Privacy Policy

Welcome to Suprema Poker!

Please read these Privacy Policy and the Documents very carefully as they form a binding legal agreement between you, an online poker Player (“Player”), and us, managed by Suprema Promoção de Eventos LTDA, a limited liability company established in São Paulo, Brazil, registered at the National Corporate Taxpayers Registry under Registration number 37.684.385/0001-63.

This Privacy Policy applies to all visitors, users, and others who access the Service (“Users” or “you” or “your”). This Privacy Policy describes how we collect, store, use, disclose, and otherwise process your personal information when providing these Services to you, and your rights and choices concerning your information. For avoidance of doubt, the capitalised terms used in these Rules are defined in the Terms of Service (“Terms of Service”).

By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play our games or use our Services. We may amend the Privacy Policy from time to time, and we encourage you to read the Privacy Policy regularly for changes.

1.DEFINITIONS

“Account” means an account you create when you access the App.

“Community Rules” means the rules of conduct that govern your interaction with our Services and other Players.

“Content” means any information, text, graphics, photos or other materials uploaded and/or downloaded through our App.

“Feature Terms” means any other rules related to specific services, like platforms and APIs, applications for mobile
devices, forums, contests, subscriptions or loyalty programs that we may publish.

“Game” means online poker play through Suprema Poker App.

“Offers” means special programs, including offers, excursions, and special gifts, both digital and tactile, that Suprema Poker may offer from time to time to certain eligible Players.

“Player” means any natural person possessing full civil capacity, of legal age, who agrees with all the provisions of this T&C and the Documents.

“Services” means our Game, Services, Content, SMS, APIs, email notifications, applications, buttons, widgets, ads, commerce services, domains or websites, including but not limited to supremapoker.net, https://supremapoker.com.br and other covered services that are bound to this T&C and Documents.

“Suprema Poker” means the name of the application of poker online managed by Suprema Promoção de Eventos LTDA, registered at the National Corporate Taxpayers Registry under Registration number 37.684.385/0001-63.

“User Content” means all the data that you upload, transmit, create, or generate on or through the App. This includes things like your profile picture, your in-game text or video chat, and your in-game art or other content authored or designed by you.

“Virtual Item” means either a virtual currency to be used in the Services, or a virtual in-game item.

“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 Suprema Poker’s Service, tailoring recommendations to interests, and making the Service easier to use.

2.INFORMATION WE COLLECT

2.1.We collect the following types of information.

(a) Information you provide us directly from the Services whether submitted by you or others;

(b) Your username, password and e-mail address when you register for a Suprema Poker account;

© Profile information that you provide for your user profile (e.g., first and last name, picture, phone number, gender, age or birthday, profile photo, game username, approximate physical location information, links to your profiles on various social networks etc). This information allows us to help you or others be “found” on Suprema Poker;

(d) User Content (e.g., all the data that you upload, transmit, create, or generate on or through the Services. This includes things like your profile picture, your in-game text or video chat, and your in-game art or other content authored or designed by you);

(e) Communications between you and Suprema Poker. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails;

(f) Confirmation of identity: Photo of personal document with photo, within validity and in good condition; selfie; copy of proof of address;

(g) Digital Identity Data: Source IP address and logical port, device (operating system version), geolocation, timestamps of each action you take, which screens you accessed, session ID and cookies.

2.2.In some circumstances it may be necessary for us to collect information from a third-party source. If you play Suprema Poker’s games or connect our Services to any third-party applications, including social networks like Facebook and Instagram, Suprema Poker 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, Suprema Poker may collect and store some or all of the following information shared by the provider of the connected third-party application:

(a) your profile picture or its URL;

(b) your user ID number (like your Facebook ID number and Instagram), which may be linked to publicly-available information like your name and profile photo;

© the user ID number and other public data of your friends;

(d) the login e-mail you provided to that third-party application when you registered with it;

(e) your gender;

(f) your birthday;

(g) whether you like our Facebook page and Instagram; and

(h) any other information that you or the provider of the third-party application share with Suprema Poker.
If you access 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.

2.3.Payment Information

(a) Suprema Poker may obtain the billing and payment information that you provide when your purchase is processed by our payment partners. Our Terms of Service explain our policies and terms relevant to our charges, billing practices and Virtual Items.

(b) If you purchase Virtual Items in a Suprema Poker 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.

© Suprema Poker does not collect or store your financial information, like credit card numbers. However, Suprema Poker’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.

2.4.Cookies and Automated Information Collection

(a) Suprema Poker and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as “cookies” to collect information.

(b) 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 use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

(d) We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

(e) 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 times.

(f) We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:

(i) the type of device you are using;

(ii) your operating system version;

(iii) your location;

(iv) your IP Address;

(v) your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);

(vi) your browser types;

(vii) your browser language;

(viii) referring and exit pages, and URLs;

(ix) platform type;

(x) the number of clicks on a page or feature;

(xi) domain names;

(xii) landing pages;

(xiii) pages viewed and the order of those pages;

(xiv) the amount of time spent on particular pages; and

(xv) game state and the date and time of activity on our websites or games.
In some cases, we will connect this information with your social network ID or Suprema Poker user ID.

2.5.Log file information

(a) Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

(b) When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

2.6.Device identifiers

(a) When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Suprema Poker.

(b) A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

2.7.Metadata

Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

3.HOW WE USE YOUR INFORMATION

3.1.We use your information under several legal basis, including to establish and perform our contract with you, for our legitimate interests, to comply with our legal obligations, to establish, use and protect Suprema Poker’s rights, or otherwise with your consent.

3.2.The main use of the information we collect and store is to provide our Services and to improve your gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

(a) to operate, improve and optimize our Services and our users’ experiences;

(b) to create your game accounts and allow you to play our games;

© to identify and suggest connections with other Suprema Poker players and personalize our Services to you;

(d) to communicate with you about the Services you’re using, including in-game updates, new Services, and promotional offers that we think might be of interest to you;

(e) to enable users to communicate with each other;

(f) to provide technical support and respond to users’ inquiries;

(g) to protect the safety and well-being of our users;

(h) to protect Suprema Poker’s rights and property in connection with our Services;

(i) to prevent fraud or potentially illegal activities, and to enforce our Terms of Service, rules available on the website https://supremapoker.com.br/jogo-limpo/, https://supremapoker.com.br/# and https://supremapoker.com.br/jackpot/;

(j) to manage and deliver contextual and behavioral advertising;

(k) to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;

(l) to comply with our legal obligations, resolve any disputes we may have with you or other users, and to enforce our agreements with third parties; and/or

(m) to conduct research.

3.3.One important use of your information is communication. If you have provided your e-mail address to Suprema Poker, 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 Suprema Poker having certain contact information from you.

4.SHARING OF YOUR INFORMATION

4.1.We may disclose or publish aggregated information (information about you and other players collectively that is not intended to specifically identify you and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

4.2.Parties with whom we may share your information:

(a) We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Suprema Poker is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences);

(b) We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”), including but not limited to 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. Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms. We contractually require these Service Providers to maintain the confidentiality of the information we share with them, and we contractually require them not to use your information for anything other than to provide services on our behalf;

© We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you;

(d) We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information;

(e) Any other users 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.

4.3.Parties with whom you may choose to share your User Content

(a) Any information or content that you voluntarily disclose to us, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set;

(b) If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Suprema Poker API have copied or saved that information.

4.4.What happens in the event of a change of control

In the event that Suprema Poker 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 of the business transition before transferring your personal information.

4.5.Responding to legal requests and preventing harm

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

5.HOW WE STORE YOUR INFORMATION

5.1.Your information collected through the Service may be stored and processed in any country in which Suprema Poker, Suprema Poker Affiliates or Service Providers maintain facilities.

5.2.Suprema Poker, its Affiliates, or Service Providers, to the extent permissible by the applicable law, may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or Brazil or other regions with laws governing data collection and use that may differ from Hong Kong law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

5.3.By registering for and using the Service you consent to the transfer of information to any country in which Suprema Poker, Suprema Poker Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

5.4.We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Suprema Poker cannot ensure the security of any information you transmit to Suprema Poker or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

5.5.You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Suprema Poker, at all times. Your privacy settings may also be affected by changes the social media services you connect to Suprema Poker make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization. While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.

6.YOUR CHOICES ABOUT YOUR INFORMATION

6.1.Your account information and profile/privacy settings

(a) Update your account at any time by logging in and changing your profile settings.

(b) By clicking on the Unbind Email Button, we will not send further email communications.

6.2.Managing your information with us

If you want to review, delete, or change the information Suprema Poker has about you or have additional questions, you may send an e-mail to privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil.

6.3.Stopping Use of Your Information

If you no longer want Suprema Poker to make active use of your information, you may send an e-mail to privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil. 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 it.

6.4.Managing your information with third-party applications

You will need to follow the instructions from the third-party application for updating your information and changing your privacy settings. Once Suprema Poker receives your information from a third-party application or your mobile device, that information is stored and used by Suprema Poker in accordance with this Privacy Policy.

6.5.How long we keep your User Content:
We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. Following termination or deactivation of your account, Suprema Poker, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, audit and/or legal purposes.

7. YOUR RIGHTS

We would like to make sure you are aware of all of your privacy rights. If you would like to obtain further information or exercise any of the following rights, contact Calian’s Privacy Officer at privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil.

·The right to access – You have the right to request that Suprema Poker provide copies of your personal information. We may charge you a small fee for this service.

·The right to rectification – You have the right to request that Suprema Poker correct any of your personal information you believe is inaccurate or incomplete.

·The right to erasure – You have the right to request that Suprema Poker erase your personal information, under certain conditions.

·The right to restrict processing – You have the right to request that Suprema Poker restrict the processing of your personal information, under certain conditions.

·The right to object to processing – You have the right to object to Suprema Poker’s processing of your personal information, under certain conditions.

·The right to data portability – You have the right to request that Suprema Poker transfer the data that we have collected to another organization, or directly to you, under certain conditions.

7.1. HOW TO CONTACT US

If you would like to exercise any of these rights, please contact us at privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil

8. HOW TO DELETE YOUR CURRENT ACCOUNT

If you want to delete your Suprema Poker account, simply follow these instructions:

a) Access your Profile in the App;

b) Choose the option “Delete Account”;

c) Enter your Player ID;

d) Read the information carefully:
Your current account will be deleted and there is no way to get it back.
All the property will be lost, including but not limited to your game coins, transaction, ID, nickname and all the other information. You can never login with current account.

e) If you are sure, choose the option “I am sure”. If you do not want to delete your account, choose the option “Cancel”;

f) After choosing the “I am sure” option, enter your password and confirm it a second time.

g) If everything is correct, choose the option “Delete my account”.

h) You will be directed to Step 3 to final confirmation. Confirm the option “I totally understand what I am doing” and choose the option "Delete my accont”.

After following this steps, your current account Suprema Poker will be delete. But the Suprema Poker has a legal duty to store your data for a period of five years, to comply with its legal obligations, to defend its interests and to investigate any misconduct carried out on the app.
You could be choosing another option for deleting your current account. Just send an e-mail to security@suprema.group and request the deletion of your account.

You will need to enter your Player ID, the Poker Club ID you are affiliated with and wait for your account to be locked. The team will have 72 hours to respond to your request.

If you request the deletion of your account and you have a balance deposited in your digital account, Suprema Poker will arrange for your chips to be sent to your Poker Club and you must contact them to withdraw the deposited chips.

9. CHILDREN’S PRIVACY

We do not knowingly collect, use or share any personal information about children (generally, under the age of 16 or depending on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with personal information, you can contact us and request your child’s information to be deleted from our system.

10.OTHER WEB SITES AND SERVICES10

We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. Please remember that when you use a link to go from our Service to another application, website or service, our Privacy Policy does not apply to those third-party application, websites or services. Your browsing and interaction on any third-party application, website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party application, website or service, you should consult their privacy policy before providing any personal Information and if you allow them to access your User Content you do so at your own risk.

11.DATA PROTECTION

9.1.Suprema Poker has encrypted and stored players’ data, and will not process them.

9.2.We will not distribute any users’ data to third party organizations and will not use the data for any commercial purposes.

9.3.Suprema Poker 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 treated securely and in accordance with our Privacy Policy.

9.4.Also please note that email and messaging systems are not considered secure, so Suprema Poker discourages you from sending Suprema Poker 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.

12.HOW TO CONTACT US ABOUT A DECEASED USER

In the event of the death of an Suprema Poker User, please contact us, send an e-mail to privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.

13.HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us by sending email to you may send an e-mail to privacy@suprema.group if you are located outside of Brazil, and to encarregado@suprema.group if you are located in Brazil.

14.CHANGES TO OUR PRIVACY POLICY

Suprema Poker may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of Suprema Poker or the Service after any modification to this Privacy Policy will constitute your acceptance of such modification.