Privacy Policy

Last Updated: June 10th, 2022

Introduction

Z4, LLC provides games and related services under the brand name HD Poker (“HD Poker” or “us” or “we”), including our social or “free-to-play” games and related services that are presented on social networking websites, such as www.Facebook.com (collectively, the “Services”).

Your privacy is very important to Z4. This Privacy Policy is designed to explain to you what information Z4 collects and how the information is used. By using the Services, you agree to the terms of this Privacy Policy as updated from time to time. We may update the terms of the Privacy Policy at any time for any reason and will provide you with thirty (30) days written notice of these changes either through email or through a notice provided by the Services. Your continued use of the Services after the update means that you agree to the changes to the Privacy Policy.

If you are located in California, please see our Privacy Notice for California Consumers appended to this Privacy Policy.

Information We Collect

To provide the best experience for our users and to comply with applicable regulations and laws, Z4 collects a variety of information relating to your use of the Services. We’ll collect some information from other companies, including social networks, if you access our games through your accounts with those companies or you choose to connect your accounts with companies to our Services. The types of information collected by Z4 are categorized into Personally Identifiable Information and Non-Personally Identifiable Information. Together, this information is referred to as “Collected Information.” When you create an account for the Services, Z4 collects the following Personally Identifiable Information:

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s terms of service and privacy policy.

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.

If you choose to purchase in-game currency or other in-game content, Z4’s third-party payment processors will collect the billing and financial information they need to process your order. This may include your email, your address, and other necessary financial information. Z4’s payment processors do not share your financial information like credit card numbers, but they may share non-financial information with Z4 related to your order, such as your name, billing address, and the items purchased.

When you use the Services on connected third-party platforms like Facebook, Apple iOS. Steam (Valve), or Google Android, these purchases are services by the respective platform and are subject to the individual third-party application’s terms of service and privacy policy.

When you use the Services on poker.hd.io, you are subject to HD Poker’s third-party processor. For details on how these purchases are served, go to: https://www.braintreepayments.com/legal

In addition, Z4 may automatically collect Non-Personally Identifiable Information, such as how you interact with the Services, your IP address, and the URL of a website that referred you to the Services, if applicable. As part of this effort, Z4 may temporarily store cookies on the device you use to access the Services. Z4 may also assign an anonymized identification number to your account that may be used for analyzing how you and other players interact with the Services, advertisements, and referring websites.

How we use the Collected Information

We will use the Collected Information to ensure compliance with applicable laws and regulations in the jurisdictions that we operate in.

From time to time, we may send emails to you to notify you of events, promotions, and other information we believe will be of interest to you. You may opt out of these emails by following the directions listed in the email, or by emailing your request to [email protected].

Information we share with third parties

Your Member name, chat contributions and forum posts will be visible to other users of the Services when you use the Services.

We do not sell or rent your Personally Identifiable Information to third parties. However, we may send Non-Personally Identifiable Information to third parties to enable advertisements to appear within the Services and to enable affiliate marketers to refer players to the Services. We may also share the anonymized identifier with select partners to analyze how players interact with the Services.

If you purchase goods or services related to the Services, we will share your Personally Identifiable Information with banks, credit card companies, or other payment processors as needed to complete your purchase. These third parties are ordinarily located in the USA.

We may also share Collected Information with law enforcement personnel, regulatory agencies, or other personnel to comply with subpoenas, search warrants, court orders, gaming regulations, or other laws or regulations that we believe require us to disclose the information. In addition, we may share Collected Information to preserve our rights or property, to preserve the rights or property of our affiliates, and to investigate or prevent the commission of a crime.

Your Personally Identifiable Information will be stored on encrypted servers and computers located in the USA where data protection and privacy regulations may differ from those in other parts of the world.

Policy towards minors

The Services are intended only to be used by persons eighteen (18) years of age or older. We never intend to collect information from minors (those persons under the age of 18). If we find out that we have inadvertently collected Personally Identifiable Information of a minor, we will delete the information from our systems.

Third Party Links

Our Services may contain links to websites operated and maintained by third parties over which we have absolutely no control. These third-party websites are not subject to this Privacy Policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third-party websites. The inclusion of third-party links in any of our Services in no way constitutes an endorsement of such websites’ content, actions or policies.

Cookies

Z4 uses cookies. Cookies collect information that includes the server your computer or device is logged onto, your browser type and how you gained entry to our Services. Therefore, when you access our Services, details are recorded about your visit, such as time and date and pages accessed. As stated above, this Non-Personally Identifiable Information is used in an anonymous form for statistical purposes and, as such, cannot be used to identify you individually. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other Personally Identifiable Information.

Check the “Help” menu of your browser for more information on how to change your cookie preferences. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your use of our Services and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions.

Requests for access and correction of Personally Identifiable Information

You are entitled to access and correct the Personally Identifiable Information we hold about you and to have any inaccuracies in the information corrected.

If you would like to access, update or correct any of the Personally Identifiable Information we hold about you, you may do so by contacting us using the Contact Details below and informing us that you wish to access or correct your Personally Identifiable Information.

There are some circumstances specified by law where we may refuse your request for access to and/or the correction of your Personally Identifiable Information. However, if one of these circumstances applies, we will provide you with a written explanation of the reasons for refusal, unless it would be unreasonable to provide that notice.

Once we receive your request for access or correction, we will endeavor to respond to your request within thirty (30) days after the request is made. We may also charge reasonable costs for responding to your request.

Complaints

If you have any concerns or a complaint about a breach of your privacy or the way we have handled your Personally Identifiable Information, please contact us using the Contact Details below and inform us of the nature of your complaint.

We will then investigate your complaint and endeavor to provide you with our response within thirty (30) days.

For Australian residents: If, after receiving our response you still consider that your privacy complaint remains unresolved, you may then, for example, refer your concern to the Office of the Australian Information Commissioner at www.oaic.gov.au.









Privacy Notice for California Consumers

EFFECTIVE DATE: January 1st 2021

Our Privacy Notice for California Consumers supplements the information contained in our Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“Consumers”, “You”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.

We do not sell Your Personal Information to anyone or share it with third parties for their own marketing purposes.


To opt out of any future instances where our current information processing methods might be designated by California law as selling Personal Information, email us at [email protected]  or visit the Do Not Sell or Share My Personal Information page to submit a request.


Personal Information does not include:

In the preceding twelve months, we have or may have disclosed the following categories of Personal Information for business purposes:

In particular, we may have collected, depending on the nature of the interaction with, or the Services provided by Z4, the following categories of Personal Information from our Consumers within the last twelve months:

Personal Information Category

Types of Personal Information

Identifiers

Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number.

Personal Information listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e))

Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.

Protected Information under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Internet or other similar network activity

Browsing history, search history, information on a Consumer's interaction with a website, application, or advertisement.

Geolocation data

Physical location or movements.

Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

Professional or employment-related information

Current or past job history or performance evaluations.

Non-public education information
(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Inferences drawn from other Personal Information.

Profiles reflecting Your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


Your Rights and Choices

The CCPA provides California Consumers with specific rights regarding their Personal Information. The following sections describe Your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to You about our collection and use of Your Personal Information over the past 12 months. Once we receive and confirm Your verifiable Consumer request, we will disclose to You:

If we disclosed Your Personal Information for a business purpose, we will identify the Personal Information categories that each recipient obtained.

Do Not Sell My Information; Opting Out

We do not sell Your Personal Information to anyone.

We do not sell Your Personal Information or share it with third parties for their own marketing purposes.

To opt out of any future instances where our current information processing methods might be designated by California law as selling Personal Information, email us at [email protected]  or visit the Do Not Sell or Share My Personal Information page to submit a request.


Deletion Request Rights

You have the right to request that we delete any of Your Personal Information that we collected from You and retained, subject to certain exceptions. You can make this request via the game by clicking Support then General Inquiry and making the request to delete Your Personal Information. Once we receive and confirm Your verifiable Consumer request, we will determine whether any legal exception applies.

We may deny Your deletion request if retaining the information is necessary for us or our service providers for a variety of reasons.

Exercising Your Access, Data Portability, and Deletion Rights

You may exercise the access, data portability, opt out, and deletion rights described above by submitting a verifiable request to us in one of the following ways:

Only You or a person registered with the California Secretary of State that You authorize to act on Your behalf may make a verifiable Consumer request related to Your Personal Information. You may also make a verifiable Consumer request on behalf of Your minor child.

You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. In order for us to assist You, we ask You to provide us with information so that we may reasonably verify that You are the person about whom we collected Personal Information or are an authorized representative of that person and describe Your request with enough detail for us to understand, evaluate, and respond to it.

To maintain the confidentiality of the Personal Information we may have collected, we cannot provide You with Personal Information if we cannot reasonably verify Your identity or authority to make the request and confirm the Personal Information relates to You or to the California Consumer who You represent.

To maintain the confidentiality of the Personal Information we may have collected, we will use only the Personal Information You provide within Your verifiable Consumer request to verify Your identity or Your authority to make the request.

All requests to delete Personal Information may be subject to our internal information retention policies and/or to any applicable legal requirements.

Response Timing and Format

We will both acknowledge receipt of Your initial request and respond to You with the results of our research into Your verifiable Consumer request within the timeframe allowances specified within the CCPA.

Any response we provide will only cover the 12-month period preceding the receipt of Your verifiable Consumer request and may state reasons as to why we cannot comply with it.

We will use a format to provide Your Personal Information that is readily useable and should allow You to transmit the information successfully to another entity.

Changes to Our Privacy Notice

Z4 reserves the right to amend this Privacy Notice for California Consumers at our discretion and at any time. When we make substantive changes to this Privacy Notice, we will post a summary at the top of the first page of this Notice and update the Notice effective date.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights.



Conclusion

We hope that you find this Privacy Policy useful and informative. If you have any questions about the Privacy Policy, please contact Z4 using the Contact Details immediately below:

Z4, LLC
323 Orville Wright Ct
Las Vegas NV 89119
[email protected]