Privacy Policy
1. Data Controller Information
The provision of our applications (referred to as the "App"), whether accessed via websites or through various app stores, is managed by Summit Wind Culture & Tech Co., Ltd., which serves as the Data Controller for your personal information. Accordingly, any references to "We," "Us," or "Our" in this policy pertain to the Data Controller.
We have a designated data protection officer (DPO) to help us comply with the requirements of the General Data Protection Regulation (EU) 2016/679. You may contact the DPO directly by emailing business@pokerbang.net
2. Personal Data Processed and Legal Basis for Processing
We collect different types of information, either directly from you or automatically from your device, when you use the App. We only collect data that is strictly necessary to provide our services—nothing more, nothing less.
The information collected, whether related to you or your device, may be automatically identified by our systems, provided to us by the operating system of your device, or manually input by you when completing certain fields, such as authorizing specific actions within the App.
Information You Provide Us With
Legal Basis for Processing
1. Social Network Information via the OAuth method for secure login (more details about OAuth here https://oauth.net). This includes data from your public profile (e.g., Facebook), which you can control at any time.
Performance of the contract with you. We cannot provide our services to you as a registered user without this data.
2. Your name and avatar (an image of your choice shown when playing the App).
Your consent provided at the time of data submission. You may change or replace your name and avatar in the App settings at any time.
3. Messages and communication with support.
Performance of the contract, allowing us to respond to your queries and provide customer support. This data is not used for any other purpose, such as building profiles or targeting users based on communications
Strange, but that's it. The remaining data is technical information that must be processed to deliver our services effectively.
Information Collected Automatically or Assigned by Us
Legal Basis for Processing
1. The server hosting the App may record requests made by your device to the server, including details such as the device and browser used, your IP address, date and time of access, city and country, operating system, browser type, and mobile network information.
Performance of the contract. The App requires this data to operate and connect to the internet. This information is used solely for technical purposes to ensure the proper functioning and security of the App, and to investigate any potential security incidents.
2. Device identifiers, provided by the operating system (e.g., device ID or vendor ID) or assigned by Us (e.g., your in-App ID).
Legitimate interest in fraud prevention and protection against unauthorized access across multiple devices/locations, ensuring the App's technical availability and security.
3. App version, OS version information, browser type, language settings, device make/model.
Performance of the contract. This technical data is essential to ensure the App operates correctly on your device.
4. Usage events naturally occurring during your use of the App (such as logs, events, hands played, purchase history, app crashes, system reports, etc.). Statistical information about App usage.
Partly performance of the contract and partly legitimate interests in fraud prevention and preventing unauthorized access, ensuring the technical availability and security of the App. Analyzing this statistical data helps optimize the App for future updates, without affecting your rights and freedoms or revealing any personal information about you or your contacts.
We may collect technical information related to your device, such as device ID, advertising identifiers (such as IDFA or GAID), IP address, browser type, and operating system version. This data is primarily used to improve the performance of our services and the user experience.
3. How We Use Your Personal Data
We take the protection of your personal data seriously and ensure that it is handled in a way that aligns with your expectations. We will not use your data in any manner that would be surprising or unexpected, unless we have explicitly informed you and you have provided your informed consent for such usage.
For instance, your account is encrypted during the sign-up process, and your personal data is securely stored on servers designed to prevent unauthorized access or destruction.
The purposes for processing your personal data include:
Providing you with our services
Preventing fraud
Enhancing and improving our services
Informing you of any changes or updates to our services
4. Retention of Personal Data
The duration for which we store your personal data depends on its type. Typically, your data is stored until you delete the App or after six months of inactivity. Certain information, such as IP addresses or blacklisted email addresses used for fraud prevention, may be retained longer, in accordance with our legitimate interest in protecting the business from potential losses.
By law, we are required to delete any information that is no longer necessary to provide our services to you. If you have not used the App for more than six months (referred to as the "Period of Inactivity"), we will assume you have discontinued use of our services. Following this period, we will delete any personal data we hold on your behalf.
However, should you wish to return to our App, you are always welcome to create a new account and start fresh.
5. Security Measures Implemented by Us
Your personal data is stored on secure servers that we rent, and we follow industry best practices to ensure its security. We implement appropriate technical and organizational measures to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access during transmission, storage, or processing.
We have contracted Google (the "Hosting Providers") to securely store your personal data. These Hosting Providers hold various internationally recognized security certifications that guarantee the safety of your data. For more details about the security measures of our Hosting Providers, you can follow the links provided on their respective sites:
https://cloud.google.com/security/compliance/compliance-reports-manager#/ReportType=Certificate ISO 27001 certificate
While we trust our Hosting Providers to maintain the necessary security protocols, we also ensure that access to your data is limited to those who need it for their job. This controlled access is governed by a range of technical and organizational measures, including:
Two-factor authentication for accessing the Hosting Providers;
Adhering to the principle of least privilege (limiting access only to what is necessary);
Continuous monitoring of servers and services, including logging personal access via the user interface;
Each employee accesses the system using their individual credentials, with access rights restricted to their specific responsibilities and team functions.
You have the right to choose not to share or sell your personal data. If you wish to opt-out, please contact our Privacy Support Team at: business@pokerbang.net.
6. Categories of Recipients
We do not share your personal data with third parties, except in the following cases:
Data processors (service providers) that operate solely under our instructions in performing our services to you;
As detailed in this Privacy Policy;
Where we are required to comply with a legal obligation.
This does not mean we automatically comply with every disclosure request. We carefully review each request to ensure it meets relevant safeguards, contains a valid court order, or is issued under legal provisions aimed at preventing, investigating, detecting, or prosecuting criminal offenses.
Independent Controllers
For iOS and Android Users:
6.1 Adjust GmbH ("Adjust") – Adjust is a data analytics platform that provides solutions for campaign tracking, optimization, and user data security, helping mobile marketers drive app growth. The Adjust SDK collects and processes information according to Adjust’s privacy policy, available at https://www.adjust.com/terms/privacy-policy
The Adjust SDK collects data to help us understand and improve the effectiveness of our marketing campaigns. This includes data used for presenting our website and its contents to you, providing information or services you request, marketing and advertising purposes. Additionally, it may be used for other purposes that we specifically explain to you prior to collecting your information.
The information collected by the Adjust SDK helps us monitor and optimize our promotional activities, ensuring secure data management and enhancing the user experience within our App.
6.2 Google LLC ("Google")
Google provides multiple services that help us ensure the stability, security, and proper functioning of the App. These services are operated and maintained by Google LLC and process data in accordance with Google’s Privacy Policy, available at https://policies.google.com/privacy
6.2.1 Firebase
Firebase is a mobile development platform operated by Google that offers tools such as Authentication, Cloud Messaging, and Crashlytics. Firebase may collect data such as login information, crash reports, and notification delivery status to support these features. The information helps us ensure secure login, deliver timely notifications, monitor app crashes, and improve overall app performance. This data may also be used for other purposes that we specifically explain to you prior to collection. For more details, please refer to Firebase Privacy Notice, available at https://firebase.google.com/support/privacy
6.2.2 Play Integrity API
Play Integrity API is a service provided by Google to protect the app and its users from fraud, abuse, and unauthorized activity.The data, such as app installation source, tampering status, and device certification, is used to verify that the app is operating in a secure and trustworthy environment, which helps prevent cheating, fraud, and misuse. The collected data is processed in accordance with Google’s Privacy Policy, available at https://policies.google.com/privacy
6.2.3 Google AdMob SDK
Google AdMob SDK is a service provided by Google LLC for serving advertisements within the App, including rewarded ads which allow users to view video ads or interact with promotional content in exchange for in‑app rewards.
The SDK collects data such as device and account identifiers (e.g. Advertising ID, App Set ID), IP address (which may be used to estimate general location), user interactions with ads (e.g. video views, taps), and diagnostic and performance information (e.g. app launch time, crash logs) for the purposes of ad delivery, analytics, fraud prevention, and improving ad relevance. The collected data is processed in accordance with Google’s Privacy Policy, available at https://policies.google.com/privacy
7. Your Rights
You are entitled to all the rights granted under the General Data Protection Regulation (GDPR), and we will make every effort to accommodate any valid request. You can exercise certain rights directly on your device by deleting specific features, or you may email us at business@pokerbang.net to exercise your full range of rights.
We fully respect your rights, which include the following:
Right of access: Request access to your personal data.
Right to rectification: Request corrections to any inaccurate or incomplete personal data.
Right to erasure: Request the deletion of your personal data.
Right to withdraw consent: Revoke your consent to the processing of your personal data, where applicable.
Right to non-discrimination: Ensure that you are not discriminated against for exercising any of your rights.
Right to lodge a complaint: File a complaint with your national supervisory authority (in the EEA) if you believe your privacy rights have been violated.
To ensure the security of your personal data, we may require verification that the request is coming from the actual data subject. This process may involve contacting us from within the app and confirming a code sent to your registered email address. This ensures that no unauthorized parties gain access to your data.
If your personal data is erased upon your request or due to our data retention policy, we will only retain the information necessary to protect our legitimate interests or comply with legal obligations.
Please note that all requests can be sent via email to business@pokerbang.net, by post, or through the app’s related website, where applicable.
8. Children’s Privacy
The App is strictly intended for individuals aged 18 and older. We do not knowingly collect or solicit any personal information from anyone aged 13 or younger. The App and its content are not designed to target or appeal to individuals under this age group.
If you are a parent or guardian and believe that we may have inadvertently collected personal data from a child aged 13 or under, please contact us at business@pokerbang.net, and we will promptly take steps to delete any such information.
9. Cookies and Similar Technologies
We use cookies when you visit our websites. However, we provide you with the option to choose which non-essential, optional cookies you would like to allow. Please refer to the relevant cookie policy on the website you are visiting for more detailed information regarding the specific cookies used.
10. Notice to California Residents
For the purposes of the California Consumer Privacy Act of 2018 (the “CCPA”):
1) We do not sell nor share consumer personal information as per sections 1798.140(ad)(2) and 1798.140(ah)(2) respectively.
2) In accordance with section 1798.130(a)(5):
the list of your rights is specified in section 7 of this privacy policy;
the categories of personal information We collect and have collected about consumers in the preceding 12 months and the business purpose for collection are listed in section 2 of this privacy policy.
3) In accordance with section 1798.130(a)(1)(A) and (B), consumers can contact us via an email address provided herein. And where an internet website is separately accessible for a particular App, that internet website is also available to submit any requests consumers may have.
4) As per the last sentence of section 1798.130(a)(2)(A), We do not wish to collect more information than we already hold about consumers when dealing with verifiable requests, and, as such, We require the consumers to use the account they hold with us to submit a verifiable consumer request.
Put simply, We have an obligation to reduce the risk of processing unauthorized requests. Thus, if you contacted us from an email address asking for information relating to a user with a completely different email address and user ID, We would ask you to use the in-App chat to authenticate the request. And this has to be done to a reasonably high degree of certainty.
5) You may designate an authorized agent to make a request on your behalf. In order to do this, you should, firstly, provide the agent with written and signed permission to submit a request on your behalf. Secondly, you must verify your own identity directly with us and confirm the authority of the agent. Please, note that We retain the right to refuse a request from an allegedly authorized agent absent the legal proof of authority.
11. Rights of Virginia Residents
If you are a resident of Virginia, under the Virginia Consumer Data Protection Act (VCDPA), you have the following rights:
You have the right to know how we collect, use, and share your personal data.
You can request to access, delete, correct, or receive a copy of your personal data.
You have the right to opt-out of targeted advertising, personalized analytics, or sales activities based on your personal data.
To exercise these rights, please contact us: Section 13
We will respond to your request within 45 days of receipt.
12. Third-Party Login
12.1 Facebook Login
Our App integrates the Facebook Login SDK to provide you with a convenient way to access your account.
12.1.1 Data Collected
When you choose to log in with Facebook, we may receive the following information, depending on your permissions:
Basic Facebook public profile data (such as your name, profile picture, and email address);
Other information that you explicitly authorize us to access.
12.1.2 Purpose of Use
This data is used solely for:
Verifying your identity and enabling login authentication;
Providing login services and maintaining your account access;
Delivering a more personalized in-app experience.
12.1.3 Data Sharing
The Facebook Login process involves secure data exchange between our App and Facebook. For more details, please refer to the Facebook Data Policy, available at https://developers.facebook.com/terms/dfc_platform_terms/ We do not sell your data to third parties.
12.1.4 Your Choices
- You may revoke Facebook authorization at any time through your Facebook account settings, or choose to log in with another method.
- Data Deletion (Self-Service): You can delete your game account at any time by navigating in the App to: Home → Settings (top-right corner) → Account → Delete Account. Once confirmed, your account and related data will be deleted, and the connection with your Facebook account will be automatically unlinked.
If you prefer, you may also send a data deletion request to business@pokerbang.net with your Facebook profile link or UID, and we will process your request in line with our data retention and legal obligations.
12.2 Apple Login
Our App integrates the Apple Login feature (Sign in with Apple) to provide you with a secure and convenient login option.
12.2.1 Data Collected
When you choose to log in with Apple, we may receive the following information:
- Basic information provided by Apple (such as your name, email address, or the anonymous email address you select).
12.2.2 Purpose of Use
This data is used solely for:
Verifying your identity and enabling login authentication;
Providing login services and maintaining your account access;
Delivering a more personalized in-app experience.
12.2.3 Data Sharing
The Apple Login process involves secure data exchange with Apple. For more details, please refer to the Apple Privacy Policy, available at https://www.apple.com/legal/privacy/ We do not sell your data to third parties.
12.2.4 Your Choices
- You can revoke authorization or adjust login settings at any time through your Apple ID management page;
- You can also delete your game account directly in the App using the same Settings → Account → Delete Account path, which will remove your data and unlink your Apple login.
13. Device Permissions and Notification Features
To provide notification reminders and unread message indicators, our App may access certain device notification-related features and system settings.
This includes the ability to interact with the device’s notification management and launcher badge functionality in order to display unread counts or alert indicators on the App icon.
These permissions are used solely to support notification and reminder features. We do not use them to collect personal information such as your name, contact details, or precise device identifiers, nor do we access the content of your notifications.
Any access to such device features is limited to what is necessary for the App to function properly and improve user experience, in accordance with Google Play policies.
14. Data Protection Officer/Representative
1) Our data protection officer who is responsible for matters relating to privacy and data protection at Bang Bang can be reached at: business@pokerbang.net
2) In accordance with the applicable legal regulations governing the protection of Personal Data, each request/inquiry will be resolved without undue delay and at the latest within 30 days of receipt.
3) When contacting and posting such requests, we will invest reasonable efforts to confirm your identity and to prevent unauthorized Personal Data processing.
15. Contact Us
If you have any questions regarding this privacy policy, feel free to reach out to us at any time via email, by post, or through the App.
Summit Wind Culture & Tech Co., Ltd.
Attention: Data Protection
Flat 1309, 13/F, King's Commercial Building, No. 2-4 Chatham Court, Tsim Sha Tsui, Hong Kong
Support Team: business@pokerbang.net