WPT® Home Game – Privacy Policy

INTRODUCTION

Thank you for your interest in our mobile application ("App"). Your privacy is important to Grand Cru Concepts Ltd (operating as "WPT Home" and referred to as "WPT Home", "we", "us" and "our") and we respect the privacy of everyone who uses our App.

WPT Home is committed to protect the privacy of anyone who uses our App. This privacy policy ("Privacy Policy") sets out how WPT Home manages your personal data when you, for example, visit our App or send us an email. "Personal Data" means information about you which can be used, on its own or together with other information, to identify you as a person.

Important Notice Regarding Children. Protecting the privacy of children is especially important to WPT Home. If you believe we have any Personal Data from or about anyone under 18, please email us at support@wpthomegame.com.

WHAT INFORMATION WE COLLECT AND WHY

Information You Provide. We collect information that you voluntarily provide when you fill out forms on our App (like entry forms) or register for our Services. The main purpose we collect this information is to manage our relationship with you and to be able to provide you with the requested information and Services. WPT Home also keeps emails from you and records of correspondence with you for us to be able to contact you and to respond to a question from you. Some information that we may collect, such as geolocation information, etc. is necessary for us to comply with legal and regulatory requirements. Please note that you can always choose not to provide certain Personal Data. However, in such cases, you will not be able to benefit from certain aspects of the App's features.

Information collected automatically from your device. We and our third-party service providers may collect information automatically from your device in a variety of ways, including:

Through your browser or device. Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet type you are using. We use this information to ensure that our services function properly.
Through your use of the App. When you download and use one of our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our servers and the information and files that have been downloaded to the App.

Categories of Personal Data. The categories of Personal Data that we collect and process may include:

contact details, such as your first name, last name, email address;
demographic data and personal details such as your age range, username, and account login details;
geolocation information including your approximate location information provided by a mobile or other device or associated with your IP address, where we are permitted by law to process this information;
player tracking for events, player rankings, the number of titles players have won, how many times players win in a tournament, etc.

HOW WE USE YOUR PERSONAL DATA

We will process your Personal Data as described in this Privacy Policy when you contact us using the contact methods on https://support.wpthomegame.com. The information we collect and use helps us to operate our App and to provide you with our products and services. It also helps us to answer your questions, improve our customer service, process payments and to personalize your experience on our App. We also need to collect certain details to process payments and to satisfy applicable regulatory requirements, or to create and maintain user lists (with hashed non-personally identifiable information or similar information). The user lists are to ensure users are not sent advertisements from certain third parties and to allow the third parties to identify similar target audiences. In addition, we may contact you about our services, including sending your marketing materials. You may opt out of these communications, as provided below in Section 10.

The basis for which we process your information are indicated in the chart below.

Purpose	Legal basis
Provide our Services	Performance of our contract with you
Ensure security and protection of our App	Our legitimate interest to prevent fraud
Market and promote our Services or those of our key partners	Your consent when required or our legitimate interest when consent is not required
Process your requests to exercise your rights	Necessity to comply with our legal obligations

HOW WE SHARE YOUR PERSONAL DATA AND WITH WHOM

All Personal Data collected by WPT Home is treated as confidential. We disclose the entire or part of your data in the following limited circumstances. (Note that if we share your Personal Data with a third party, we will take reasonable steps to ensure your information is protected to the same standards that we protect our own and prohibit them from using your information for purposes other than those requested by us or required by law).

Compliance and legal obligations. We may also disclose personal data to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process.
WPT Home, subsidiaries, employees, and independent contractors. We will disclose Personal Data to our subsidiaries, employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf and also for administrative purposes, tax and all other purposes.
1. Vendors and service providers. We may disclose your Personal Data for technical maintenance or forums software, analytics providers, social networks, and our featured partners when you provide your Personal Data on our App to areas managed by said partners, or through cookies. (Please see our Cookies Policy) Further, we may also disclose non-personally identifiable information (e.g. hashed PIII) to third parties to create and maintain user lists (with hashed non-personally identifiable information or similar information). The user lists are to ensure users are not sent advertisements from certain third parties and to allow the third parties to identify similar target audiences.
2. Subsidiaries and affiliates. We may disclose personal data on a need-to-know basis to our subsidiaries, parent or affiliated companies to help us support our Services. These subsidiaries and affiliates will use the disclosed personal data only for the purpose mentioned in this Privacy Policy.
Business transfers. We may share information if all or part of WPT Home is sold, merged, dissolved, acquired, or in a similar transaction. We may also share certain personal data as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence, or as necessary to plan for the transfer.
To protect rights and property. We will share Personal Data with companies, organizations or individuals when we believe in good-faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our agreements; to investigate potential violations; to protect against harm to the rights, property or safety of WPT Home, our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your Personal Data to third parties as part of legal process.

WPT Home will not sell, rent, share, use your Personal Data for targeted advertising, or otherwise disclose or use your Personal Data in any way that is contrary to the commitments made in this Privacy Policy. We will take all reasonable steps to notify you when and what information might go to third parties and you will be able to choose whether to share it or not.

HOW LONG WE KEEP YOUR PERSONAL DATA

We will retain your Personal Data only for as long as is necessary to provide the Services (i.e. as long as your account is active) and otherwise for the purposes set out in this Privacy Policy.

Once your account is deleted, only the Personal Data relevant to comply with our legal obligations or defend our rights in the event of a claim or a dispute may be kept for 5 years after the closing of your account. After the data retention term defined above, your Personal Data is deleted or anonymized. WPT Home may keep anonymized derivatives of your data for business analytics purposes where no automated decision making is involved.

For more specific information about data retention terms or to request to have your data deleted, please contact us at support@wpthomegame.com.

HOW WE PROTECT YOUR PERSONAL DATA

WPT Home has appropriate technical and organizational safeguards to protect your Personal Data against accidental or unlawful destruction or loss, modifications, unauthorized use, disclosure or access, and all other unlawful forms of processing. However, we cannot guarantee that information you transmit will not be accessed, disclosed, altered or destroyed by breach of any of our safeguards or otherwise. We will of course follow applicable rules and processes for notifying you if this should happen.

CHANGES TO THIS PRIVACY POLICY

We will occasionally make changes to this Privacy Policy. If we do, we will inform you and also give you the opportunity to consent to any material changes. Changes will be effective upon the posting of the changes and your acceptance of the changes.

ABOUT WPT Home

WPT Home is owned and operated by Grand Cru Concepts, Ltd., which is a company incorporated in Cyprus with organization number HE 463724 and registered address at Arch. Marikiou III & Evagorou, 1-7, MITSI 3, 1st Floor, Flat/Office 102, 1065, Nicosia, Cyprus. Grand Cru Concepts, Ltd. is responsible for your Personal Data for the purposes of the applicable data protection law and is in charge of the data collected on the App.

HOW TO CONTACT US

If you have any questions, complaints or comments about this document or our use of Personal Data contact us by email at support@wpthomegame.com.

YOUR ADDITIONAL RIGHTS

Depending on where you live, you may have certain rights relating to the collection and use of your Personal Data based upon local data protection laws. Note that the exact scope of these rights may vary by jurisdiction. These rights include the right to:

Confirm whether we process your Personal Data;
Access the Personal Data we hold about you;
Know how we process your Personal Data;
Correct any inaccuracies in the Personal Data that we hold, taking into account the information's nature and processing purpose;
Delete your Personal Data (Note that this right is subject to certain exceptions. For example, we may need to retain your Personal Data to complete a transaction or other action you have requested. We may have a legal or regulatory obligation or other valid reason to continue to process it. If your deletion request is subject to one of these exceptions, we may deny your deletion request.);
Obtain a copy of the Personal Data that you provided;
Opt-out of Personal Data processing for:
- Targeted advertising,
- Sales, or
- Profiling in furtherance of decisions that produce legal or similarly significant effects;
Either limit (opt-out of) or require consent to process certain sensitive Personal Data;
Object to the processing of your Personal Data; and
Withdraw your consent at any time, should we process your Personal Data based upon consent (Note: if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of your Personal Data, if such use or disclosure is necessary to enable you to use some or all of our services);
File an appeal if you are not satisfied with our response to your request or file complaint with the relevant regulatory authority in your jurisdictions about our practices with respect to your Personal Data.

Marketing Communications. Regardless of where you live, you may consent or withdraw your consent to our use of your Personal Data for marketing at any time by following the instructions to unsubscribe included in each marketing-related email sent to you. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you administrative messages relevant to any specific services you may have signed up for. If you do not wish to receive marketing communications from us you may, subject to applicable law, refuse to give consent or opt out at any time by following the unsubscribe instructions contained within our emails, or by contacting us at support@wpthomegame.com.

Opt-Out of Online Behavioral Advertising. To opt out of the collection and processing of your Personal Data for advertising purposes, please see our Cookies Policy.

Jurisdiction Specific Rights. If you are a resident of California, Colorado, Oregon, Nevada, Texas, Utah, Virginia or Canada, please see the Jurisdiction Specific Policies in Appendix A of this Privacy Policy to learn more about your privacy rights under applicable law.

Exercising Your Rights. To exercise your rights, you or your authorized agent may contact us at support@wpthomegame.com.

10.5.1 We may need to verify your identity and place of residence before completing your rights request. We will only use Personal Data provided in a request to verify you and complete your request.

If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf.
Subject to legal and other permissible considerations, we will make reasonable efforts to honor your request promptly or inform you if we require further information to fulfill your request. We do our best to ensure that we respond to valid requests within one month unless otherwise required by law. We will not discriminate against you (e.g., through denying products and services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.
To appeal a decision regarding a consumer rights request please contact us at support@wpthomegame.com with the subject heading "Consumer Rights Request Appeal". The appeal will be escalated internally to address your questions or concerns.
We reserve the right to charge a fee, where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

APPENDIX A: Jurisdiction Specific Policies

California Residents. If you are a resident of California, you have specific rights regarding your Personal Data under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights* include:

Right to Know. The right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months.
Right to Delete. The right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions.
Right to Opt-Out. The right to opt-out of the "sale" and "sharing" of your Personal Data. NOTE: We do not "sell" or "share" your Personal Data.
Right to Non-Discrimination. The right to not be discriminated against for exercising any of your CCPA rights.
Right to Correct. The right to request correction of inaccurate Personal Data.
Right to Limit Use of Sensitive Personal Data. The right to limit the use and disclosure of your sensitive Personal Data

* Note that these rights may be limited by law in certain circumstances. To the extent such rights are limited, and we cannot honor them accordingly, we will let you know in our response to your request.

Colorado Residents. If you are a resident of Colorado, you have specific rights regarding your Personal Data under the Colorado Privacy Act. These rights* include:

Right to Opt Out. The right to opt-out from the sale of your Personal Data, or use of Personal Data for targeted advertising and certain types of profiling. NOTE: We do not sell your Personal Data or use your Personal Data for targeted advertising or profiling.
Right to Know. The right to know whether certain Personal Data is being collected.
Right to Access. The right to access certain Personal Data collected about them.
Right to Correct. The right to correct Personal Data.
Right to Delete. The right to delete Personal Data.
Right to Obtain a Copy. The right to download and remove Personal Data from a platform in a format that allows the transfer to another platform.

Nevada Residents. If you are a resident of Nevada, you have specific rights regarding your Personal Data under Nevada Revised Statutes Chapter 603A. These rights* include:

Right to Opt-Out. The right to direct us to not sell your Personal Data. NOTE: We do not sell your Personal Data.
Privacy Policy Disclosure. We are required to provide a privacy policy that discloses the categories of Personal Data we collect and the categories of third parties with whom we share such Personal Data.
Designated Request Address. We must provide a designated address where you can submit requests to opt-out of the sale of your Personal Data. Please note that you can contact us at support@wpthomegame.com.

Oregon Residents. If you are a resident of Oregon, you have specific rights regarding your Personal Data under the Oregon Consumer Privacy Act. These rights* include:

Right to Confirm. The right to confirm whether we are processing or have processed your Personal Data and the categories of Personal Data we are processing or have processed.
Right to Know. At our option on your request, we may provide you a list of specific third parties to which we have disclosed: (i) your Personal Data; or (ii) any Personal Data; and (C) a copy of all of your Personal Data that we have processed or are processing.
Right to Correct. The right to correct inaccuracies in Personal Data about you, taking into account the nature of the Personal Data and our purpose for processing the Personal Data.
Right to Delete. The right to delete Personal Data about you, including Personal Data you provided to us, Personal Data we obtained from another source and derived data.
Right to Opt Out. The right to opt out from the processing of Personal Data that we process for any of the following purposes: (A) Targeted advertising; (B) Selling the Personal Data; or (C) Profiling in furtherance of decisions that produce legal effects or effects of similar significance. NOTE: We do not sell your Personal Data or use your Personal Data for targeted advertising or profiling.

Texas Residents. If you are a resident of Texas, you have specific rights regarding your Personal Data under the Texas Data Privacy and Security Act. These rights* include:

Right to Know. The right to know whether we are processing your Personal Data and to obtain the Personal Data in a readable format.
Right to Correct. The right to correct inaccuracies in your Personal Data, taking into account the nature of the data and the purposes for processing the data.
Right to Delete. The right to delete Personal Data provided by or obtained about you.
Right to Opt Out. The right to opt out of the processing of Personal Data for purposes of targeted advertising, the sale of Personal Data, or profiling in furtherance of a decision made by the company concerning the consumer that results in the provision or denial by the company of certain services. NOTE: We do not sell your Personal Data or use your Personal Data for targeted advertising or profiling.
Right to Non-Discrimination. The right to not face retaliation or discrimination for exercising these rights.

Utah Residents. If you are a resident of Utah, you have specific rights regarding your Personal Data under the Utah Consumer Privacy Act. These rights* include:

Right to Know. The right to confirm whether we are processing your Personal Data.
Right to Access. The right to access your Personal Data.
Right to Delete. The right to delete your Personal Data that you provided to us.
Right to Obtain a Copy. The right to obtain a copy of your Personal Data that you previously provided to us, in a format that: to the extent technically feasible, is portable; to the extent practicable, is readily usable; and allows you to transmit the data without impediment,
Right to Opt Out. The right to opt out of the processing of the consumer's Personal Data for purposes of: targeted advertising; or the sale of Personal Data. NOTE: We do not sell your Personal Data or use your Personal Data for targeted advertising or profiling.

Virginia Residents. If you are a resident of Virginia, you have specific rights regarding your Personal Data under the Virginia Consumer Data Protection Act. These rights* include the right:

Right to Know. The right to confirm whether or not we process your Personal Data and to access such Personal Data.
Right to Correct. The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the data.
Right to Delete. The right to delete Personal Data provided by or obtained about you.
Right to Obtain a Copy. The right to obtain a copy of your Personal Data that you previously provided in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data.
Right to Opt-Out. To opt out of the processing of the Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects. NOTE: We do not sell your Personal Data or use your Personal Data for targeted advertising or profiling.

Canadian Residents. Unless allowed by applicable law, we will not collect additional personal information or use or disclose the personal information we collected in a way that is materially different, unrelated, or incompatible with the identified purposes without providing you with prior notice of our intention to do so and, if required by law, seeking your consent. In general, we collect, use, or communicate your personal information with your consent. We may however use or communicate your personal information without your consent in certain situations when permitted by applicable law. For example, we may use your personal information without your consent for security or for fraud prevention purposes. In certain cases, we may not be able to provide certain services to you or process an application on your behalf if you do not agree to the collection of personal information.

You have the right to withdraw your consent to the use or communication of your personal information: however, this will not affect the legality of any processing done prior to this withdrawal.

Right to Request Access and Correction of Personal Information. You have the right to request access to and correction of the personal information that we have collected about you. Your right to access personal information is not absolute but subject to restrictions in applicable law. If we do not make the correction you have requested, we will annotate the records to show that you made the request and explain to you why we did not make the correction.