Sachiko Privacy Policy

Sachiko Gaming Private Limited, 109/25 Hazra Road, Shop 1-A, Ground Floor, Kolkata, West Bengal, India. ("us", "we" or "Sachiko") is the operator of the website www.pokerstars.in (the "Site").

Sachiko is incorporated as a Company under the Companies Act, 2013 and provides various skill game based services to you in India as set out in the Sachiko End User Licence Agreement (“Agreement”).

You acknowledge that the trademark PokerStars (the “Brand”) is owned by Rational Intellectual Holdings Limited (“RIHL”).

We are committed to maintaining the confidentiality of the Personal Information (as defined below) 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 available on the Site 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 note that the Agreement takes precedence over any conflicting provision of this Privacy Policy. Unless otherwise defined herein, capitalised terms shall have the meaning given to them in the Agreement.

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 Site. 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 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 Agreement.

2. As part of the User Account opening process across the Site 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, postal address, contact number, e-mail address and password (together the “Personal Information”) as well as to certify that you are at least 18 years old. You are reminded that you can only use the Service if you are physically present in India. In compliance with our regulatory requirements in order for you to access and use the Service, 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 PC/Device (which may include but not be limited to your IP address, GPS Co-ordinates, 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 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 Device, all in accordance with the purposes set out in this Privacy Policy. We and our service providers may also use any or all of your Personal Information to verify your credentials from third parties including financial institutions, identification verification agencies and credit reference agencies for the purposes of us providing services to you. In addition, when you use the Service we also store and share certain Personal Information, including information about your activity on the Site 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 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 information for various purposes such as:
   • to process or confirm financial transactions on the Site,
   • 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).
   Your Personal 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 Information. By accepting this Privacy Policy, you hereby consent to your Personal 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 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.

3. 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 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 information.

4. We undertake substantial efforts to protect the confidentiality of your Personal Information and will not knowingly allow access to your Personal information to anyone other than to the User or as described in this Privacy Policy. Our systems will protect your data in line with IS/ISO/IEC 27001 on "Information Technology - Security Techniques - Information Security Management System - Requirements" standards or equivalent.   You should also do your part in protecting 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.

5. Legally Required Disclosures: due to the legal, regulatory and security environment in which the We operate, We, as applicable, may be required, under certain circumstances, to disclose your Personal Information to third parties and they may not be permitted to inform you that they have done so. The, as applicable, will use its reasonable endeavours 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.
   Further, we can, and you hereby give your authorisation to, disclose your Personal Information, including, name, date of birth, age, street address, city, state, post code, country, phone number, e-mail, geo-location data, details of your payment transactions on the Site, 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 them to legal liability.

6. In addition to Legally Required Disclosures, we may disclose your Personal Information to Stars Interactive Asia (Malta) Limited and its group companies, and to our employees, agents and to third party service providers, who use your Personal Information to provide services to us in respect of you being a User of the Services. All recipients of your Personal Information shall be bound by applicable data protection laws to keep your Personal Information confidential and safeguard it at no less a level than that by which we are bound and will treat them in accordance with this Privacy Policy and your marketing preferences.

7. If requested by you at initial registration or by checking your marketing preferences in the ‘My Account’ section of the Site, 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 Site 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 partners who have received your contact details from us prior to your request to be removed from these lists.

8. 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 altered or corrected in accordance with your rights under applicable legislation and in this event we may require evidence of your identity. In order to contact us regarding your information please e-mail Support. We may in certain circumstances levy a small charge to cover the cost of administration regarding any request made by you in this regard if the information is given to you in writing. Please note that if we close or 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.

9. Cookies are text-only strings of information that are downloaded to 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 recognises 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 websites, to remember your preferences, and to generate anonymised statistical data, which we use to improve the user experience on our websites. 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 a website, 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 Site. 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.

10. Sachiko Gaming Private Limited
    109/25 Hazra Road
    Shop 1-A, Ground Floor
    Kolkata
    West Bengal
    India Sachiko can be contacted via Support.

In force from April, 2018.