1. Introduction

Replay Digital Ltd develops and operates the Replay Poker social poker game, available via the website ReplayPoker.com (the “Service”). Replay Digital Ltd is the data controller responsible for the processing of personal information on this site.

We are committed to safeguarding your privacy and providing a secure, enjoyable social gaming experience. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our games, services, and websites, including ReplayPoker.com and any other domains operated by Replay Digital Ltd (collectively referred to as the “Services”).

This policy outlines:

• The types of information we collect and how we collect it;
• How we use and share your information;
• How you can access and update your information;
• How we protect children’s privacy;
• How we secure the information we store and share.

By accessing or using the Services, you agree to the collection, use, and sharing of your information as described in this policy. If you do not agree, please discontinue use of the Services. We may update this Privacy Policy periodically, and we encourage you to review it regularly.

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

If you are located in certain jurisdictions, you may have legal rights to access the personal information we hold about you. These rights will be respected in accordance with applicable laws.

2. Information We Collect and How We Collect It

We only collect personal information when it is necessary for our legitimate business purposes, and we do so through fair and lawful means. While most of the information we collect is provided directly by you, in some cases we may receive data from third parties.

a. Information from Third-Party Applications (e.g., Facebook)

If you access our Services via third-party applications (such as social networks), we may receive information based on your privacy settings with that third party. This may include:

• Your profile picture or its URL;
• Your user ID (e.g., Facebook ID), which may link to publicly available data such as your name and profile image;
• The user IDs and public information of your friends;
• The email address used to register with the third-party service;
• Your gender and birthday;
• Whether you follow our official pages (e.g., on Facebook);
• Any other data you or the third-party application shares with us.

To understand what information is shared, please refer to the privacy settings and policy of the third-party application you use.

b. Cookies and Automated Data Collection

Like many websites, we use cookies and similar technologies (e.g., web beacons, tracking pixels, local storage) to enhance your experience and collect data about how you use our Services.

Cookies are small files stored on your device to track usage and preferences. These may be linked to your personal information for purposes such as improving our service, tailoring content, and optimizing performance. You may disable cookies via your browser settings, but doing so may limit some features of the Services.

Other technologies we and our partners use may collect:

• Device type and operating system;
• Unique device identifiers (e.g., MAC address, IDFA, IMEI);
• Browser type and language;
• Referring and exit pages;
• Clicks and time spent on various pages;
• IP addresses and URLs visited;
• Game state and session timestamps.

In some cases, this data may be linked to your social media ID or Replay Digital Ltd user ID.

Please see the “Opting Out of Cookie Tracking” section for details on how to limit data collection.

c. Information You Provide Directly

When you register or use our Services, you may provide personal information directly. This can include:

• Email address;
• Username;
• Password.

We also create a public player profile that may include:

• Profile photo;
• Full name;
• Gender;
• Date of birth;
• City and country;
• A personal bio.

Other players may view this profile, so please consider what information you choose to share.

Communications Features

Our Services offer features that allow you to interact with other players and share content. These include:

• Participating in player forums and message boards
• Posting public comments on hand replays or our blog
• Sending private messages or invitations via the site or email
• Engaging in chat with other players

By using these features, you acknowledge and agree that Replay Digital Ltd may, in real time or retrospectively, access, record, and store these communications on our servers. We do this to:

• Safeguard the well-being of our users
• Protect our legal rights and property
• Operate, personalize, and improve the Services
• Conduct research and analysis
• Support contextual advertising

Payment Information

When you make a purchase (such as buying virtual currency), your payment is processed through trusted third-party providers like PayPal or Stripe. These payment processors collect the financial data required to complete the transaction, including your:

• Postal address
• Email address
• Payment details

Replay Digital Ltd does not store or access your full financial information, such as credit card numbers. However, we may receive limited non-financial details from these providers—such as your name, billing address, and items purchased—to help fulfill your order and maintain your account.

For more information on our billing policies, please refer to our [Terms of Service].

Message Boards and Chat Rooms

You may choose to share information publicly through features like:

• Chat rooms
• User profiles
• Blog comments
• Message boards
• Hand replays

Please be aware that anything you post in these public spaces is visible to other users and may be read, collected, or used by them—including for sending unsolicited messages. Replay Digital Ltd is not responsible for any personal information you choose to share publicly.

We may monitor, record, and store these communications to:

• Maintain the safety of our community
• Enforce our policies
• Protect our rights and the integrity of our platform

If you upload images, videos, or other media for public display, others may view, copy, or reuse that content without your permission. For more guidance on sharing content, see our [Terms of Service].

Customer Support Communications

If you contact our Customer Support team, we may collect:

• Your name and email address
• Details about your gameplay and activity
• Your player ID and support history

We store this information to resolve your issue, improve our Services, and provide better support in the future.

Other Information Sources

We may also receive data from third-party sources (like data providers or partners). This information is combined with the details you provide to improve features such as friend suggestions, account linking, or gameplay personalization.

For information on how we keep your data secure, see the Security of Your Information section below.

3. How We Use and Share the Information We Collect

How We Use Your Information

We collect and use your data primarily to provide a better and more personalized experience. Specific purposes include:

• Creating and managing your game account
• Enabling gameplay and social features
• Personalizing and improving your experience
• Helping you connect with other players
• Responding to technical and customer support inquiries
• Enhancing safety and ensuring community integrity
• Preventing fraud and enforcing our Terms of Service
• Sending in-game updates and promotional offers
• Running surveys, contests, or events
• Complying with legal obligations and resolving disputes
• Conducting analytics and research

We may also communicate with you using the email address you’ve provided. These communications may include:

• Customer Support responses
• In-game notifications (e.g., messages from friends, updates, promotions)
• Promotional emails (“Promotional Communications”), based on your preferences

You can opt out of Promotional Communications at any time using the options provided in those messages.

How We Share Your Information

Aggregated and Anonymized Information

We may share anonymous or aggregated data (such as general statistics or demographics) with partners for purposes like marketing, analytics, and business development. This information does not identify you personally.

Sharing with Other Players

Replay Digital Ltd games are social by design. Other players may see:

• Your username and profile photo
• Game activity, including games you’ve played
• Your profile if you’re at the same virtual table or watching a hand replay

If you sign in via a social network (e.g., Facebook), your friends who also play Replay Poker may be automatically added to your in-game friends list. Other users may be able to send you friend requests through our platform.

Third-Party Service Providers

We share information with third-party companies that help us operate the Services. These providers assist with:

• Payment processing
• Data analysis
• Hosting and infrastructure
• Customer support
• Email delivery
• Advertising and marketing optimization

All third-party partners are contractually obligated to keep your data secure and use it only as directed by Replay Digital Ltd.

Business Transitions (e.g., Sale or Merger)

If Replay Digital Ltd is involved in a business transition—such as a merger, acquisition, or sale of assets—we may transfer your information, including personal data, to the acquiring organization. We will take reasonable steps to notify you about such changes, in accordance with the “Changes to Our Privacy Policy” section.