PRIVACY NOTICE of Seven Little Sparrows S.A.S for Vortex Poker App

We at Seven Little Sparrows S.A.S (”Seven Little Sparrows S.A.S”, ”we”, ”us” or ”our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (”Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, ”Personal Data”) when you play our games that are part of our gaming platform. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you play Vortex Poker (” Services ”).

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the processes that specifically apply to a certain Service.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data. For specific information with more details about our processing activities, please see the specific information below.

Who is responsible for the processing of your Personal Data?

Seven Little Sparrows S.A.S is responsible (the data controller) for the processing of your Personal Data in Vortex Poker.

What types of Personal Data do we process and how do we collect it?

When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any ”special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our Services you use and how you use them. We may process the following types of your Personal Data:

Personal Data provided by you

When you use our Services, you may provide or be asked to give us certain information, including:

• Your account information: In order to use our Services, you need to create an account. This will also allow you to use our Services on different devices. When you create your account, we collect your log-in data (your nickname/avatar name and/or your email address and password) and may collect additional profile information provided by you to personalize your profile (such as your first name and your avatar). This information will be combined with your account ID.
• Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details.

Personal Data we receive or generate from your use of our Services

When you use our Services, we may also process device-related information and information about how you interact with our Services, including:

• Technical information: We collect information about your device/device settings and combine information from different devices you use for the purposes described below. The information we obtain from your device(s) includes the type of your device, online identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address), browser settings, screen resolution, battery status, free storage, and other technical information.
• Cookie data: As further described in our Cookie Policy (”Cookie Policy”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Policy.
• Your usage: We collect information about how you use our Services. This information includes the actions you take within the game (e.g. if you win or lose a game, your achievements (such as the level reached), the items purchased within our Service, the amount you spent in the game, a list of friends that also play the game, winning streaks in the game), the time and duration of your activity. Furthermore, we collect information about the websites that led you to our Service. Part of this information will be stored in your account (such as your friends list and your progress).

Personal Data we collect from third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:

• Payment Providers: If you make an in-app or website payment, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any specific financial information (such as the payment method or your credit card information) but may receive information which is related to your transaction, for example the payment status and payment date.
• Social Networks and connected third-party platforms: If you choose to connect our Service with your e.g. Facebook, Google, Microsoft Windows account by using your e.g. Facebook, Google, Microsoft Windows credentials within our log-in process, we may receive certain information about you from e.g. Facebook, Google, Microsoft or like e.g. your name, you profile picture, your email address, and your friends list. If you enter our Services from a third-party platform ( Facebook or Google), and you have created an account on the third-party platform, your username and your avatar may be shared with us to create your Service account. Furthermore, the third-party platform provider may share with us e.g. the platform ID, the avatar url, your email address, and your friends list.
• User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about installs of our Services, your country and language, and technical identifiers (Advertisement Device ID) from our user acquisition partners.
• Other third parties: We may also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Appsflyer). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

To learn more about which data is processed when you use a certain Service, please see the section with service specific information below.

For what purpose do we process your Personal Data?

Depending on which Service you are using and which privacy settings you have selected, we may process your Personal Data for the following purposes:

Provision and improvement of our Services

• to allow you to use our Services
• to facilitate in-game communication via chat
• to create and manage your account
• to restore your account if you ever lose access
• to communicate with you in context of account activation and password management, to simplify the registration process
• to facilitate your purchase, to verify and confirm your payment
• to facilitate content sharing on social networks
• to provide technical support and respond to your requests
• to identify and correct any bugs/errors
• to indicate the popularity of our Services
• to assess the quality of our Services
• to understand and improve your online experience
• to pay our business partners for the promotion of our Services

Personalization of your game experience

• to remember your preferred game settings
• to remember you next time you visit one of our Services

Marketing and analytics

• to show you advertisements for our Services on other websites or apps
• to measure the effectiveness of advertising
• to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers
• to acquire new users on social media platforms

Prevention of fraud and illegal activity

• to investigate fraud and illegal behavior in our Services
• to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

• to determine the legal requirements for processing of your Personal Data
• to obtain a valid consent, if necessary
• to respond to your requests related to your data subject rights
• to comply with our legal obligations (e.g. tax and accounting obligations)
• to inform you about any changes to this Privacy Policy

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data per Service.

Do we engage in profiling activities?

We may use tracking mechanisms to track your Personal Data for profiling purposes. This helps us to find new users for our Services, based on the information we have about you, and to target users who were already interested in our Services on the websites or in apps of our business partners. You have the right to object to this type of processing. You can also go to your in-game settings to review and amend your privacy choices related to this type of processing at any time.

On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

• Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in the context of profiling. We may also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-game settings. Please note that this will not affect any processing carried out before you withdraw your consent.
• Performance of a contract: We process your Personal Data for the performance of a contract to which you are party, for example, where it is necessary for the creation and administration of your account, to process your in-game purchase and the associated payment, to support the operation of our games or facilitate the delivery of requested services.
• Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations.
• Legitimate interests: We may also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for analytics, improvement of the Service provided to you, or to provide you with a better user experience.

Please see for additional information the section with service specific information below.

With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorized to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfill the purposes mentioned above, we may disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

• External service providers: We may share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, data management services, user notification and marketing services, and forum hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
• Payment providers: If you make in-app purchases, the transaction will be processed by a third-party payment provider and will be subject to the third-party payment providers’ privacy policies.
• Social networks and connected third-party platforms: If you wish to share certain content on social media, you will be asked to log-in with your social media platform credentials. In this case, the content you want to share (e.g. a screenshot from the game) will be sent to the respective social network or third-party platform. If you signed up with your third-party platform account, we will send your account identifier and request data (e.g. user name, e-mail, profile picture) from the third-party platform provider.
  Furthermore, your Facebook ID and/or the advertisement ID may be shared with Facebook Inc. (Facebook) or Snap Inc. (Snapchat) in connection with Facebook’s and Snapchat’s ”Lookalike Audience” and ”Custom Audience” remarketing features which we may use for our Services. Learn more about our marketing activities in the service specific section below.
• User acquisition companies: We provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third-party website or in a third-party network, you will be redirected to the app store where you can install our Service. The information about the installs of our Service, your country and language, the campaign ID, your user ID, and post install events (such as session time, reached level), including any purchase events and the purchase segment , may be shared with the user acquisition company.
• Law enforcement, government authorities or courts: We may disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
• Other third parties: We may also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Where will my Personal Data be processed?

In general, your Personal Data is stored on servers within the European Union (EU)/the European Economic Area (EEA). However, your Personal Data may also be shared outside the EU/EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data. Where the recipient is a U.S. based company certified under the EU-U.S. Privacy Shield, the data transfer may also be based on the EU-U.S. Privacy Shield.

How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations. Afterwards, we will delete or anonymize your Personal Data. Please see below for service specific information about how long we will retain your Personal Data.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period.
• Request the update or correction of your Personal Data so that it is always accurate.
• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transmit your Personal Data to another controller.
• Request the deletion of your Personal Data if you think that it is no longer needed for the purposes indicated above. If you have created a Service account, you can delete your account at any time by submitting a deletion request. To submit this request, contact our support team or our Data Protection Officer at support@vortexpoker.app
• Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy.
• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the processing based on consent before its withdrawal.

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such a case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to support@vortexpoker.app providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example the Autoriteit Persoonsgegevens in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our Data Protection Officer:

• For Vortex Poker: support@vortexpoker.app
• Or by mail :

• Seven Little Sparrows S.A.S
• 17 Rue François Chambrelent
• 33300 Bordeaux
• FRANCE

How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Service Website.

This Privacy Notice was last updated on:

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed for each Service. For general information about data processes that apply to all Services, please see above.

Vortex Poker

Hosting and content delivery

Vortex Poker is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Creation/administration of your account

In order to play Vortex Poker, you have to create an account . We store your log-in data (your nickname, email address and password) to allow you to log in on different devices, based on the performance of a contract. If you choose to register using your e.g. Facebook, Google, Windows or enter our game from a third-party platform (e.g. Facebook, Steam or Google), we receive certain information about you from the respective third-party provider like e.g. your name, you profile picture, your email address, and a list of your friends that also play the game. This information will be stored in your Vortex Poker account. If the third-party platform has an achievements system to measure and show you your achievements in the games you play, and only if you have provided your consent to the third-party platform provider, we will send event data (for example, that you reached a certain level in Vortex Poker) to the third-party platform provider so that this information will also be stored in your profile on the third-party platform.

If you choose to register using your Facebook account, we may receive certain information about you from the respective third-party provider like e.g. your name, your profile picture, your email address, and your friends list. This information will be stored in your Vortex Poker account.

Your account data will be stored for as long as your account exists. You can delete your Vortex Poker account at any time, for example by submitting a deletion request to our support team using the contact feature within the game or by contacting our Data Protection Officer at support@vortexpoker.app

Customer service

If you contact us for customer support at support@vortexpoker.app, an external customer service provider will process the content of your request. In a first step, we will provide you with general information from our ”Frequently Asked Questions” feature (FAQ), based on the keywords from your request. For example, if you have asked for information related to your account (e.g. on how to make changes in your account settings), we will suggest articles from our FAQ which contain account-related information (e.g. on why your account was blocked or on how to disconnect your Vortex Poker account from Facebook). If the suggested articles from our FAQ do not contain the information you were looking for, we may ask you to provide your name and your email address in order to help you with your request.

This information will be processed together with your user ID (including segment), the last steps taken within the game, and device data (such as device model, battery status, free storage, device language, operating system version, carrier and platform). The request history will be stored in order to solve newer requests based on the information related to your previous request(s) (generally for account lifetime). We process this data on the basis of the performance of a contract in order to provide you with our customer service.

Analytics

We use analytics services to understand which features you like in Vortex Poker and how you use them. For this purpose, we process purchase events (the amount spent within the game), the purchase segment, the level you reached within the game, your session time, which saloons you played in, how many hands you played, whether you won or lost the game, the features you used, and how many friends you have in the game. We combine this information with campaign data (including the advertisement device ID, installs data, your country and language, the campaign ID, and your user ID) to get an insight into campaign results and to create user segments for new user acquisition and remarketing purposes.

The use of analytics services also helps us to improve the game for you, to find crashes and issues in the game, and to improve the performance of our websites/apps. For this purpose, we process crash information, ANR information (the situation if the game freezes), and device information (battery, Wifi situation, CPU, memory).

We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access Vortex Poker for the first time.

Data management service

Based on your consent you provided for ”Profiling”, we create user segments and use these user segments for new user acquisition and remarketing purposes. The user segments are created based on your in-game behavior (such as your in-game purchases, your sharing activity, and the level you have reached within the game) and by determining the spending behavior for each segment. For this purpose, your Personal Data, including your in-game behavior, your country, game language, purchase segmentation, the highest price point ever spent in Vortex Poker, and the advertisement ID are collected and sent to a data management service provider.

New user acquisition, remarketing and campaign tracking

The following processes help us to find new users, remarket existing users and measure the effectiveness of our advertisements:

• New user acquisition: In order to acquire new users, we create advertisements (banners/videos) for Vortex Poker and provide our advertisements to third-party user acquisition companies which show our ads in their apps or on their websites. If you click on the banner/video shown to you in a third-party app or on a third-party website, you will be redirected to the app stores (Google, Steam or Apple) where you can install Vortex Poker. The information that you have clicked/viewed the advertisement (campaign information) will be sent from the user acquisition companies to an attribution platform provider (Appsflyer) and will then be passed by Appsflyer to the app store. If you install Vortex Poker, the campaign information will also be passed from the app store to us and will be processed to measure the effectiveness of our advertisements . When you start playing Vortex Poker, we collect and share post install events (for example, the level you reached within the game and purchase segments) either through the Appsflyer SDK or directly with the user acquisition companies which helps them optimizing their services.
  The described data processing activities help us to track and optimize our campaigns and to reward our user acquisition partners and are based on our legitimate interests.
  Furthermore, we use Facebook’s ”Lookalike Audience” feature to find new users based on the user segments we have created for our user base. In order to allow Facebook to search for a ”lookalike audience”, we select the segments that have a good spending behavior and give a list of these users' Facebook IDs and Advertisement IDs (IDFA from the device, which users can reset) to Facebook. Facebook processes this information to check the Facebook profiles of the respective users for common characteristics of these users (for example, hobbies or the user’s location, using data available only to Facebook and which is not shared with us) and to find similar new users ('lookalikes') which are likely to be interested in our game. These similar users will be shown advertisements (banners/videos) for Vortex Poker to encourage them to click the advertisements and install Vortex Poker through the app-store.
• Remarketing: We also provide our advertisements to third-party user acquisition companies to show advertisements for Vortex Poker to existing users and to encourage them to come back to the game. For this purpose, if you are a registered user, we will share your user ID, your country and language with third-party user acquisition companies. Furthermore, we will share in-game data (for example, the level you reached within the game and purchase events and segments) either through the Appsflyer SDK or directly with the user acquisition companies to help them optimize their campaigns.
  These processes are based on our and the user acquisition companies’ legitimate interests.
• Campaign validation and fraud prevention: In order to prevent fraud and analyze our campaigns we send campaign data we receive from our user acquisition partners in connection with the acquisition of new users (views, clicks and installs, campaign ID) together with analytics reports relating to the game usage to our internal user acquisition service.
  This processing is based on our legitimate interest to optimize our marketing performance.

Push notifications

Based on our legitimate interests, we may show you push notifications on your device to inform you of new content and offers in Vortex Poker. For this purpose, a user notification service will process information about the status of the push notification (notification received/viewed) and device information. You can turn off the push notifications in your account settings at any time.

Newsletters

When you sign up for an account in Vortex Poker, you will be asked to provide your consent for the delivery of newsletters. In this context, we may process the following Personal Data such as your email address, your last log-in, your name, language, country, your user ID. You can cancel your subscription to our newsletter at any time over the corresponding link which appears at the end of every newsletter (or opt out through the in-game settings).

Payments

If you make in-game purchases, you will be redirected to an external payment provider for the transaction of your payment. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers the following information related to your transaction: the quantity of the product you purchased, the product name, your user ID, the payment ID, the price, the currency symbol, your country, the receipt, product ID (sku if applicable), and the operating system.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.

Logging of all in-game actions

In order to help you with any issues you might have with our game, we store all the steps you take within Vortex Poker in our logs which will be deleted after two months.

This process is based on our legitimate interest to be able to analyze and solve any potential issue with our game.

List of third parties we may share your data with or may share your data with us

Analytics

Amplitude Analytics,
Personal Data: Tracker; Usage Data

Device permissions for Personal Data access
Personal Data: Contacts permission

Hosting and backend infrastructure

Amazon Web Services (AWS)
Personal Data: various types of Data as specified in the privacy policy of the service

Infrastructure monitoring

Bugsnag
Personal Data: device information; device logs; username

Marketing

SMS Marketing

Social features

Inviting and suggesting friends
Personal Data: various types of Data

Push notifications

Vortex Poker may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Vortex Poker, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of Vortex Poker.