Privacy policy

Breeds Tech Limited designs and publishes. "UPoker, "we", "our", or "us" in this Privacy Policy refers to Breeds Tech Limited registered in (Location). For purposes of data protection laws, Breeds Tech Limited is the data controller of your personal information.

INFORMATION WE COLLECT

The information we collect depends on the nature of the services that we provide for your use. Please see below for more details.

INFORMATION YOU GIVE US DIRECTLY

We collect information that you provide us, including:

- Your UPoker Account information, including your email address.
- Security questions and answers;
- Details you give when requesting assistance, such as name, contact number, and email records of the errors or difficulties you faces while using any of our services.

INFORMATION YOU PROVIDE WHEN PLAYING ONLINE

During your participation in social features of our products such as chat, audio, and visual messaging and other electronic information that you may disclose could possibly become publicly available. These information may also be read, copied, and disseminated by other players. Please ensure that your privacy settings reflect your preferences.

OTHER INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES

Other information may be collected automatically by our system through your use of our Services. This includes IP addresses;

- Mobile and other hardware or device identifiers - GPS location data
- Browser details including the browser type and your preferred language
- Referring and exit pages, including landing pages, pages you viewed as well as interactions with other web content.
- Platform type
-Information about your device, hardware and software, such as your hardware settings and components, UPoker software and updates you have installed or use and presence of required plugins;
-Device events information, including updates and crash reports.
-Biometric information (for specific functions or specific applications including face scan).

We also may collect and store information locally on your device using mechanisms like cookies, browser web storage (including HTML5) and application data caches.

LEGAL BASIS FOR PROCESSING

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing for our Services and on contractual necessity to process information when you create a UPoker Account. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in Section 11 below.

HOW WE COLLECT INFORMATION

We and third parties use technologies described below to collect information.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small files who archive your internet browser use. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what games you play. This information helps us keep track of your activities in the shopping cart and we will use such information to enhance your user experience.

We use other technologies for similar purposes as a cookie. We use tracking pixels or clear GIFs to collect information about your use of our Services and your and your response to our marketing emails. We use internet log files (which contain technical data such as your IP address) to monitor traffic on our Services, troubleshoot technical problems, detect and prevent fraud and enforce our User Agreement.

We also use Analytics, Advertising, and Anti-Cheat and anti-Fraud technologies in our services that utilize the same cookies and similar mechanisms.

ANALYTICAL TECHNOLOGIES

We use our own game servers and internal and third party analytic technologies to collect information about how you use our Services, your computer or device and the health of our Services. This information includes technical and related information about your computer or device and operating systems (such as IP Address and Device ID), information about your feature usage, gameplay and usage of statistics, system interactions and play a game offline, this data will be stored in your device and transmitted to UPoker when your device connects back to the internet. If you participate in the online services, UPoker also may collect, use, store, transmit and publicly display your persona and /o statistical data regarding your game play. Third party analytics may be included in our systems of our Services and they may combine the information they find both in UPoker and a list of other sources to be used.

HOW WE USE YOUR INFORMATION

We use your personal and non-personal information, both individually and combined together, in the following ways:

TO OPERATE OUR BUSINESS AND TO ENHANCE AND YOUR BUYING EXPERIENCE INCLUDING TO:

  • Operate, improve, and develop our site and Services;
  • Undertaking research for technological development and demonstration;
  • Facilitate sharing on social networks;
  • Serve and measure the effectiveness of advertising;
  • Measure the health of our Services;
  • Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;
  • Set up and maintain accounts you register for;
  • Identify, fix, and troubleshoot bugs and Service or functionality errors;
  • Other purposes you consent to, are notified of, or are disclosed when you provide personal information;
  • Adhere to your preferences and to deliver dynamic content; and
  • Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.

TO PROVIDE YOU SUPPORT, INCLUDING TO:

  • Help identify and troubleshoot problems with your account;
  • Survey your opinions through surveys or questionnaires;
  • Communicate with you and respond to your specific requests or questions; and
  • Manage and send you confirmations and important information about your account, Services, purchases, subscriptions, and warranties.

TO PERSONALIZE OUR COMMUNICATIONS WITH YOU, INCLUDING TO:

  • Present offers and/or information relating to games you might like;
  • Make recommendations to you; and
  • Personalize advertising for you and deliver targeted marketing, services updates and promotional offers.

We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational or other legitimate reasons.

INFORMATION WE SHARE WITH THIRD PARTIES

We do not share, sell (as the term is defined under applicable privacy laws, such as the California Consumer Privacy Act), or disclose your personal information with Third Parties other than for Security Reasons (Anti-Cheating Measures).

WHERE WE HOLD YOUR INFORMATION

Personal information we collect may be stored and processed for the purposes set out in this Privacy and Cookie Policy in Hong Kong, China or any other country in which UPokers, its subsidiaries, or third-party agents operate. By using our Services, you acknowledge that your personal information may be transferred to recipients in Hong Kong, China and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Security of our players’ information is a priority at UPoker, and we take a range of measures to help protect it, including encryption of sensitive financial information. Even so, no security measure is 100% perfect. This means we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

YOUR CHOICES AND CONTROLS

We give your meaningful choices when it comes to important uses and collection of information. For example, if you no longer wish to receive marketing emails from UPoker, you may click the unsubscribe link included in the footer of every marketing email we send.

To protect your account security and personal information, you may be asked before exercising these rights to verify your account ownership, for example by reciting a code sent to the email address associated with your UPoker account to a customer support representative. Once you have verified your account ownership, you may also provide your written confirmation authorizing an agent to exercise these rights for you.

Your right to deletion. You may deactivate your UPoker Account or delete the personal information associated with your account by contacting shop@upoker.net. If you do so, you will no longer have access to the UPoker games or Services associated with your account. Note that UPoker may retain information needed to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Services. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you with, create, and improve our Services, and to comply with the law.

Your right to access. You can access the personal information we hold about you in a portable format. You can download a copy of your basic information by visiting your UPoker account.

Your right to correction. You can request correction of your personal information where it is inaccurate of incomplete. In some cases, we may provide self-service tools, such as those on the UPoker customer account portal.

Your right to opt out or object to certain processing. You may have the right to opt out of the sale of your personal information to third parties, if applicable, or object to some processing of your data, where such requests are permitted by law.

You have a right not to receive discriminatory treatment for the exercise of the privacy rights described in this section.

CHANGES TO OUR POLICY

We may update this policy from time to time, so please review it frequently. We’ll notify you of material changes via a notice on our home page (www.upoker.net) effective immediately. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the ‘last updated’ date displayed at the top of this policy.

WHAT PERSONAL DATA DOES UPOKER COLLECT AND USE (CATEGORIES OF PERSONAL DATA)?

These are the categories of Personal Data we collect directly or indirectly from you.
Identity Information - includes: name [first, last, initials], Date of Birth, e-mail address, unique consumer identifier number (including your Creators Club membership number), nickname, password, social media identifiers and information passed along to us via your Facebook or Runtastic account, your device fingerprint, and gift card codes that are assigned to you. We use it to verify your identity.
Contact Information - includes: your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information. We use it to contact you for different reasons depending on the purposes stated below.
Location Information - includes: your residential location, current log-in location [IP address], GPS location (if you wish to share us, for example through your mobile device settings), or the specific UPoker site you have visited that might give us clues about where you are. We use it to help you find what you are looking for at your current location.
Size Information - includes: shoe size, clothes size, height, weight, chest, waist, hip, inseam, body shape, heel-toe measurement. We use it to make sure your gear fits.
Purchase Information - includes: your payment information (credit card number), payment risk profile (provided to us by our payment risk solution), shopping cart (your ordered items), delivery details, shipping and billing address, customer order number, purchase history with UPoker, transaction ID, and any other information related to your purchase. We use it to complete your order on UPoker sites and apps, in UPoker stores, or other selling platforms.
Behavioural and Profile Information - includes: your shopping history, Wishlist items, your browsing behaviour, your browsing preferences, your shopping preferences, in-store interactions, your workout history, product reviews, social media interactions with us, and any other intelligence we have about you to help us learn you as a consumer better, including “Community information”. We use it to know you better as a consumer, so we can send you marketing messages containing only products and services that we think you might be interested in.
Community Information – includes: information provided by you when you participate various UPoker events and communities either as a trainer, team member, a participant or as a promotor of our events, including for example: pictures, videos, your nickname, your team, your interests and preferences, your feedback, leader boards, event participation, joined groups, and registration details. We use this information to organise the events and communities, and to know more about you as a consumer.
Social Media Information – includes: information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc., including: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”. We obtain this information from the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with.
Device Information – includes: Information about your device or browser that give us an idea about your browsing behaviour or device usage. Your device information is collected by our app, and your browser information is collected by our cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on our website, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type, device type, versions, operating system.
Activity Information - includes: fitness data (for example workout start and end times, activity type, sports category), sensor data (for example step goal, duration, pace, distance, calories, heartbeat, RunScore and speed), and other data related to your fitness app. We use it to help you improve your performance goals and improve your user experiences and identify what products might be best for you based on your exercise patterns.
Correspondence – includes: conversation we have when you contact customer service, the emails you write us about our products or services, the complaints you address to us via post, e-mail, fax, or call, notes we prepared on your feedback, call back from our Customer Service to you, and any other communication between you and UPoker personnel. We record all Customer Service calls for quality assurance purposes.
Preference information - includes: preferred language, log-in location, Wishlist items, preferred shipping address, browsing preferences, our correspondence with you, your UPoker product reviews. We use it to give you convenience when you visit and/or shop on our sites and apps.
Creators Club information – includes: Unique Member Identifier (member ID), date you became a member, store ID (if you signed up in a retail store), source ID, country and brand of your original membership, membership points, engagement history, rewards history, membership vouchers associated to members. All the information the listed here will be kept for as long as you are a Creators Club member.

WHAT DOES UPOKER DO WITH YOUR PERSONAL DATA AND WHY (PURPOSE, PROCESSING, LEGAL BASIS)?

The lawful basis upon which we rely to process your Personal Data are:

  • a. Your consent:
    When you:
    i. access, use and/or interact with us through our website as well as our different platforms, portals and applications;
    ii. participate in any of our product review or survey; and/or
    iii. participate in our events and communities,
    you consent to us processing your Personal Data for the purposes identified in this Privacy Notice and in accordance with the manner stated in this Privacy Notice.

    We will obtain your consent separately should we process your Personal Data for any other specific purposes, for example where your Personal Data is processed for purposes related to sending marketing and promotional messages to you and inviting you to our events.

    We will also obtain your explicit consent should we process your sensitive personal data. Your sensitive personal data include information as to your physical or mental health or condition.
  • b. Performance of contract:
    We will process your Personal Data in order to fulfil our contractual obligations, so that that we can provide you with your requested products and/or services.
  • c. Legal Obligation:
    We will process your Personal Data to comply with any legal obligations under applicable laws to which we are subject.

In this section, we explain:

1.When and why do we need your Personal Data (“Purpose”)?
2.What do we do to your Personal Data for each Purpose (“Processing”)?
3.Which of your Personal Data do we need for each Purpose (“Categories of Personal Data”)?
4.With whom (types of service providers) do we share your Personal Data to achieve the purpose (“Categories of recipients”)?

I. SITE (UPOKER DOMAIN) OPERATION AND APP OPERATION
PROCESSING
To run the sites that are connected to the UPoker domain and the UPoker app, fix bugs to make sure you always see the site the way we intended, and monitor compliance with our Terms and Conditions, we screen all traffic to our site and analyse data that is received by our servers.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Device information
Identity information
Behavioural and Profile information
Preference information
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Site Administration Support Providers
II. DOMAIN AND NETWORK SECURITY AND USER AUTHENTICATION
PROCESSING
To protect our domains, detect unusual activities, and prevent security threats and protect our site-visitors from unauthorised accesses (such as hackers), we screen all traffic to our sites, and authenticate user log-in information using tokens to verify the details you provide to us and compare it with other available information, such as the credentials you have provided directly to UPoker or other platforms (such as Runtastic or Facebook) or information that is available in the public domain to ensure only “authorised” users have access to our sites. 

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Device information
Identity information
Behavioural and Profile information
Preference information
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Site Administration Support Providers
III. GLOBAL CREDENTIAL TO ALL UPOKER PLATFORMS – USER EXPERIENCE
PROCESSING
We know you don’t like to remember usernames and passwords, or having to register multiple times.

To enable our users to log on to all platforms, portals, services, communities and apps operated by or on behalf of UPoker or our subsidiaries and affiliates (which includes the Runtastic app and services) (“UPoker Platforms”) with one set of log-in credentials (“UPoker Log-In”), we store your UPoker Log-In in our global authentication platform. When you use your UPoker Log-In to enter any UPoker Platform, we will use a token to verify your identity from our global authentication platform. This also further ensures our network and domain security.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Identity information (username, password, email)
Creators Club information (for Creators Club members only)
Preference informationn
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Site Administration Support Providers
IV. SALES OF UPOKER PRODUCTS - ONLINE AND OFF-LINE ORDER
PROCESSING
To process your online and/or in-app orders, make sure your payment is received, comply with the requirements under our Terms and Conditions (3. Purchase Terms) (for selling you the products) including invoice processing, delivery, personalisation services, exchanges and refunds, click and collect. Your order cannot be completed if our payment fraud detection solutions flag your transaction as suspicious and potentially fraudulent. Please note the payment fraud detection system is an automated decision-making process. It is required to allow us to conclude the contract with you.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Location information
Size information
Purchase information
Correspondence
Device information
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Selling Partners (where applicable)
Manufacturing Providers
Delivery Service Providers
Payment Risk Solution Providers
Payment Processing Providers
IT Cloud Solution Providers
V. PAYMENT FRAUD DETECTION
PROCESSING
We combine the purchase information you provide to us with other information we obtain through our third-party payment risk and fraud prevention service providers to ensure any purchases are legitimate, or you do not purchase our products in violation with our terms and conditions. This means depending on the outcome of the analysis of your information, we may reject your order, and decline your payment. This is an automated decision-making process that is required to conclude our sales contract with you.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Behavioural and Profile information
Purchase information
Device information
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Payment Risk Solution Providers
Payment Processing Providers
IT Cloud Solution Providers
VI. PRODUCT DELIVERY
PROCESSING
Once you have successfully placed an order, we use your contact details (home and/or shipping address) and other purchase information to deliver the products you purchased to you.
CATEGORIES OF PERSONAL DETAILS
Identity information: Name
Contact information: Shipping Address
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Delivery Service Providers
IT Cloud Solution Providers
VII. ELECTRONIC DELIVERY TRACKING
PROCESSING
This is a service provided on request of the consumer by our Delivery Partners.

You have the option to track your delivery using services provided directly by our delivery partners; however, we will only be able to share your information with our delivery partners for this purpose with your consent. The service is hosted on the Delivery Partner’s platform. You should read their Privacy Notice for the processing of your Personal Data for this purpose.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Any other information you may directly and voluntarily provide to the Delivery Partner
CATEGORIES OF RECIPIENTS
Delivery Service Providers
VIII. BUSINESS OPERATIONAL ANALYTICS
PROCESSING
We need to know how we do as a business. This is in the interest of our shareholders, our board members, our employees, and our partners. For this purpose, we need to analyse different categories of information to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of our marketing and advertising campaigns, our product designs and distribution strategy, our website design and overall user experience, so we can establish, implement, and evaluate our business strategy.

This includes analysing data to understand how users browse our site and use the app to improve our user experience design to make sure you will continue to purchase our products and interact with us on our sites and applications.

To minimise the risk to you as an individual, we will only use either the unique consumer identifier or the IP address for this purpose.

You can learn more about how our Data Analytics Solution Providers provide analytics services by using your data here:
Adobe Analytics Data Collection: https://marketing.adobe.com/resources/help/en_US/reference/c_Privacy_Overview.html

Google Analytics Data Collection: https://support.google.com/analytics/answer/6318039?hl=en
CATEGORIES OF PERSONAL DETAILS
Identity information: Unique Consumer Identifier (only)
Size information
Purchase information
Behavioural and Profile information
Community information
Activity information: if we collect and process your activity information, we will explicitly ask for your consent.
Device information
Correspondence
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Prospective Buyers and Investors
Business Consulting Service Providers
Data Analytics Solution Providers
IT Cloud Solution Providers
IX. CUSTOMER SERVICE
PROCESSING
We collect your Personal Data to tell you when the product you like is available upon your request and respond to your questions and concerns through various communications channels we make available to you.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Location information
Size information
Purchase information
Correspondence
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
Customer Service Provider
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Selling Partners (where applicable)
Delivery Service Providers
Payment Risk Solution Providers
Payment Processing Providers
IT Cloud Solution Providers
X. PERSONALISED MARKETING MESSAGES VIA EMAIL (Newsletter Sign-Up)
PROCESSING
We send you marketing messages that we think you would be interested (“personalised”) to the email address you provide to us because you signed up to our email newsletters. To send you “personalised” messages, observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behaviour means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information (if available to UPoker)
Location information
Size information (if available to UPoker)
Purchase information (if available to UPoker)
Behavioural and Profile information (if available to UPoker)
Community information (if available to UPoker)
Social Media information (if available to UPoker)
Activity information (if available to UPoker): if we collect and process your activity information, we will explicitly ask for your consent. Device information
Preference information (if available to UPoker)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Email Marketing Support Providers
IT Cloud Solution Providers
XI. PERSONALISED MARKETING MESSAGES VIA EMAIL (via existing contract)
PROCESSING
We send you marketing messages that we think you would be interested in (“personalised”) to the email address you provide to us during a purchasing contract. To send you “personalised” messages, observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behaviour means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information (if available to UPoker)
Location information
Size information (if available to UPoker)
Purchase information (if available to UPoker)
Behavioural and Profile information (if available to UPoker)
Community information (if available to UPoker)
Social Media information (if available to UPoker)
Activity information (if available to UPoker): if we collect and process your activity information, we will explicitly ask for your consent.

Device information
Preference information (if available to UPoker)
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Email Marketing Support Providers
IT Cloud Solution Providers
XII. TARGETED MESSAGES ON 3RD-PARTY ADVERTISING PLATFORMS
PROCESSING
We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. We use third-party solutions such as Google Audience and Facebook Custom Audience to help us do a better job at targeting our campaigns and messages for our consumers. Your Personal Data is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from UPoker. We also need to analyse necessary information to understand the impact of our campaigns. If you don’t accept that we track you for this purpose, you will still see UPoker advertisements on other platforms at random.
You can learn more about how our Advertising Partners help us achieve this purpose by visiting their sites:
Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en
Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956
Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531
Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience
Use of Cookies/Tags/Pixels: We may collect your personal details for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES”.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information (if available to UPoker)
Location information
Size information (if available to UPoker)
Purchase information (if available to UPoker)
Behavioural and Profile information (if available to UPoker)
Community information (if available to UPoker)
Social Media information (if available to UPoker)
Activity information (if available to UPoker): if we collect and process your activity information, we will explicitly ask for your consent.
Device information
Preference information (if available to UPoker)
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Advertising Agency Partners
Social Media Platforms
Targeted Marketing Service Providers
IT Cloud Solution Providers
XIII. CREATORS CLUB MEMBERSHIP ADMINISTRATION – WHERE APPLICABLE
PROCESSING
Please note this section only applies if you are joining UPoker Creators Club to become a Creators Club member.

When you become an UPoker Creators Club member, we use the information specified above to maintain and administer your membership as described in the Creators Club Terms and Conditions.

In particular, your Personal Data is used for:
a) calculating your club points to provide you rewards;
b) providing you access to special offers and promotions;
c) sending you invitations to exclusive events;
d) allowing you access to limited edition products;
e) providing you access to a premium Runtastic subscription when eligible;
f) storing your shipping address and payment details to shorten check-out time online and in the app; g) storing your complete order history so you can access it at any time; and h) allowing you to track your order delivery from your account.

When you use your Creators Club membership ID, we receive the information to calculate reward points for you, such as when you purchase in participating UPoker brand retail stores. Your data will be shared with Creators Club Partners who provide certain rewards according to Creators Club Terms and Conditions.

You will receive email marketing messages from UPoker as a Creators Club member. If you wish to unsubscribe from our marketing messages, please refer to “6”. What are your rights and how can you exercise them?” section.

You can also use your Creators Club membership in the UPoker app. When you use the UPoker app with your Creators Club membership, we use push notifications in the app to communicate information about your membership or promotional activities and offers. You can switch off push notifications at any time using “Settings” in your mobile devices. However, if you switch off push notifications, we may need to contact you via emails for important messages relating to your membership.
CATEGORIES OF PERSONAL DETAILS
Creators Club information
Size information (if available to UPoker)
Purchase information (if available to UPoker)
Behavioural and Profile information (if available to UPoker)
Community information (if available to UPoker)
Social Media information (if available to UPoker)
Activity information (if available to UPoker): if we collect and process your activity information, we will explicitly ask for your consent.
Device information (if available to UPoker)
Preference information (if available to UPoker)
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Prospective Buyers and Investors
Business Consulting Service Providers
Data Analytics Solution Providers
Creators Club Partners
XIV. PRIVATE EVENT REGISTRATION
PROCESSING
When you sign up for an event we organise that have limited spots, we use the Personal Data you provide to reserve a spot for you. Your Personal Data will be used according to the Terms and Conditions associated with the event.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Location information
Activity information: any information we may collect from you on the day of the event. We will explicitly ask for your consent, before collecting and processing your activity information.
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker User organising the event
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Event Partners (where applicable)
IT Cloud Solution Providers (where applicable)
XV. OPEN EVENT REGISTRATION
PROCESSING
We often also organize events that are open to everyone. We use the Personal Data you provide to keep you inform of the events you are interested in.
CATEGORIES OF PERSONAL DETAILS
Identity information
Contact information
Location information
Activity information: any information we may collect from you on the day of the event. We will explicitly ask for your consent, before collecting and processing your activity information.
Creators Club information (for Creators Club members only)
CATEGORIES OF RECIPIENTS
UPoker User organizing the event
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Event Partners (where applicable)
IT Cloud Solution Providers (where applicable)
XVI. PRODUCT RESEARCH AND DEVELOPMENT
PROCESSING
We conduct analysis to research improve our products and services. This includes asking you questions in surveys, asking you for feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us, try new technologies in our product that might collect Personal Data to stay ahead of the competition.We process this information based on your consent, so by participating in any product review or survey, you consent to us processing your Personal Data for this purpose. Where you wish to object to us processing your Personal Data for this purpose, we will anonymise your information, so it is no longer Personal Data.
CATEGORIES OF PERSONAL DETAILS
Identity information (only if required by the project)
Contact information (only if required by the project)
Location information (only if required by the project)
Size information
Purchase information (only if required by the project)
Behavioural and Profile information (only if required by the project)
Community information: this is the response you provided whichever format agreed at the time of the project.
Social Media information (only if required by the project)
Activity information (only if required by the project): if we collect and process your activity information, we will explicitly ask for your consent.
Device information (only if required by the project)
Correspondence (only if required by the project)
Preference information
Creators Club information (for Creators Club members only)
Health information: if a project requires you to also provide health information, we will explicitly ask for your consent.
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Prospective Buyers and Investors
Business Consulting Service Providers
Data Analytics Solution Providers
Manufacturing Providers
IT Cloud Solution Providers
XVII. LEGAL OBLIGATION - COOPERATION WITH LAW ENFORCEMENT AND REGULATORY AUTHORITIES (INCLUDING COURTS)
PROCESSING
When we are legally required to provide your Personal Data for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims, we will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law. We may not be able to notify you if it is against the law to do so.
CATEGORIES OF PERSONAL DETAILS
All Categories of Personal Data as requested by the enforcement authority.
CATEGORIES OF RECIPIENTS
UPoker Data Users
UPoker AG Subsidiaries and Affiliates
Local and national government authorities, including tax authorities
Local and national law enforcement agencies
Local and national judiciary
XVIII. COLLECTING YOUR DEVICE INFORMATION ON OUR WEBSITE USING COOKIES, PIXELS, TAGS, AND SIMILAR TECHNOLOGIES (“COOKIES NOTICE”)
PROCESSING
When you visit the UPoker site, we store data collectors such as cookies, tags, pixels, tag containers, beacons, among others, in your browser to obtain certain information about your current browsing session. These technologies are often referred to as “Cookies” collectively by other websites. Cookies also enable our website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. We use Cookies for different purposes. Please review the information below to understand how we use different types of Cookies to fulfil different purposes.

“REQUIRED” – site functionality and business operation.
We use “Required Cookies” to operate our site. This includes storing a unique identifier to manage and identify you as a unique visitor to our site, to provide a consistent and accurate service to you. This includes making sure that we remember the products you have placed in your cart, or your language preferences. These Cookies are stored for the duration of your browsing session. Without these Cookies, you will not be able to view our site properly.

“FUNCTIONAL” – website improvement and performance
We use “Functional Cookies” to continuously improve our website performance. This includes using the data we collected from you to do the following:
Web analytics —Based on your browsing behaviour, we will analyse the data to improve the functionality and design of our site.
Ad response rates— Based on how you come to our site, we will measure our ad response rates by analysing our ad click-through rates to improve the effectiveness of advertising purchased on a site external to ours.
Affiliate tracking— We need to let our affiliate marketing partners, or service providers have certain information if you came to our site, and purchased products, through a visit to theirs. This is required as we may need to provide them a fee for such services. For this purpose, we will share information about your visit, including the products you have purchased.
Error management— We measure errors presented on a website, to make sure we fix bugs or any issues promptly.
Testing designs— We need to use A/B testing or multivariate testing, to ensure a consistent look and feel is maintained for the user of the site in the current and subsequent sessions.
“MARKETING”
We use “Marketing Cookies” provided by our advertising partners to make sure our advertising messages are shown to you at the right time and the right place. These Cookies are persistent but time-limited cookies. These Cookies contain a unique key to distinguish individual users’ browsing habits. We also use these Cookies to limit the number of times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign. The identifier stored by these Cookies are provided by our partners. We cannot use the same identifier in our own systems. We also use these cookies to serve ads that are relevant to your immediate geo-location, for example to provide you with the nearest store where the product you are browsing may be available.
CATEGORIES OF PERSONAL DETAILS
Device information

WHAT DOES UPOKER DO WHEN WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF MALAYSIA?

Depending on the Personal Data processing activity, your Personal Data is shared with different “Categories of Recipients”. Where the recipient is located outside Malaysia, we will either obtain your consent to transfer your personal data overseas or take all reasonable precautions and exercise all due diligence to ensure that your Personal Data will not be processed in contravention of the PDPA.

HOW DO WE SECURE YOUR PERSONAL DATA?

We implement appropriate technical and organisational measures to address the risks corresponding to our use of your Personal Data, including loss, alteration, or unauthorised access to your Personal Data, and empowering you to exercise your rights. We require our service providers to do the same through contractual agreements. However, you should be aware that any transmission of your Personal Data through the internet is at your own risk. We can only protect your Personal Data when we have it.

WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Under the PDPA, you have the rights listed and explained below. We also provide you instructions on how to exercise each right. We need to confirm your identity before we can handle your requests. When we refuse your request for legal reasons, we will tell you why.