you informed of your in-game activity, including messages from friends, let you know about in-game status and promotions. Some messages, like private messages to friends, may include your name and profile photo. We may also send promotional e-mail messages ("Promotional Communications") directly, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages. Receipt of such communications depends on Replay Digital Ltd having certain contact information from you.

How We Share Your Information

We may disclose or publish aggregated 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 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 information 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 Digital Ltd Players and/or

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 Digital Ltd’s communication channels.

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 Digital Ltd undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part 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.

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

Accessing and Updating Your Information Held by Replay Digital Ltd

If you want to review, delete, or change the information Replay Digital Ltd has about you or have additional questions, you may send an e-mail to [email protected].  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 Digital Ltd to make active use of your information, you may send an email to [email protected].  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.

Manage Information We get from a Third-Party Application

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

Opting Out of Promotional Emails from Replay Digital Ltd

If you want to stop receiving promotional e-mails from Replay Digital Ltd, click on the "unsubscribe" link in any promotional email from Replay Digital Ltd or visit the e-mail preference . 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.

Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

If you disable cookies, you may lose some of the features and functionality of our Services because Replay Digital Ltd cookies are necessary to track and enhance your game activities.

5. Children Policy

Policy Regarding Persons Under 18

Unless written otherwise, our games are intended for use by those 18 or older for amusement purposes only. We allow players ages 13-17 to create an account with the consent of a legal guardian who must read and agree to our Terms & Conditions. Without derogating from the foregoing, Replay Digital Ltd does not knowingly collect personal information from children under the age of 13. Children under the age of 13 should not use our websites or games at any time. If Replay Digital Ltd learns that a person under the age of 13 has provided it with personal information, Replay Digital Ltd will take reasonable steps to delete such information as soon as possible.

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

Security of Your Information

Replay Digital Ltd 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 Digital Ltd 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 Digital Ltd 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 Digital Ltd discourages you from sending Replay Digital Ltd 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 Digital Ltd 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 Digital Ltd 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 Digital Ltd and other applicable third parties, including to enforce our Terms of Service.

International Operations and Transfers Out of the 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 European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the EEA.

The data we hold may also be processed by employees operating outside of the 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 you provide us your express and unambiguous consent to such transfer 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 ReplayPoker.com, 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 ReplayPoker.com 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 [email protected]


Contact Us

VeraSafe has been appointed as Replay Digital Ltd’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 [email protected] 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 Digital Ltd at: [email protected] 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 [email protected].