This Privacy Notice is effective from 19 February 2025. We may change this Privacy Notice at any time, and if we do so will post the changes to this page as well as the date that the changes take effect.
PKR.Strategy LLC (“we”) commit to protecting and respecting your privacy. This notice (together with our terms of use and any other documents referred therein) sets out the basis upon which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Ultimately, we aim to only process your personal data where it is necessary. We will always keep your personal data secure. Your enjoyment of our services and your safety are our primary concerns.
1. Introduction
1.1. This Privacy Notice sets out the way in which PKR.Strategy LLC ("we" or "us"), a company incorporated and registered in Marshall Islands, collects and processes Personal Information (as defined in paragraph 2.1 below). If you have any questions about this Privacy Notice or the processing of your Personal Information, please contact us at privacy@PokerStrategy.com
1.2. By using our Services, you acknowledge that we, as well as any partners and subcontractors will process your Personal Information in accordance with this Privacy Notice, including for the purposes set out in paragraph 5 below. If you do not wish to provide your Personal Information on the basis set out in this Privacy Notice, you should not enter the relevant information on the Website, or otherwise provide us with your Personal Information. However, if you do not provide your Personal Information, you may not be able to use all of the Services.
1.3. Capitalised terms not defined in this Privacy Notice are as defined in the Terms & Conditions. This Privacy Notice is incorporated into, and forms part of, the Terms & Conditions.
2. The information we collect
2.1. As part of operating the Website, we collect your Personal Information. "Personal Information" means any information from which you can be personally identified, including your name, email address, home address, telephone number, and date of birth.
2.2. We collect Personal Information which you provide to us, including when you register for an Account and information you provide in communications with us. We also collect information about the transactions you undertake, including details of payment cards used. We may also collect Personal Information through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of the Website and our Services. We will also collect other information necessary for us to process your Personal Information for the purposes set out in this Privacy Notice.
3. Information we collect through Cookies and similar technologies
3.1 We collect information through "Cookies" and other similar technologies (e.g. pixel tags or links). This helps us to remember you when you visit the Website, and to improve your experience.
3.2 We also use information collected through "Cookies" and other similar technologies to detect any fraudulent behaviour or abuse of our Website and Services, and to help verify your identity by registering and remembering your device information.
3.3 To find out more about "Cookies" and similar technologies please see paragraph 11 of this Privacy Notice. More information about the purposes of the "Cookies" we use can be found in paragraph 5.
5. How we use your Personal Information
5.1. In accordance with data protection laws, we will only process your Personal Information where we have a lawful basis for doing so. In respect of your Personal Information, these bases are: (i) where it is necessary to provide services to you under the performance of the contract we have with you; (ii) where we are required to do so in accordance with legal or regulatory obligations; (iii) where you have given your consent; and, (iv) where it is in our legitimate interests to process your Personal Information, provided that none of these prejudice your own rights, freedoms and interests.
5.2. The following are a list of the "Purposes" for which we (including any of our agents, Group members, sub-contractors and/or employees) process your Personal Information, and the lawful basis on which we carry out such processing:
| Purpose | Lawful Basis |
|---|---|
| To set-up, administer and manage your Account including personal details, such as name and email address, that you provide to us by filling in forms on the site. This includes information you may have provided at the time of registering to use the site, subscribing to our services, posting material, making purchases on the site or requesting further services. We may also ask you for information when you report a problem with the site. | Necessary for the performance of a contract |
| To provide and personalise our Services | Necessary for the performance of a contract |
| If you contact us or make any comments on the site or post forum entries, we do keep a record of that correspondence | Necessary for the performance of a contract where such communication relates specifically to our Services, otherwise consent |
| To notify you about updates to our Website and Services | Necessary for the performance of a contract |
| To ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you provide us | Necessary to comply with a legal or regulatory obligation |
| • Details of transactions you carry out through the sites and of the fulfilment of your orders. | Necessary for the performance of a contract |
| To provide and personalise our Services | Necessary to comply with a legal or regulatory obligation |
| Details of your visits to and actions on the sites including, but not limited to traffic data, location data, weblogs, conversion data, behavioral data and other communication data. | Necessary for the performance of a contract |
| Data in respect of your transactions with our partners. For example, in order to credit you with the correct amount of Strategy Points we will require certain player data from our partner Operators. | Necessary for the performance of a contract |
| Information about your device, including where available your IP address, operating system and browser type. | Legitimate interests so we can understand the use of, and therefore improve, our Website and Services |
| To provide you with information about, and support for, our Services, including changes to our Services, technical updates for the Website and changes to the Terms & Conditions (including this Privacy Notice) | Necessary for the performance of a contact and necessary to comply with a legal or regulatory obligation |
| To keep you informed of offers and promotions relating to our Services, provided that you don't "opt-out" from this option | Legitimate interests or consent, so we can send you information about our Services (and promotions and offers) that you may be interested in |
| To support any other purpose necessary for performance of our contractual obligations or specifically stated at the time at which you provided your Personal Information | Necessary for the performance of a contract |
| To prevent you from using our Website and Services if you have requested that we do so. | Necessary to comply with a legal or regulatory obligation |
| To use your username or location in publicity and marketing, but only where you have provided your express and informed consent for us to do so | Consent |
| Cookies: [Those that are necessary for the operation of the Website, including allowing you to interact with our Website and to recall selections as you move between pages] | Necessary for the performance of the contract |
| Cookies: [Those that analyse your use of our Website and monitor our web audience] | Legitimate interest so we can continue to analyse and improve our Website and Services |
| Cookies: [Those that are necessary for regulatory compliance, including identifying multiple accounts, false logins or potential fraud] | Necessary to comply with a legal or regulatory obligation |
6. Disclosure of your Personal Information
6.1. We may, for the Purposes, disclose your Personal Information to any of the following recipients:
6.1.1. any company within our Group (including to its employees and sub-contractors) which assists us in providing our Services or which otherwise has a need to know such information;
6.1.2. any third party which assists us in providing our Services, including (but not limited to) payment processors and customer services representatives;
6.1.3. any third party which assists us in monitoring use of our Services, including the detection and prevention of fraud and collusion,
6.1.4. any contractors or other advisers auditing any of our business processes or who have the need to access such information for the purpose of advising us;
6.1.5. any law enforcement body which may have any reasonable requirement to access your Personal Information;
6.1.6. any potential purchaser of our business or any investors in it or in any company within our Group (including in the event of insolvency).
6.2. If at any time you wish us to stop processing your Personal Information for the above Purposes, you should contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed.
7. Marketing Preferences
7.1. We will not send you unsolicited information regarding any third party's products or services.
7.2. As part of the Account registration process, you will have the opportunity to choose whether or not to receive information on our offers and promotions.
7.3. Unless you have informed us at the time of setting up your Account that you do not wish to receive promotional emails, we will send you such communications until you inform us that you no longer wish to receive them. You may update your marketing preferences at any time by:
7.3.1. if you are receiving emails, clicking on the "unsubscribe" link in an email and following the instructions;
7.3.3. contacting our Customer Services team.
8. Transfers of your Personal Information outside of the EEA
Your Personal Information will be transferred outside of the European Economic Area, both to us and other members of our Group. This includes, but is not limited to, Marshall Islands. Where we transfer your personal data outside of the EEA, we will put in place adequate measures to ensure that your Personal Information is kept secure (and such adequate measures shall include: (i) transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; and (ii) transfers pursuant to standard contractual clauses in accordance with European Commission decisions on transferring personal data).
For transferring data to service providers outside the EEA, we will ensure that such transfers are absolutely necessary in order for us as data controller to either adhere to a regulatory requirements or perform a contract/service agreement between ourselves and our players. We will also ensure that such transfers are necessary for us as data controller to perform a contract with another party that is in our players interest. We will ensure that the non-EEA countries used for a transfer and processing of personal data are either fulfilling EU adequacy requirements or where needed we will apply the appropriate contractual safeguards in the form of EU Standard Contractual Clause agreements with our suppliers in line with EU GDPR requirements.
9. Updating your Personal Information
You may update or delete your Personal Information at any time via the Website or by contacting our Customer Services team.
10. Your rights
10.1. You have the following rights in relation to your Personal Information:
10.1.1. a right to access your Personal Information as held by us (also known as a subject access request);
10.1.2. a right to receive certain Personal Information in machine-readable format;
10.1.3. a right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
10.1.4. a right to have inaccurate Personal Information rectified;
10.1.5. a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 10.1.8, where you have objected pursuant to paragraph 10.1.3, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation;
10.1.6. a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
10.1.7. a right to complain to the Marshall Islands Regulatory Authority;
10.1.8. where we have specifically requested your consent to process your Personal Information and have no other lawful conditions to rely on, you have the right to withdraw this consent; and
10.1.9. a right to object to direct marketing, which can be done by opting-out of direct marketing either through your Account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.
10.2. If you are unsure about your rights or are concerned about how your Personal Information may be processed, you should contact your national data protection regulator.
10.3. If you would like to exercise any of your rights, then you can do so by contacting us as described below. Please be aware that while we will try to accommodate any request you make in respect of your rights; they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
10.4. Where you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity. If we receive repeated requests or have reason to believe requests are being made unreasonably, we reserve the right not to respond.
11. Retention of your Personal Information
We will retain your Personal Information for the period necessary for us to provide you with our Services and to comply with our legal and regulatory responsibilities. Accordingly, your Personal Information will be retained for a minimum of [five] years following [the closure of your Account (if applicable) or the last contact with us emanating from you]. Where it is no longer necessary for us to process your Personal Information, we will delete it sooner. If you request that you should not be able to access our Website and Services (i.e. self-exclude), we will retain this information for a maximum of two years after account closure.
12. Contacting us
12.1. You can contact our Customer Services team using the details here.
12.2. If at any time you believe that we have not adhered to this Privacy Notice, please contact our privacy team at privacy@PokerStrategy.com
13. Advertising and use of Cookies
13.1. We may collect anonymous information about your use of the Website using "cookies", pixel tags and similar functionality. A "cookie" is a small file of text which is downloaded onto your computer when you access the Website, and it allows us to recognise when you come back to the Website. We use cookies for the operation of the Website, including (for example) to allow you to remain logged in as you move between different parts of the Website. We also use cookies for our own analytical purposes so that we can identify where customers have encountered technical problems on the Website, and therefore help us improve our customers' experiences. We also use services provided by third parties for fraud prevention purposes. For these purposes, Cookies are placed on your device to identify it in the future when you visit our Website or connect with our applications.
The cookies used on this Website are either set by us or by our third party service providers, and fall into the following categories:
1) Strictly Necessary - these cookies are essential in order to enable you to move around the Website and use its features. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Websites or benefit from all our security features.
2) Performance - these Cookies collect information about how visitors use our Website. They allow us to recognise and count the number of visitors and to see how visitors move around our Website.
3) Functionality - these Cookies are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our Website to meet your preferences for content layout, text size etc. You can manage these Cookies using your browser settings. However, if you block them we may not be able to offer you certain services that you have chosen
4) Targeting - these Cookies record the fact that you have visited our Website, including which web pages you have accessed, which device you have accessed them from, and which links you have followed. We use this information to make our Website relevant to your interests and for fraud and website abuse detection purposes, including detecting players who have abused bonus schemes or other promotions.
Some of these are "session cookies", which stay in place only for the duration of your visit to our website and are deleted at the end of your browsing session. Others are "persistent cookies", which remain on your device for a period of time after you have left the Website.
13.2. Most browsers have cookies enabled by default, but you are able to change your cookies settings, which are usually found in the 'options' or 'preferences' menu of your internet browser. You can block any cookies from any website by activating the setting on your browser that allows you to refuse the setting of some or all cookies. However, if you block all cookies you may not be able to access all or part of our Website. You can also use your browser settings to delete cookies. For more information about how to disable cookies in your browser please visit www.allaboutcookies.org.
13.3. As part of the Website's operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do NOT log any e-mail address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.
13.4. While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.
13.5. Cookies table:
| Cookie name | Purpose | Retention period | Lawful basis | Geographic location |
|---|---|---|---|---|
| cookie_login | allows user to auto-login on visit, if he wants to | 1yr | Functionality Cookie – Relies on User consent | |
| language_id | user will see the same website language as his last visit | 180 days, or last visit, whichever comes first | Strictly Necessary – This website cannot function without properly without this cookie | |
| SSOID | session token | session | Strictly Necessary – This website cannot function without properly without this cookie | |
| once_logged_in, trackbrowser | user lifecycle stage | 1yr | Functionality Cookie – Relies on User consent | Belgium |
| timezoneoffset | display of correct time and date formats | 1yr | Functionality Cookie – Relies on User consent | |
| transferaccount | ensure user does not see personal offers which he is not allowed to use | 1yr | Strictly Necessary – This website cannot function without properly without this cookie | |
| wbb2_lastForumVisit, wbb2_lastForumActivity, wbb2_boardpasswords, wbb2_hidecats | forum functionality and preference settings | session | Functionality Cookie – Relies on User consent | |
| cookie_consent | stores cookie consent | 1yr | Strictly Necessary – This website cannot function without properly without this cookie | Belgium |
| Source, referrer | referal marketing | session | Targeting Cookie – Relies on User consent | |
| WidgetSoruce | referal marketing | session | Targeting Cookie – Relies on User consent | |
| just_registered | User early life functionality | session | Functionality Cookie – Relies on User consent | |
| twitchLangsIdx | language preferences | session | Functionality Cookie – Relies on User consent |
Manage your cookie preferences
Click the link below to open your cookie preferences center and adapt your settings
14. Security
14.1. We are committed to ensuring that your Personal Information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the Personal Information that we collect.
14.2. All the Personal Information that you provide us is stored in a secure computing environment protected by secure firewalls to prevent unauthorized access. We control access so that only people who need to access the Personal Information can. All staff are provided security training and are required to adhere to a comprehensive set of security policies, procedures, and standards related to their jobs.
14.3. When you use secure areas of our Website, we use SSL encryption. This means that all the information sent between your computer and our secure computer environment is encrypted or scrambled so that no one can read it in transit. Secure areas of the site have a time-out feature. If you leave your secure session inactive for some time, it times-out to prevent unauthorized access.
14.4. Where your Personal Information needs to be disclosed to our service providers, we require them to process and protect your Personal Information in a manner consistent with this Privacy Notice and applicable laws.
15. Testing
Occasionally, we may share limited personal data to test a new third-party service or new software providers, to improve our capabilities to adhere regulatory requirements. Any personal data shared will be fully restricted for the purpose of testing of services, new software, new third-party providers capabilities. This is a mandatory aspect of continuous improvement of services we offer to players and clients.
Any data shared to conduct these tests will be deleted promptly at the end of the testing period.