PokerBoss

PRIVACY POLICY — POKERBOSS

Last updated: 14.02.2026

Operated by: Zaptech Media Limited (“Zaptech”, “PokerBoss”, “Platform”, “We”, “Us”, or “Our”)

Capitalised words used in this Policy but not defined shall have the meaning assigned to them in the Terms of Use (“Terms”).

Introduction and scope
1. This Privacy Policy (“Policy”) explains how Zaptech collects, uses, discloses, transfers, stores and protects your Personal Information when You access or use the PokerBoss mobile applications, APIs, websites, Games, or related services (collectively, the “Platform” or “Services”). The Policy does not apply to any other data collection, storage or processing, including without limitation, data collection conducted offline, or through Our products or services not linked directly with this Policy, or any data collection by third-party websites or applications that may be accessible through the links on the Platform.
2. This Policy applies to all Users of the Platform worldwide. Where relevant national or regional law of a jurisdiction imposes additional privacy or data protection requirements, PokerBoss will comply with such requirements and apply the relevant legal standard to Users located within those jurisdictions, in addition to the provisions set out in this Policy.
3. We may update or modify this Policy periodically. Unless stated otherwise, any revisions will take effect immediately upon being posted on the Platform. Please review the Policy regularly to stay informed of any updates. Your continued access or use of the Platform after such changes will constitute Your deemed acceptance of the revised Policy.
4. By registering for an Account, downloading or using the Platform, You acknowledge that You have read and understood this Privacy Policy and consent to the processing of Your Personal Information as described herein. If You do not agree with this Policy, please do not use the Platform.
5. The Services are not intended for any individuals under the age of 16 years (or of a higher age as applicable in Your country of residence). If not, please do not access our Platform, use any of our Services, create an Account or submit any personal information to the Platform (such as your name, address or email address). We do not knowingly collect any Personal Information from anyone under the minimum age for the concerned jurisdiction. In case We become aware that a person under the requisite age has provided Personal Information, we will promptly take appropriate steps to remove such information and terminate such Account. If You become aware that any Personal Information of an underage individual is provided, please contact Our support team immediately.
6. This Policy does not apply to mobile applications or websites which are not owned or controlled by Zaptech, including third party links and applications which You may interact with while using the Platform. Zaptech assumes no liability for any harm, loss, or damage incurred as a result of Your access to or use of such third-party websites or links or services advertised on the Platform. Your interaction with any third-party websites or apps or services is entirely at Your own risk. Zaptech shall not be a party to any transaction between You and a third-party service provider and bears no responsibility for any issue arising out of Your interaction with third-party websites, contents, products or services, apps, or links.
Key definitions
1. “Personal Information” or “personal data” means any information that identifies or can reasonably be used to identify an individual, directly or indirectly through such information alone or in combination with other available data. This includes but is not limited to aspects such as a person’s name, email address, username, date of birth, device identifier, internet protocol (“IP”) address, approximate location.
2. “Processing” means any operation performed on digital Personal Information, including collection, recording, organization, structuring, storage, adaptation, retrieval, alignment or combination, indexing, retention, use, sharing, disclosure, transfer, restriction, erasure or destruction.
3. “Grievance Officer / Data Protection Officer” refers to the individual designated by Zaptech to address User grievances, privacy-related queries, data protection and other requests, including exercise of rights, as outlined in Clause 15 of this Policy.
Categories of information we collect
We collect Personal Information you provide to Us directly, as well as certain data which is collected automatically when you access or use the Platform.
1. Information you provide directly
  1. Account & Identifiers: Includes, but is not limited to aspects such as Your username, display name, email address, date of birth, jurisdiction and any profile information you choose to enter.
  2. Third-party sign-in data: When you register or login using Google, Apple, Facebook or other single sign-on (SSO) providers, we may receive Your limited public profile information from such third-party service provider (e.g., name and email) subject to the authorization given by You to such service provider. We do not control the data collected by such third-party service providers and recommend You review their respective privacy policies prior to registering through this mode.
  3. Customer Verification information (where required): In cases where We or Applicable Law require identity or age verification, We may request documents for proof of identity, date of birth, proof of address, tax identifiers and similar documents. Note: PokerBoss is primarily a social gaming application purely for the purposes of entertainment; Customer verification will only be requested where legitimately required (e.g., regional legal or regulatory requirements or to investigate misuse).
  4. Transaction records: We maintain records of In-app purchases including purchase receipts, product identifiers, purchase timestamps and virtual currency balances. We do not collect or retain any payment method details or any sensitive payment information of Users. Payments towards any In-app purchase is processed via third-party app stores such as Apple/Google Play Store, which are processed directly by such third-party platforms according to their respective privacy policies. Please note that We are not responsible for such third-party platforms’ data handling practices and therefore recommend reviewing their respective privacy policies for more information.
    All Virtual Chips/ Items so purchased are intended solely for use on the Platform, strictly for entertainment purposes, and hold no real-world/monetary value whatsoever.
  5. Communications: this includes customer support correspondence, chat messages exchanged through the Platform, User Content as well as any feedback, inquiries or and survey responses you provide.
2. Information collected automatically
  1. Device & technical data: device model, operating system and version, device identifiers (e.g., advertising ID, UUID), app version, device language, time zone, mobile carrier, hardware characteristics and other telemetry.
  2. Network identifiers and IP address: We may collect your device’s network identifiers, such as Internet Protocol (IP) address, connection type, Internet service provider (ISP), and other related technical identifiers automatically when You access or use the Platform. This information is used for purposes such as maintaining the security and integrity of the Platform, preventing fraud, diagnosing technical issues, and improving User experience.
  3. Location data: approximate location derived from IP address. Where required for specific features, and only with Your explicit consent, we may collect precise GPS or geolocation data. We will only collect GPS/Geolocation data where necessary (for example, for location-based club features, anti-collusion checks, restricting Users in jurisdictions where Platform Services may not be offered, compliance with Platform Policies, Applicable Laws) as per Platform Policies. You may disable geolocation permissions at any time in your device settings; however, doing so may limit certain Platform functionalities.
  4. Usage, gameplay and analytics events: Includes data such as session durations, screens visited, gameplay events (e.g., tables joined, hands played, wins/losses, in-app purchases, chat activity), crash logs, diagnostics and performance data. This information is used for service operation, product improvement and fraud detection and prevention.
  5. Device push token: We collect a unique device push token when You enable push notifications on your device. This token is required to deliver notifications. Please note that such notifications are optional and You have the option to opt-in or out of the same through your device settings at any time.
  6. Cookies, pixels and similar technologies: Our Platform website uses cookies, pixels, and similar tracking technologies to enable session management, analytics, and limited advertising personalization. You can manage or disable cookies through your browser settings; however, some features of the Platform may not function properly if cookies are disabled.
3. Information from Third Parties: We may receive information about you from third parties (e.g., fraud prevention providers, identity verification vendors, app stores, or advertising partners). We will use that information only for the purposes described in this Policy and subject to appropriate contractual safeguards.
4. Aggregated or De-identified Data: We may collect or generate aggregated, anonymised or de-identified information that does not personally identify any user. Such data may be used for statistical, analytical, or research purposes to improve the Platform and understand usage trends.
5. Third-Party Tools and Software Development Kits (SDKs): The Platform may integrate certain third-party SDKs necessary to provide core services, including but not limited to Google Analytics, Firebase (including generated device tokens for guest Accounts), Firebase Cloud Messaging, Google/Apple/Facebook SDKs. Data collected by these third party tools is governed by their respective privacy policies and Zaptech is not responsible for their data handling practices.
Purposes of processing and lawful bases
We process Your Personal Information for the following purposes. The legal basis for processing such data may vary depending on Applicable Law (such as the General Data Protection Regulation (GDPR), the UK GDPR and other data protection laws relevant to the jurisdictions where the Platform may offer its Services) and the context in which we collect or use Your Personal Information.
1. Primary purposes
  1. To create, authenticate, manage Your account and account records; to address and respond to Your enquiries, requests or complaints; and to provide customer support; (Lawful basis: performance of Our contract with You / legitimate interests).
  2. To provide and improve our Services, including game play, match-making, and Club/League features and personalised content or recommendations; (necessity for performance of Our contracts).
  3. to provide You with the ability to reach out to, connect with, or interact with friends, family, or other Users on the Platform, where such features exist.
    (Performance of contract / legitimate interests).
  4. To process and record In-app purchases and transaction history and payment-related information as identified under Clause 3.1(d); (for performance of Our contract with You / legitimate interests).
  5. To keep the Platform safe and fair, including through measures for fraud prevention, anti-cheating, anti-collusion, security, and enforcement of Platform rules (including analysis of device identifiers, IPs, GPS to detect collusion, chip-dumping, multi-accounting, etc.); (for performance of Our contract with You / legitimate interests).
  6. To verify the accuracy of the information You provide (including identity verification and Customer verification, where required), and to comply with all Our legal obligations (including without limitation, tax or anti-money laundering obligations), Applicable Laws, regulatory requirements, court/tribunal orders, audits; and to respond to lawful requests from authorised enforcement or regulatory authorities. (Legal compliance).
  7. to send You transactional communications, service messages, security alerts, notices about updates to the Platform software, Services or Platform Policies, and enforcement-related notifications. (Performance of contract / legitimate interests).
  8. To analyse usage and improve performance: Analytics, product improvement, performance monitoring and troubleshooting (including crash reporting such as Firebase Crashlytics), market research, traffic analysis, and popularity measurement; (legitimate interests).
  9. For marketing and promotions and personalized offers, where you have consented (you can withdraw your consent or opt-out anytime); (consent / legitimate interests where permitted).
  10. To handle disputes, enforce the Terms of Use and other Platform Policies, protect or enforce our legal rights and claims, prevent or address any harm or attempt thereof to the rights, property or safety of the Platform, its Users or the public, as required or permitted by Applicable Laws; (legal compliance / legitimate interests).
Analytics, SDKs and automated processing
1. We use trusted third-party analytics, cloud and messaging providers (for example Google Firebase Analytics, Firebase Cloud Messaging, Firebase Remote Config and Crashlytics, and similar services). These vendors collect device and usage data and may set identifiers (including advertising IDs) to support analytics and messaging among other features. The information collected by such third-party service providers is handled according to their own privacy policies. The Platform ensures appropriate contractual and data protection safeguards are in place with such third-party service providers.
2. We use automated systems and algorithms to help maintain a fair and safe environment for Our Users. This includes systems and algorithms to detect any Prohibited Conduct including cheating, collusion, fraud, bots and Account/Platform abuse/misuse through analysis of Account activity, device data, or location information where necessary. Such processing is necessary to protect the Platform and other Users. Automated decisions may result in temporary suspensions or requests for manual verification; you may request human review where permitted/mandated by Applicable Laws. You acknowledge and agree that such temporary actions may be taken automatically to maintain Platform security and fair play.
Cookies and website tracking
1. Where you visit Our website, We or Our service providers may use cookies, local storage, web beacons and similar technologies for session management, analytics, fraud prevention, improvement of overall Platform performance and (where permitted) advertising personalization. You can manage or disable cookies through Your browser or device settings. Please note that if You choose to block cookies, certain Platform website features or Services may have limited functionality.
2. Our Platform website may include links or embedded content from third-party providers (such as analytics services or social media plugins). These third parties may collect information about your interactions with their content independently of the Platform. We request you to review their respective privacy policies for details on how they handle your information. You acknowledge and agree that the Platform is not liable for any third-party service provider’s collection and handling of Your Personal Information.
Sharing and disclosure
We do not trade, sell or make your Personal Information available for rent. We share data only as described below where necessary to operate the Platform, comply with legal requirements and obligations, and provide the Services. Such sharing and disclosure are subject to appropriate contractual and legal safeguards:
1. With service providers and processors such as payment processors, cloud hosting providers, identity verification vendors, analytics and fraud detection vendors, notification gateways and support platforms. Any such sharing is undertaken with third-party service providers pursuant to them being bound by appropriate contractual, technical, and organizational safeguards to ensure the confidentiality, integrity, and security of Your Personal Information, in accordance with Applicable Laws.
2. With affiliates and corporate groups: where necessary for operations, support and improvement, with appropriate safeguards in place.
3. With legal and regulatory authorities: to the extent required to comply with Applicable Laws, respond to lawful requests, subpoenas or court orders, or to enforce our Terms of Use and maintain Platform integrity.
4. Business transfers: in the event of sale, merger, restructuring or asset transfer, we may transfer Personal Information subject to suitable protections and notice to users.
5. With your consent: where you expressly authorize disclosure (for example social sharing).
International transfers and storage
1. PokerBoss is a global service. Personal Information may be stored and processed in any country where Zaptech or its service providers maintain facilities, subject to Applicable Laws. We will ensure that if any personal data is transferred to other countries, the same is transferred in accordance with applicable data protection laws and this Policy, and that suitable contractual, organizational, or technical safeguards are in place to protect such information.
2. By using the Platform and Services thereof, you consent to the processing and transfer of your Personal Information outside your country of residence as described in this Policy.
3. If your local law imposes stricter data localization requirements, the Platform will comply to the extent feasible and may inform You if local storage or processing is required.
Retention and deletion
1. We retain Personal Information only for as long as necessary to provide the Services, fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, prevent fraud, enforce our agreements or for defending against legal claims. Where Applicable Laws require longer retention, we retain Personal Information only for the duration mandated by such Laws and limited to the extent mandated by such Laws.
2. Deletion and Anonymization: When data is no longer required, we securely delete or anonymize Personal Information in accordance with Applicable Laws and industry best practices. If you request account deletion, we will delete your Personal Information subject to any retention obligations as indicated in this Policy (for example preservation of transaction records for tax or AML compliance). Deletion requests may be processed after completion of any outstanding investigations, disputes or chargebacks, if any.
Your rights and choices
1. At PokerBoss, we value transparency and empower you with the ability to manage your account information effectively. While certain data is retained to comply with legal, regulatory, or operational requirements only as long as required under Applicable Laws, we provide you with options to update, correct, or request deletion of specific details associated with your account. You may also request access to a copy of your Personal Information or limit the use and disclosure of your sensitive Personal Information if the Applicable Laws permit the same. You may also withdraw the consent granted to the Platform with respect to processing of Your Personal Information.
2. Upon a request to correct, update, delete or exercise any rights associated with Your Personal Information, We will make reasonable efforts to respond promptly to such requests in accordance with Applicable Laws. You can reach out to Us through the Grievance Officer as mentioned under Clause 15 of this Policy.
Security measures
1. We implement reasonable administrative, technical and organizational measures designed to protect Personal Information against unauthorized access, loss, misuse, alteration or disclosure. These measures include, but are not limited to, encryption of data both in transit and at rest, access controls, activity logging, and regular security assessments and audits, data backup, disaster recovery protocols, amongst others, to ensure the continued integrity and security of our systems.
2. While we strive to maintain strong security, no system or method of electronic data storage is impenetrable. We cannot guarantee absolute security of your information. If a data breach of your Personal Information occurs, We will promptly notify You and concerned regulators as required by Applicable Law.
Age limits
The Platform is only intended for persons who are at least sixteen (16) years of age (or of a higher age as applicable in their respective jurisdiction). We do not knowingly collect Personal Information from individuals below the permitted age or allow underage persons to register on the Platform and/or access gameplay features. We may request valid identification proof to verify age and eligibility at any time. Personal Information of Users aged 16 years and above but below the legal age of consent in the concerned jurisdiction would be processed in accordance with applicable data protection laws of such jurisdiction and parental consent may be sought, if necessary, in such jurisdiction. If we learn that a person under the requisite age has provided Personal Information, we will take prompt steps to delete the information and terminate the associated account. Parents or guardians who become aware of such a situation should contact Us immediately at playerrelations@pokerboss.com.

For individuals below the applicable age of consent in their respective jurisdiction, the definition of ‘User’ for purposes of this Clause extends to their parents/guardians/any individual legally permitted to act on their behalf. Users, therein, for the purposes of this clause can exercise the rights mentioned in Clause 10 of this Privacy Policy.
Automated profiling and decision-making
We use automated tools to analyse gameplay and behavioural data for fraud detection, anti-cheating measures and personalized offers. Some automated decisions may affect account status (temporary hold or request for verification). Where local law grants you rights regarding automated decision-making, you may request human review by contacting Us.
Push notifications and communications
PokerBoss may send you push notifications, in-app alerts, or emails to share important information about your Account, gameplay, events, and updates. These may include service messages, game invitations, club broadcast messages and notifications scheduled by club admins and/or managers, promotional content, or transactional and security notices. You can control marketing or promotional messages through your account settings, device permissions, or by following the instructions to unsubscribe to Our emails. Please note that opting out of marketing communications will not affect receipt of essential messages such as account confirmations, security alerts, or service-related notifications.
Grievance officer - contact details
If you have any concerns regarding this Policy, the processing or protection of your Personal Information, have any privacy-related questions or feedback, want to exercise your privacy rights, or wish to make a complaint, please contact:
Data Protection / Grievance Officer
Zaptech Media Limited (PokerBoss)
Email: privacy@pokerboss.com / grievanceofficer@pokerboss.com
Address: Zaptech Media Limited, 3 Warren Yard Wolverton Mill Milton Keynes England MK12 5NW
We aim to acknowledge and respond to requests within applicable statutory timeframes (commonly 30 days; may vary by jurisdiction in accordance with Applicable Laws).
Third-party links and feeds
Our Platform may contain links to third-party websites, services, or embedded content. We are not responsible for the privacy practices of any such third parties. Please review the respective privacy policies of such third-party websites before providing any personal data to them. You hereby acknowledge and agree that the Platform bears no responsibility for the handling of Your Personal Information by any third-party links and feeds accessed by You.
Changes to this Policy
We may update or modify this Privacy Policy from time to time to reflect changes in legal, operational, or technological requirements. In case of material changes, we will:
1. Notify users via the Platform, in-app notifications, or by email (if applicable);
2. Update the “Last Updated” date at the top of this Policy.
Your continued use of our Services after any modification constitutes your deemed consent to the updated Privacy Policy. If you do not agree with any change, you should immediately discontinue use of the Services and may request account closure.
Consent and Acceptance
1. By using the Platform and accepting this Privacy Policy, you expressly consent to:
  1. The collection, use, storage, sharing, and processing of your Personal Information as outlined herein;
  2. The terms governing data storage (including across jurisdictions), retention, security, and disclosure;
  3. The communication of service updates, transaction alerts, promotional information, and support messages.
  If you do not agree with any part of this Privacy Policy, please do not access or use our Services.
2. Withdrawal of consent:
  You may withdraw your consent to the collection or processing of your personal data at any time by sending a request to Us at playerrelations@pokerboss.com .
  
  Where processing of your personal data is based on your consent, you may withdraw your consent at any time. This does not impact past processing or processing carried out under any other lawful basis permitted under Applicable Laws.
  
  Upon receipt of your withdrawal request, we shall acknowledge and process your request within a reasonable time and cease processing your personal data unless required to retain it under Applicable Laws and for purposes outlined in Clause 9 above. Once no longer required for such purposes, the data shall be securely deleted or anonymized in accordance with industry standards and Applicable Laws.
Miscellaneous
This Privacy Policy is supplemental to the Platform Policies governing the Platform (including the Terms) and does not create contractual rights beyond those contained in our Terms. Where there is conflict on a subject matter contained in this Policy with the Terms or any other Platform Policy, this Policy will prevail to the extent of such conflict/inconsistency. Where there is a conflict between any provision in this Policy with the Applicable Law, the Applicable Law will supersede this Policy to the extent of such inconsistency.