Replay Digital Ltd develops and publishes the Replay Poker social poker game for the web (the
"Service"). Replay Digital Ltd is the data controller of the website ReplayPoker.com.
Replay Digital Ltd is committed to protecting the privacy of its
users and provide them a better social Digital experience ("users" or
Replay Digital Ltd manages, collects, stores, shares, uses and protects the
information you provide in connection with any Replay Digital Ltd game or
application whenever you play our games or otherwise access any of our
Services, products, content, ReplayPoker.com and/or the other domains
provided by Replay Digital Ltd.
access any of our other products, services, content, ReplayPoker.com
and/or the other domains provided by Replay Digital Ltd, together referred
to as “Services.”
By using the Service, you agree to the collection, disclosure, storage
do not want Replay Digital Ltd to collect, store, use or share your
not play Replay Digital Ltd’s games or use our Services. Replay Digital Ltd may
- what information we collect, how we collect it
- how we use that information and with whom we share it
- how you can access and update that information and means of
- how do we protect children privacy
- how we protect the information we store and share about you
We do not share personal information with third parties for direct
Users in certain jurisdictions have a right to access personal
information held about themselves. Your right of access can be
exercised in accordance with applicable law.
2. Information We Collect and How We Collect It
Replay Digital Ltd only collects Personal Information to the extent
necessary to fulfil one or more of its functions and activities, and
will do so only by fair and reasonable means. Generally we will collect
Personal Information directly from the individual to whom the Personal
Information relates, but in some circumstances (including as outlined
below), it may be necessary for us to collect information from a third
Information About You That We Get from Third-Party
Applications, Including Social Networks (like Facebook)
If you play Replay Digital Ltd’s games or connect our Services to any
third-party applications, including social networks like Facebook,
Replay Digital Ltd may receive certain information about you from the
provider of the third-party application. The information we receive
depends on your privacy settings and, if applicable, your
friends’ privacy settings on that third-party application.
For example, Replay Digital Ltd may collect and store some or all of the
following information shared by the provider of the connected
If you access connect our Services to a third-party application, you
should also read that third-party application's Terms of Service and
- your profile picture or its URL;
- your user ID number (like your Facebook ID number), which
may be linked to publicly-available information like your name and
- the user ID number and other public data of your friends;
- the login e-mail you provided to that third-party
application when you registered with it;
- your gender;
- your birthday;
- whether you like our Facebook page;
- any other information that you or the provider of the
third-party application share with Replay Digital Ltd.
If you are unclear about what information a third-party application is
sharing with us, please go to the third-party application to find out
more about their privacy practices.
Cookies and Automated Information Collection
Like many websites, Replay Digital Ltd and service providers acting on our
behalf, like Google Analytics, store log files and use tracking
technologies such as "cookies" to collect information. A cookie is a
small data file that is transferred to your computer’s hard disk or
your mobile device for record-keeping purposes. The Service may send
cookies to a computer or a mobile device when a user accesses or views
a Service. Information contained in a cookie may be linked to personal
information for purposes such as improving the quality of Replay Digital Ltd’’s Service, tailoring recommendations to interests, and making
the Service easier to use.
Cookies can be disabled at any time by changing your web browser’s
options to stop accepting cookies, to prompt you before accepting a
cookie from the websites you visit or limit the type of cookies you
allow. Flash cookies operate differently than browser cookies and
cookie management tools available in a web browser may not remove flash
cookies. If you do not accept cookies, however, you may not be able to
use all features, portions or functionalities of the Service.
We and our service providers may also employ other technologies
including (i) web beacons, which allow us to know if a certain page was
visited or whether an e-mail was opened; (ii) tracking pixels, which
allow us to advertise more efficiently and effectively by excluding our
current users from certain promotional messages, identifying the source
of a new installation or delivering ads to you on other websites; and
(iii) local shared objects also known as flash cookies, which help us
to reduce fraud, remember your in-game preferences and speed up load
We and our service providers use these log files, tags, and tracking
technologies to collect and analyze certain kinds of technical
In some cases, we will connect this information with your social
network ID or Replay Digital Ltd user ID.
- the type of device you are using;
- your operating system version;
- your mobile device’s identifiers, like your MAC Address,
Identifier For Advertising (IDFA), and/or International Mobile
Equipment Identity (IMEI);
- your browser types;
- your browser language;
- referring and exit pages, and URLs;
- platform type;
- the number of clicks on a page or feature;
- domain names;
- landing pages;
- pages viewed and the order of those pages;
- the amount of time spent on particular pages; and
- game state and the date and time of activity on our
websites or games.
For more information on how to limit the types of cookies you allow,
please see Opting out of Cookie Tracking section..
Information About You That You Share With Us Directly
When you use our Services you may give us information directly (like
when you’re setting up your account) and we will store that on our
During the account set-up process you will be asked for the following
We also create a player profile, separate from your social networking
site profile (for example, your Facebook profile), that other Replay Digital Ltd players can see. Your player profile may include information
- your e-mail address;
- a username;
- a password;
- a profile picture;
- your real name
- your gender;
- your date of birth;
- your city;
- a biography about yourself;
- the country where you last accessed the Service from;
You can take part in certain activities on our Service that let you
communicate or share information not just with Replay Digital Ltd, but also
with other Replay Digital Ltd players. These include:
You acknowledge and expressly agree that we may access in real-time,
record and/or store archives of these communications and comments on
Replay Digital Ltd's servers to make use of them to protect the safety and
well-being of our players and Replay Digital Ltd’s rights and property in
connection with our Services; to conduct research; to operate, improve,
personalize and optimize our Services and our players’ experiences,
including through the use of analytics; and to manage and deliver
- participating in player forums and message boards;
- posting public comments to hand replays and our blog;
- sending private messages or invitations to other players,
either directly on our websites or to their e-mail accounts; and/or
- chatting with other players
Replay Digital Ltd may obtain the billing and payment information
that you provide when your purchase is processed by our payment
partners (like PayPal and Stripe). Our Terms of Service
explain our policies and terms relevant to our charges, billing
practices and virtual currencies.
If you purchase virtual currency in a Replay Digital Ltd game, our
third-party payment processor will collect the billing and financial
information it needs to process your charges. This may include your
postal address, e-mail address and financial information.
Replay Digital Ltd does not collect or store your financial
information, like credit card numbers. However, Replay Digital Ltd’s payment
processors may share non-financial information with us related to your
purchases, like your name, billing address and the items purchased in
order to fulfill your order.
Message Boards and Chat Rooms
You may be able to take part in certain activities on our websites or
games that give you the opportunity to communicate or share information
not just with Replay Digital Ltd, but also with other users of our Service.
Note that certain information you post and communicate through a
Service or a third party site or service is public information for
which you have no expectation of privacy.
You may choose to disclose information about yourself in the course of
contributing user generated content to Replay Digital Ltd sites or Services
or in its chat rooms, blogs, message boards, hand replays, user
“profiles” for public view or in similar forums on its sites through
mobile services and/or through third party sites or services, posting
public comments to other users' profiles or gameboards, sending private
messages or invitations to other users, either directly on our websites
or to their email accounts. Information that you disclose in any of
these forums is public information, and there is no expectation of
privacy or confidentiality.
You should be aware that any personally identifiable information you
submit in the course of these public activities can be read, collected,
or used by other users of these forums, and could be used to send you
unsolicited messages. Replay Digital Ltd is not responsible for the
personally identifiable information you choose to make public in any of
these forums. We may also record and store archives of these
communications on Replay Digital Ltd's servers to protect the safety and
wellbeing of our users and Replay Digital Ltd's rights and property in
connection with the Service. You acknowledge and consent to the
recording and storage of such communications for these purposes.
If you post a video, image or photo through a Service for public view,
you should be aware that these may be viewed, collected, copied and/or
used by other users without your consent. Replay Digital Ltd is not
responsible for the videos, images or photos that you choose to post
through a Service. Please see Replay Digital Ltd’s Terms of Service
on this point and for other guidelines about posting content through
Customer Support Correspondence
Except as provided herein, when you ask for help from our Customer
Support team, we will collect and store the contact information you
give them (generally, your name and e-mail address), information about
your game play or activity on our Services, and your Replay Digital Ltd
player and ID number. We will also store the communications you have
with the Customer Service team and any information in those
communications in order to provide support and improve the Services.
We may collect or receive information about you from other sources like
third-party information providers. We use this information along with
information you provide us directly, for example, to help you and your
If you would like to learn more about how we secure your information,
please see Security of Your Information section below.
3. How We Use the Information We Collect and With Whom We Share
How We Use Your Information
The main use of the information we collect and store is to provide a
better Digital experience, but there are other uses as well. The uses
for which we collect and store your information include:
One important use of your information is communication. If you have
provided your e-mail address to Replay Digital Ltd, we will use it to
respond to Customer Support inquiries, and keep you informed of your
in-game activity, including messages from friends, let you know about
in-game status and promotions. Some messages, like private messages to
friends, may include your name and profile photo. We may also send
promotional e-mail messages ("Promotional Communications") directly, in
accordance with your marketing preferences. Each Promotional
Communication will offer you choices about receiving additional
messages. Receipt of such communications depends on Replay Digital Ltd
having certain contact information from you.
- to create your game accounts and allow you to play our
- to operate, improve and optimize our Services and our
- to identify and suggest connections with other Replay Digital Ltd players and personalize our Services to you;
- to enable players to communicate with each other;
- to provide technical support and respond to player
- to protect the safety and well-being of our players;
- to protect Replay Digital Ltd's rights and property in
connection with our Services;
- to prevent fraud or potentially illegal activities, and to
enforce our Terms of Service;
- to notify players of in-game updates, new products or
- to administer rewards, surveys, contests, or other
promotional activities or events sponsored or managed by us;
- to comply with our legal obligations, resolve any disputes
we may have with you or other players, and to enforce our agreements
with third parties; and
- to conduct research.
How We Share Your Information
We may disclose or publish aggregated information (information about
you and other players collectively that is not intended to specifically
identify you, for example, players between the ages of 30 and 40 who
live London) and other non-personal information about our players for
industry analysis, demographic profiling, marketing, analytics,
advertising, and other business purposes.
Aggregated and Analytical Information
We use anonymous, statistical or aggregated information and may share
it with our partners for legitimate business purposes. It has no effect
on your privacy, because there is no reasonable way to extract data
from the aggregated information that can be associated with you. We
will share your identifiable information only subject to the terms of
this policy, or subject to your prior consent.
Friends and Other Replay Digital Ltd Players and/or
The Service supports and often encourages you to interact with other
players. If you register through a social network (for example,
Facebook Connect), your social network friends who are registered on
Replay Poker will automatically be added as Friends. Other players,
regardless of whether they are your social network friends or not, will
be able to see descriptions of your game activity (including the
identification of any Replay Poker games you have played), communicate
with you within our Services, and view your game profile, which will
include your username and your profile picture, if you have one. Any
other player will see your game profile if you are playing at the same
table or if they are watching a replay of a poker hand you participated
in. Other players may also be able to send you
friend requests through the related Replay Digital Ltd’s
Third-Party Service Providers
We will share your information with third-party companies to perform
services on our behalf, like processing payments, analyzing data,
optimizing game play, e-mail delivery, hosting services, customer
service and to help us in our marketing efforts, including managing and
delivering contextual and tailored advertisements. We contractually
require these third-party service providers to maintain the
confidentiality of the information we share with them, and we
contractually require them not use your information for anything other
than to provide services on our behalf.
Sale or Merger
In the event that Replay Digital Ltd undergoes a business transition
(including proposed transactions), like a merger, acquisition by
another company, or sale of all or part its assets (like selling a
game), we may disclose or transfer all of your information, including
personal information, to the successor organization in the transition.
We will make reasonable efforts to let you and other players know (in
transition before transferring your personal information.
4. How to Access, Update and Manage Your Information and Means
Accessing and Updating Your Information Held by Replay Digital Ltd
If you want to review, delete, or change the information Replay Digital Ltd
has about you or have additional questions, you may send an e-mail to firstname.lastname@example.org.
Place "Review My Account" in the subject line and include your username
and e-mail address in the body of the e-mail. We will respond to your
request within thirty days.
Stopping Use of Your Information
If you no longer want Replay Digital Ltd to make active use of your
information, you may send an email to email@example.com.
Place "Delete My Account" in the subject line and include your username
and e-mail address in the body of the e-mail. We will respond to your
request within thirty days. Please note that certain records, for
example those relating to payments or customer service matters, will be
held for legal and accounting purposes. If you have sent content
through or posted content on the Service, we may not be able to delete
Manage Information We get from a Third-Party Application
To manage the information Replay Digital Ltd receives about you from a
third-party application where you play our games, like Facebook, you
will need to follow the instructions for the third-party application
for updating your information and changing your privacy settings. The
privacy management tools for applications on Facebook can be found here.
To review and update information associated with your Replay Digital Ltd
game profile in certain games, visit the “settings” page in that game.
You also can manage some aspects of information collection and use by
visiting the “settings” page of your mobile device and reviewing the
permissions of each application or “app.”
Once Replay Digital Ltd receives your information from a third-party
application or your mobile device, that information is stored and used
and update that information as described below.
Opting Out of Promotional Emails from Replay Digital Ltd
If you want to stop receiving promotional e-mails from Replay Digital Ltd,
click on the "unsubscribe" link in any promotional email from Replay Digital Ltd or visit the e-mail preference . Please note that once we
receive your request, it may take an additional period of time for your
opt-out to become effective. Your unsubscribe or e-mail preference
change will be processed promptly, and in no event longer than ten
Opting Out of Cookie Tracking
You can set your web browser to warn you about attempts to place
cookies on your computer or limit the type of cookies you allow. Flash
cookies operate differently than browser cookies and cookie management
tools available in a web browser may not remove flash cookies. To learn
more about and manage flash cookies you can visit the Adobe website and make
changes at the Global
Privacy Settings Panel.
If you disable cookies, you may lose some of the features and
functionality of our Services because Replay Digital Ltd cookies are
necessary to track and enhance your game activities.
5. Children Policy
Policy Regarding Persons Under 18
Unless written otherwise, our games are intended for use by those 18 or
older for amusement purposes only. We allow players ages 13-17 to
create an account with the consent of a legal guardian who must read
and agree to our Terms & Conditions. Without derogating from the foregoing, Replay Digital Ltd does not knowingly collect personal information from children
under the age of 13. Children under the age of 13 should not use our
websites or games at any time. If Replay Digital Ltd learns that a person
under the age of 13 has provided it with personal information, Replay
Digital Ltd will take reasonable steps to delete such information as soon as
6. How we protect the information we store and share about you.
Security of Your Information
Replay Digital Ltd has made reasonable technical and organizational
measures designed to secure your information both online and offline
from accidental loss and from unauthorized access, use, alteration or
disclosure, and we are committed to the protection of customer
information. We will take reasonable steps to ensure that your data is
When you sign into your Replay Digital Ltd account or enter payment
information, we or our third-party payment processor use secure socket
layer technology ("SSL") to encrypt the transmission of that
information. While we take reasonable precautions against possible
security breaches of our Services and our customer databases and
records, no website or Internet transmission is completely secure, and
Replay Digital Ltd cannot guarantee that unauthorized access, hacking, data
loss, or other breaches will never occur and that third parties will
never be able to overcome those measures or use your personal
information for improper purposes.
Also please note that email and messaging systems are not considered
secure, so Replay Digital Ltd discourages you from sending Replay Digital Ltd
personal information through these media. We urge you to take steps to
keep your personal information safe (including your account password),
and to log out of your account after use. If you access our Services
through a social network and your social network account is hacked,
this may lead to unauthorized play of your Replay Digital Ltd games without
your permission. So, be careful to keep your Account Information secure.
Although we strive to protect your personal data, we cannot guarantee
the security of your data while it is being transmitted to our site;
any transmission is at your own risk. Once we have received your
information, we have procedures and security features in place to try
to prevent unauthorized access. If you have questions about the
security of our websites, please submit a ticket via the applicable
support channel of the game.
Safety, Security and Compliance with Law
Your information, and the contents of all of your online communications
in our Services and between You and Replay Digital Ltd may be accessed and
monitored as needed to provide our Service and may be disclosed:
- when we have a good faith belief that we have to disclose
the information in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements, or
legal process (for example, a court order, search warrant or subpoena);
- to satisfy any laws or regulations that apply;
- where we believe in our sole discretion that the Service is
being used in committing a crime, including to report such criminal
activity or to share information with other companies and organizations
for the purposes of fraud protection, credit risk reduction, and other
- when we have a good faith belief that there is an emergency
that poses a threat to the health and/or safety of you, another person
or the public generally; and
- to protect the rights or property of Replay Digital Ltd and
other applicable third parties, including to enforce our Terms of
International Operations and Transfers Out of the EEA
When you use Our Services, your data may be sent to the United States
and possibly other countries.
As part of our international operations, we may transfer data to our
Affiliates (which means subsidiaries, parent companies, joint ventures
and other corporate entities from time to time for our legitimate
We store information about players and visitors to our sites on servers
located in the United States, and we may also store this information on
servers and equipment in other countries. Personal data collected
within the European Economic Area (“EEA”) may be transferred to, and
stored at, a destination outside of the EEA.
The data we hold may also be processed by employees operating outside
of the EEA who work for us or one of our Affiliates or for one of our
vendors. This staff may be engaged in, among other things, (i) the
processing of transactions and your payment details and (ii) the
provision of support services. When we transfer your personal
information internationally we will take reasonable steps to ensure
that your personal information is treated securely, lawfully and in the
manner we describe here. Please note that laws vary from jurisdiction
to jurisdiction, and so the privacy laws applicable to the places where
your information is transferred to or stored, used or processed in, may
be different from the privacy laws applicable to the place where you
If you are a resident in a jurisdiction, where transfer of your
personal information to another jurisdiction requires your consent,
then you provide us your express and unambiguous consent to such
transfer for us to provide you with our services.
How Long We Keep Your Information
How long we retain your information depends on why we collected it and
how we use it. We will not retain your personal information for longer
than is necessary for our business purposes or for legal requirements.
For instance, we may retain some information for a few years after you
have closed your account with us if this is necessary to meet our legal
obligations or to exercise, defend or establish legal rights.
tell you and other players by placing a notice on ReplayPoker.com, or
by sending you a notice to the e-mail address we have on file for you
prior to the change becoming effective. We may supplement this process
by placing notices on game blogs, social network pages, and/or forums.
You should periodically check ReplayPoker.com
and this privacy page for updates.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to
your personal data.
If you wish to exercise any of the rights set out above, please contact us at
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
VeraSafe has been appointed as Replay Digital Ltd’s representative in the European Union
for data protection matters, pursuant to Article 27 of the General Data Protection
Regulation of the European Union. VeraSafe can be contacted in addition to
only on matters related to the processing of personal data. To make
such an inquiry, please contact VeraSafe using this contact form:
Alternatively, VeraSafe can be contacted at: VeraSafe United Kingdom Ltd. Suite 1, 3rd
Floor 11-12 James Square London SW1Y 4LB United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or
another relevant supervisory authority in your home jurisdiction. We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please
contact us in the first instance.
Replay Digital Ltd at: firstname.lastname@example.org or submit a ticket via the applicable support channel of
and addressed to: Replay Digital Ltd and by email to email@example.com.