PRIVACY POLICY

We at Sachiko Gaming Private Limited (hereinafter referred to as "Sachiko Gaming," “we,” “us,” or “our”) are committed to protecting your Personal Data and Information and respecting your privacy, and strive to maintain the privacy of your Personal Data and Information.
This Privacy Policy applies to your use of PokerStars, including without limitation the https://www.pokerstars.in/ Website and the PokerStars mobile application (“Mobile App”) (collectively referred to as the “Services”), and outlines our practices in relation to the storage, use, processing, and disclosure of Personal Data and Information that you have chosen to share with us when you use our Services. This Privacy Policy sets out the basis on which the Personal Data and Information that we may collect from you, we collect about you, or that you provide to us will be processed by us, and describes our approach to the handling and usage of the same in compliance with the applicable laws and regulations.
Please note that unless specifically defined in this Privacy Policy, capitalized terms shall have the meaning ascribed to them in our Terms of Service (Terms). Please read this Privacy Policy in consonance with our Terms of Service. Please read the terms of this Privacy Policy carefully. By using all or a part of the PokerStars Services and continuing to use our products and Services, you agree are deemed to have accepted and consented to the collection, storage, use, and disclosure of your Personal Data and Information in accordance with the terms of this Privacy Policy.
We are committed to maintaining the confidentiality of the Personal Data and Information collected by us by safeguarding it utilizing best-in-class software and hardware architecture, techniques, methods and procedures which allow you to enjoy the Services in the knowledge that your privacy is safeguarded. We will comply with all applicable legal, regulatory or administrative requirements of any governmental authorities including but not limited to the terms of the Information Technology Act, 2000 and rules framed thereunder as amended, and the rules and regulations thereunder. Please read the following terms of the Privacy Policy carefully to understand our practices regarding your Personal Data and Information and how we will treat it.

Consent to Privacy Policy

• 1. By using the Services, you (“User” or “you”) agree to the terms of this Privacy Policy. We reserve the right to amend this Privacy Policy and changes will come into effect within 14 days of such change being published on the Services. Your continued use of the Service constitutes your agreement to this Privacy Policy and any amendments to the same thereinafter. The purpose of this Privacy Policy is to enable you to understand how we collect, store, use and safeguard your Personal Data and Information and for you to understand your rights in relation to that information. References to defined terms hereunder, if not specified, shall have the same meaning as set out in the Terms.




What Information Is Collected and for What Purpose




• 2. As part of the User Account opening process across the Services and to allow us to make the Services available to you, we will ask you to provide us with certain personal information, including but not limited to your name, date of birth, Permanent Account Number (PAN), postal address, contact number, email address and password (together “Personal Data and Information”) as well as to certify that you are at least 18 years old. You are reminded that you can only use the Services if you are physically present in India and are not located in any of the Restricted States. In compliance with our regulatory requirements in order for you to access and use the Services, you hereby consent and permit us, or third parties acting on our behalf, to: (i) use location-based services (LBS) to detect your geographic location from your personal computer/mobile phone/electronic device/mobile application (“Devices”), which may include but not be limited to your IP address, GPS Coordinates, cell tower data (such as cell ID and location area code), Wi-Fi connection (such as MAC address) and cookies data); and (ii) undertake the collection, storage, processing, retrieval and transmission of your Personal Data and Information (which will include but not be limited to your location data) and/or such other data or information that may be derived from your Devices, all in accordance with the purposes set out in this Privacy Policy. We and our third party service providers may also use any or all of your Personal Data and Information to verify your credentials through third parties, including financial institutions, identification verification agencies, and credit reference agencies, for the purposes of providing Services to you. In addition, when you use the Services, we also store and share certain Personal Data and Information, including information about your activity on the Services and information held on or derived from Devices that you use to allow us to enhance the Services that we provide to you as well as to ensure that you are not using any prohibited third party software or tools. We will take all reasonable efforts to ensure that information shared by us with third parties is protected in a manner that is consistent with this Privacy Policy. We, our Affiliates, and third parties providing services to us or on our behalf (whether in India or outside India) will use your Personal Data and Information for various purposes such as:

  
  

  • to process or confirm financial transactions on the Services;

  • to provide the Services to you;

  • identification, verification and vetting purposes;

  • statistical analysis and research;

  • research and development;

  • marketing, market research and customer profiling;

  • data analysis;

  • to comply with licensing and regulatory requirements;

  • to analyse your credit risk;

  • to combat against security risks;

  • for the purpose of disaster recovery;

  • to confirm your geographic location; and

  • to send you promotional communications (but we will ask you for your specific consent where applicable).




• 3. Your Personal Data and Information may be processed by us, our Affiliates, our agents and third parties providing services to us, in jurisdictions outside of India. In this event, we will comply with the terms of applicable legislation in force in relation to any such processing and/or transfers of your Personal Data and Information. By accepting this Privacy Policy, you hereby consent to your Personal Data and Information being shared, where necessary, outside of India. We will only use your name in publicity materials with your consent. The name you register with us must be your own name. In addition, it is very important that you complete the User Account registration process with valid information, since it will be used in the course of validating financial transactions and the other aforementioned purposes. You are required to advise us of any relevant changes to your Personal Data and Information. Users are able to change the information provided upon registration by accessing the dedicated User Account details section when they log in. Kindly note that requests for changes to your User Account details, such as changes to your name and permanent account number, would need to be accompanied by adequate government issued documentary proof in order to be effective.




• 4. In the course of making a deposit, you consent to providing us, or our duly appointed third party payment processors or our service providers, with the deposit method information and other relevant financial information (example: credit card number, debit card number and other payment instrument information). This information in conjunction with your other Personal Data and information might be used, either by us or by third party payment processors appointed by us or service providers to clear financial transactions executed by you. You are required to advise us of, and update on your User Account, any relevant changes to your Personal Data and information.




• 5. Consent to the Use of Other Personal Data and Information for Marketing and Promotions

  
  

  • We may use, share, or disclose your data and information including your personal, transaction, and behavioural data, and/or aggregated and/or anonymized data and information to provide you with marketing and promotional content of third parties, including that of our Affiliates. This includes sharing your Personal Data and Information with contracted third-party service providers and partners who assist us or the third parties (to whom we share, disclose your data and information) on our or their behalf to deliver marketing or promotional services, both on our platform (such as in-app messages, banners) and outside our platform (such as through SMS, email, WhatsApp, push notifications, or other digital channels). These Affiliates, third parties and partners will be contractually obligated to handle your Personal Data and Information in accordance with applicable data protection laws.

  • We may disclose or share your data and information, including your Persona Data and Information, transaction, and behavioural data, with one or more of our Affiliates including for the reasons to support platform operations, marketing, analytics, product improvement, fraud prevention, due diligence, and other business purposes, including developing or operating products and services similar or related to us. Our Affiliates will have the right to use and handle this Personal data and Information for these purposes, in compliance with applicable data protection laws, to ensure a seamless and consistent experience across our services.

  • In the event we undertake or subject to (either voluntary or under any legal process) a strategic transaction, sale (either of business or of assets), merger, acquisition, other change in control, your data and information, including your personal, transaction, and behavioural data, may be transferred to another affiliate or successor entity, in accordance with applicable data protection and data localization laws.

  • By using our services, you consent to our use of your name (full or partial), likeness, tournament wins, and other attributes, whether in an aggregated, anonymized, or identifiable form, for our marketing and promotional purposes. This may include, but is not limited to, showcasing user achievements, testimonials, and other promotional content in our advertisements, social media, leaderboards, and other communication channels.




• 6. We may use your Personal Data and Information for inter-platform gameplay.

Confidentiality

• 7. We undertake substantial efforts to protect the confidentiality of your Personal Data and Information and will not knowingly allow access to your Personal Data and Information to anyone other than to the User or as described in this Privacy Policy. You should also do your part to protect your information. Your Login Credentials are confidential and you are obliged to keep your Login Credentials secret and confidential at all times and to use your best efforts to protect their secrecy and confidentiality.

Limits of Confidentiality

• 8. Legally Required Disclosures: due to the legal, regulatory and security environment in which we operate, we, as applicable, may be required, under certain circumstances, to disclose your Personal Data and Information to third parties and they may not be permitted to inform you that they have done so. They, as applicable, will use its reasonable endeavors to limit such disclosure to the following:

  
  

  • where they believe in good faith that it is required to do so in response to a subpoena, warrant or other legal process;

  • where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce their rights.




• 9. Further, we can, and you hereby give your authorization to, disclose your Personal Data and Information, including your name, date of birth, age, street address, city, state, post code, country, phone number, email address, geo-location data, details of your payment transactions on the Services including the financial instruments used to deposit and withdraw funds, to third party advisors or official government bodies as they believe, in their sole discretion, necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose you to legal liability.

Who receives your information?

• 10. If requested by you at initial registration or by checking your marketing preferences in the “My Account” section on the Services, we may send you information by email, text message or post (as selected by you), or by any other electronic modes, or by any contact details you provide directly to us, about existing and new services, products, competitions and offers from us in accordance with this Privacy Policy. We may also share your email address and phone number with our marketing partners for the purpose of providing you with marketing offers in relation to our services. If you do not wish to receive any information about existing and new services, products, competitions, prizes and special offers from us, you can tell us not to contact you for marketing purposes at initial registration or by updating your marketing preferences in the my account section of the Services or by clicking on the “Unsubscribe” link in any marketing email that we send you. If you request to discontinue receiving marketing communications about our offers, we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you may need to unsubscribe separately from marketing offers sent by our partners who have received your contact details from us prior to your request to be removed from these lists.




Your rights in relation to your information




• 11. We aim to keep our information about you as accurate as possible. You can write to us at any time to review, change, obtain a copy of your information or have your details changed or corrected in accordance with your rights under applicable legislation, and in such an event we may require evidence of your identity. In order to contact us regarding your information, please email our customer support. We may in certain circumstances levy a small charge to cover the cost of administration related to any request made by you in this regard if the information is given to you in writing. Please note that if you request us to close your User Account for any reason, your personal details will be retained for such period as may be required under applicable anti-money laundering regulations or other regulatory requirements.

  
  

Cookies




• 12. Cookies are text-only strings of information that are downloaded onto your Device when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognizes those cookies. Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes cookies are used to help ensure that adverts you see online are relevant to you and your interests. We use cookies in order to track referrals to our Website/Services, to remember your preferences, and to generate anonymised statistical data, which we use to improve the user experience on our Services. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited our Website/Services, and to provide advertisements that are more relevant to your interests. We may use the data generated from cookies to compile statistical data on your use of our Services. You are not obliged to accept the cookie from us and you have the ability to accept or decline cookies by modifying the settings in your browser.

  
  



Telephonic Communications




• 13. We may record telephone conversations between you and our customer support representatives for purposes including quality assurance, employee training, dispute resolution, and service improvement. By contacting our support team via phone, you acknowledge and consent to such recordings, in accordance with applicable laws.

  
  



Privacy Measures for Minors




• 14. Our Services are meant only for persons aged 18 or above. If you are under 18 years of age, you are not permitted to use our Services. If you are a parent and/or guardian and believe that we may have inadvertently collected any Personal Data and Information from your child, you can notify us immediately by emailing at [email protected].

  
  



Limitation of Liability




• 15. Sachiko Gaming confirms that this Privacy Policy is only a description of its operation regarding user information. This Privacy Policy is not intended to create, and does not create, any legal rights in your favor or in favor of any other person or party. Sachiko Gaming reserves the right to change this Privacy Policy at any time without giving you prior notice. The liability of Sachiko Gaming shall be limited to the removal of Sensitive Personal Data from the system of the Services and the removal of personally identifiable elements of the other Personal Data and Information. Notwithstanding anything to the contrary contained in this Privacy Policy and elsewhere, the aggregate liability of Sachiko Gaming for all claims for damages pursuant to the provisions of the Services, including claims in respect to the violation of this Privacy Policy, shall be limited to the aggregate maximum amount of liability as provided in the Terms of Service. Your continued use of the Services constitutes your agreement to this Privacy Policy and any amendments thereof.

  
  



Request for Account Deactivation




• 16. A user can send us an email to request us to deactivate their PokerStars account. Once the account is deactivated, the user will not be able to access the account.

  
  



Grievance Officer




• 17. Sachiko Gaming currently appoints Mr. Jai Sharma as its Grievance Officer. All complaints related to your Personal Data and Information must be made to our Grievance Officer at [email protected].