Privacy Policy

01Introduction

Welcome to the Privacy and Cookies Policy for Appeak Poker (the "Game" or "Platform"), a free-to-play poker game available through our websites, mobile applications, and related services. This Policy explains how ADS Projects Group Ltd. ("we", "us", or "our") collects, uses, stores, shares, and protects personal data when you access or use Appeak Poker.

Appeak Poker is designed for entertainment. It uses virtual chips, virtual currency, rewards, and other in-game items that have no real-world cash value, cannot be redeemed for money or prizes, and are not intended to support or enable real-money gambling. Playing Appeak Poker does not create an opportunity to win money or anything of monetary value.

This Policy also describes your privacy rights under applicable laws, including the EU General Data Protection Regulation (GDPR), the UK GDPR, and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). By using Appeak Poker, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Game or related services.

02Information We Collect

We collect personal, technical, gameplay, and transaction-related information from and about users of Appeak Poker so that we can provide, maintain, improve, personalize, and secure the Game. The categories of information we may collect include:

• Identity and Contact Information: your name, username, nickname, avatar, email address, and other contact details that you provide when creating an account, contacting support, participating in promotions, or communicating with us.
• Age and Eligibility Information: information used to confirm that you are old enough to use Appeak Poker. Because the Game simulates poker, it is not intended for minors. We may ask you to confirm that you are 18 years of age or older, or the age required by local law.
• Account Credentials: login identifiers, authentication tokens, and password-related data. Passwords are stored in encrypted or hashed form where we control account authentication.
• Gameplay and In-Game Activity: poker gameplay statistics, table participation, tournaments or events joined, hands played, chip balances, virtual currency balances, achievements, rewards, bonuses, level progression, session duration, preferences, and other interaction data within the Game.
• Device and Technical Data: IP address, device type, operating system, browser type, device identifiers, mobile advertising identifiers, app version, language, time zone, crash logs, performance data, and related technical information.
• Cookies and Tracking Data: information collected through cookies, pixels, mobile SDKs, local storage, analytics tools, and similar technologies, including pages or screens viewed, buttons clicked, referral sources, session information, and advertising or analytics identifiers. See the Cookies and Tracking Technologies section below for more details.
• Virtual Item and Purchase Information: if you choose to obtain virtual chips, coins, subscriptions, boosts, or other in-game content, we collect purchase confirmations, transaction IDs, purchase history, virtual item balances, and related account data. Payments made through mobile app stores are typically processed by Apple App Store or Google Play, and we usually receive confirmation of your purchase rather than full payment card details.
• Communications and Support Data: information you provide when you contact us for customer support, report a problem, submit feedback, respond to surveys, or communicate with us by email, in-app messaging, or other channels.
• Third-Party Login or Platform Data: if you choose to log in or connect through a third-party platform such as Facebook, Google, Apple, or another provider, we may receive information that you authorize that provider to share, such as your profile name, profile photo, email address, account ID, friend list, or other connected-platform information.
• Approximate Location Data: country, region, or general location inferred from your IP address, device settings, app store region, or network information. We do not collect precise GPS location unless we specifically ask for permission and you grant it through your device settings.

We collect information directly from you, automatically through your use of Appeak Poker, and from third parties such as app stores, analytics providers, advertising partners, fraud-prevention vendors, and connected platforms. We limit our collection to information that is relevant for the purposes described in this Policy.

03How We Use Your Information

We use the information we collect for the following purposes and legal bases, where applicable:

• Providing and Operating Appeak Poker: to create and maintain your account, authenticate logins, enable poker gameplay, match players, operate tables and events, record game progress, manage virtual chip balances, deliver rewards, and provide core Game features.
• Maintaining a Free-to-Play Economy: to provide virtual chips, daily bonuses, rewards, offers, in-game purchases, and other virtual items; to prevent abuse of virtual balances; and to ensure that virtual items remain non-cash, non-transferable, and usable only within Appeak Poker.
• Improving and Personalizing the Game: to analyze usage, troubleshoot issues, fix bugs, optimize performance, test features, customize game content, tailor user interface elements, recommend tables or events, and improve gameplay balance and user experience.
• Behavioral Analytics: to understand how users interact with Appeak Poker, including which features, tables, events, offers, and screens are used most often. We use analytics data to make product and design decisions and, where possible, rely on aggregated or de-identified data.
• Personalized Advertising and Marketing: with consent where required, to show relevant advertisements, measure ad performance, manage campaigns, send marketing emails or push notifications, and promote features, events, and offers related to Appeak Poker or our other services. You can opt out of marketing communications and certain targeted advertising as described below.
• Communications and Customer Support: to respond to support requests, send account notices, provide password resets, notify you about service updates, inform you of material policy changes, and manage complaints or technical issues.
• Security, Integrity, and Fraud Prevention: to detect, prevent, and investigate cheating, bots, collusion, abuse of promotions, unauthorized access, account takeover, fraud, harassment, violations of our Terms, or other harmful conduct. This may include reviewing gameplay patterns and technical identifiers.
• Legal Compliance and Enforcement: to comply with laws, regulations, court orders, regulatory requests, tax or accounting obligations, and app store requirements; to enforce our Terms; and to establish, exercise, or defend legal claims.

Where GDPR or UK GDPR applies, our legal bases may include performance of a contract, legitimate interests, consent, and compliance with legal obligations. We rely on consent for certain marketing communications, non-essential cookies, and tracking technologies where required by law. You may withdraw consent at any time where processing is based on consent.

04Cookies and Tracking Technologies

What Are Cookies and Similar Technologies: Cookies are small text files placed on your device when you visit a website. Mobile applications may use similar technologies, including SDKs, pixels, local storage, mobile advertising identifiers, and analytics tools. In this Policy, we refer to these technologies collectively as "cookies" or "tracking technologies".

Why We Use Cookies: We use cookies and similar technologies to operate Appeak Poker, remember preferences, keep you logged in, analyze performance, improve gameplay, measure advertising, and support personalized advertising or marketing where permitted.

Types of Cookies and Tracking Technologies We Use:

• Strictly Necessary Technologies: required to provide the service you request, such as authentication, security, fraud prevention, session management, and basic Game functionality. These technologies do not usually require consent where they are strictly necessary.
• Functionality Technologies: used to remember preferences such as language, sound settings, table preferences, display options, or whether you have already seen a tutorial or notice.
• Performance and Analytics Technologies: used to collect aggregate or pseudonymous information about how users interact with Appeak Poker, including screens visited, feature usage, crashes, errors, session length, and performance metrics. Where required, we use these technologies only with your consent.
• Advertising and Targeting Technologies: used to deliver, personalize, measure, and limit advertising. These technologies may involve sharing pseudonymous identifiers, device information, or usage signals with advertising partners or networks. Where required, we use these technologies only with your consent and provide opt-out choices.

We may also use web beacons, pixels, and similar tools in emails, webpages, and in-app messages to understand whether a message was delivered, opened, or interacted with, and to measure the effectiveness of communications and campaigns.

Third-Party Cookies and SDKs: Some tracking technologies are provided by third parties such as analytics providers, attribution partners, fraud-prevention vendors, advertising networks, app stores, and social media platforms. These third parties may collect or receive pseudonymous information from your device or browser. Their processing is subject to their own privacy policies, and we encourage you to review those policies.

Website Analytics (Mixpanel): Our website uses Mixpanel, a product analytics service provided by Mixpanel, Inc., to understand how visitors use our pages, for example which pages are viewed and which buttons, such as the Play button, are clicked. Mixpanel may receive the page address, the referring website, campaign parameters (such as UTM tags), device type, screen size, browser language, and a random identifier stored in your browser's local storage. Mixpanel may also use your IP address to infer an approximate location such as country or city. We do not send your name or email address to Mixpanel from our website. Our Mixpanel data is stored in Mixpanel's European Union data center. If you are located in the European Economic Area, the United Kingdom, or Switzerland, Mixpanel is loaded only after you accept analytics cookies in our cookie banner, and you can withdraw your consent at any time through the "Cookie Settings" link at the bottom of our website. For more information, see Mixpanel's privacy policy at mixpanel.com/legal/privacy-policy.

Your Choices for Cookies and Advertising:

• Cookie Preferences: where required, our website or related services may provide a cookie banner or preference center that allows you to accept or reject non-essential cookies, including analytics and advertising cookies.
• Browser Settings: most browsers allow you to block, delete, or manage cookies. Blocking all cookies may affect website functionality.
• Mobile Device Settings: mobile operating systems allow you to reset or limit the use of advertising identifiers. On iOS, you can manage app tracking and personalized advertising in device settings. On Android, you can manage or reset your advertising ID and ad personalization settings.
• Marketing Opt-Out: you may opt out of marketing emails by using the unsubscribe link in the email. Push notifications can usually be disabled through your device settings.
• Global Privacy Control and Similar Signals: where required by applicable law, including California law, we will treat recognized opt-out preference signals such as Global Privacy Control as a request to opt out of sale or sharing for targeted advertising.

05Disclosure of Information

We do not sell personal information to data brokers for money. We may share information as necessary to operate, improve, secure, and promote Appeak Poker, and as otherwise described below:

1. Service Providers: We share information with vendors that provide hosting, cloud storage, analytics, crash reporting, customer support, payment processing, fraud prevention, email delivery, push notification delivery, security, testing, and other operational services. These providers may use personal data only as instructed by us and for the services they provide.
2. App Stores and Payment Processors: If you make in-app purchases, information may be processed by Apple, Google, or other payment providers. We receive transaction confirmations and related account information needed to deliver purchased virtual items and support purchase-related inquiries.
3. Advertising and Marketing Partners: We may share limited identifiers and usage information with advertising networks, attribution providers, and marketing platforms to deliver and measure ads, prevent ad fraud, and manage campaigns. Under some laws, this may be considered a "sale" or "sharing" for cross-context behavioral advertising. You may opt out as described in this Policy.
4. Connected Platforms and Social Features: If you connect Appeak Poker to a third-party account or use social features, we may share information necessary to enable those features, such as your profile name, avatar, friend connections, invitations, rankings, or gameplay-related social data, depending on your settings and choices.
5. Business Partners and Affiliates: We may share information with affiliates or carefully selected partners where necessary to operate promotions, events, integrated services, or business functions related to Appeak Poker. Any such sharing will be limited to the relevant purpose and subject to appropriate safeguards.
6. Legal, Safety, and Enforcement Disclosures: We may disclose information if we believe it is necessary to comply with law, legal process, regulatory requests, app store requirements, or government requests; to enforce our Terms; to investigate fraud, cheating, collusion, security incidents, or other harmful conduct; or to protect the rights, property, or safety of us, our users, or others.
7. Corporate Transactions: If we are involved in a merger, acquisition, restructuring, financing, bankruptcy, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate safeguards and notices where required.

Except as described in this Policy or with your consent, we do not disclose personal information to third parties for their independent marketing purposes.

06International Data Transfers

Appeak Poker may be accessed globally, and your information may be processed in countries other than the country where you live. ADS Projects Group Ltd. is based in the United Kingdom, and our service providers may process data in the United States, the European Economic Area, the United Kingdom, and other jurisdictions.

Where required, we use appropriate safeguards for international transfers of personal data, such as Standard Contractual Clauses approved by the European Commission or UK authorities, adequacy decisions, certified data transfer frameworks, supplementary technical and organizational measures, encryption, access controls, and data minimization.

By using Appeak Poker or providing information to us, you understand that your information may be processed internationally as described in this Policy. We remain responsible for protecting personal data in accordance with this Policy and applicable law.

07Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law. In practice:

• Account and gameplay data is generally retained while your account remains active, so we can maintain your profile, progress, virtual chips, preferences, and gameplay history.
• If you delete your account or request deletion, we will delete or anonymize personal data unless we need to retain certain information for legal, security, fraud-prevention, dispute-resolution, tax, accounting, or compliance purposes.
• Purchase and transaction records may be retained for legal, accounting, tax, app store, refund, and anti-fraud purposes.
• Marketing data is retained until you unsubscribe, withdraw consent, or request deletion, subject to maintaining suppression records so we can honor your opt-out.
• Cookies, analytics records, logs, and technical data are retained for periods that vary depending on the technology and purpose, such as session duration, 30 days, 90 days, or longer where justified.
• Backup copies may remain for a limited period before being overwritten or deleted, and we restrict active use of data stored in backups.

We periodically review the personal data we hold and delete or anonymize information that is no longer needed.

08Data Security

We use appropriate technical and organizational measures designed to protect personal information from unauthorized access, disclosure, alteration, loss, misuse, and destruction. These measures may include encryption in transit, access controls, authentication requirements, monitoring, secure development practices, vendor controls, and incident-response procedures.

No internet or electronic storage system can be guaranteed to be completely secure. You are responsible for keeping your account credentials confidential and for using a strong, unique password where applicable. If you believe your account has been compromised, please contact us promptly.

09Your Rights and Choices

Depending on where you live, you may have rights in relation to your personal data. We will honor applicable rights and provide ways for you to exercise them.

Rights for EU and UK Individuals

If you are located in the European Union, United Kingdom, or a jurisdiction with similar data protection laws, you may have the following rights:

• Right to Be Informed: to receive clear information about how we collect and use personal data.
• Right of Access: to request a copy of the personal data we hold about you.
• Right to Rectification: to ask us to correct inaccurate or incomplete data.
• Right to Erasure: to request deletion of personal data in certain circumstances.
• Right to Restrict Processing: to ask us to limit processing in certain circumstances.
• Right to Data Portability: to receive personal data you provided to us in a structured, commonly used, machine-readable format, where applicable.
• Right to Object: to object to processing based on legitimate interests and to object to direct marketing at any time.
• Right to Withdraw Consent: to withdraw consent where processing is based on consent.
• Right Not to Be Subject to Certain Automated Decisions: we do not make legally significant decisions about you solely by automated means. If this changes, we will provide required notices and rights.

To exercise these rights, contact us at support@appeakpoker.com. We may need to verify your identity before responding. We will respond within the timeframe required by applicable law.

You also have the right to lodge a complaint with a supervisory authority, such as the UK Information Commissioner's Office or your local data protection authority.

Rights for California Residents

If you are a California resident, you may have the following rights under the CCPA/CPRA:

• Right to Know: to request the categories and specific pieces of personal information we collect, use, disclose, sell, or share, and information about sources, purposes, and third-party recipients.
• Right to Delete: to request deletion of personal information we collected from you, subject to legal exceptions.
• Right to Correct: to request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing: to opt out of the sale or sharing of personal information for cross-context behavioral advertising. We do not sell personal information for money, but some advertising-related disclosures may be considered a sale or sharing under California law.
• Right to Limit Use of Sensitive Personal Information: we do not use sensitive personal information for purposes that would require a limitation mechanism unless we provide notice and a way to exercise this right.
• Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights.

California residents can submit requests by emailing support@appeakpoker.com with the subject line "California Rights Request". For opt-out of sale or sharing, you may also use any "Do Not Sell or Share My Personal Information" link or privacy settings we provide, where applicable. We will verify and respond to requests as required by law.

Other Jurisdictions

Users in other locations may have similar rights under local privacy laws. You may contact us to request access, deletion, correction, portability, restriction, objection, withdrawal of consent, or other rights that apply in your jurisdiction.

10Children's Privacy

Appeak Poker is not intended for children or minors under 18, or under the minimum age required by local law. We do not knowingly collect personal information from children or minors. Because Appeak Poker simulates poker gameplay, minors must not use the Game or provide personal data to us.

If we learn that we have collected personal information from a child or minor in violation of this Policy or applicable law, we will take reasonable steps to delete that information and terminate the account where appropriate. Parents or guardians who believe that a minor has provided personal information to us should contact us at support@appeakpoker.com.

11Free-to-Play Poker and Virtual Items

Appeak Poker is a free-to-play game. Virtual chips, coins, bonuses, rewards, subscriptions, boosts, or other virtual items used in the Game are licensed to you for entertainment use within Appeak Poker only. They have no cash value, cannot be withdrawn, sold, transferred outside the Game, exchanged for money, or redeemed for real-world goods, services, or prizes except where expressly stated in official promotional terms. Purchases of virtual items, if available, do not improve the chance of winning money because Appeak Poker does not offer real-money gambling. We may use information about virtual balances, purchases, and gameplay activity to maintain the Game economy, provide support, prevent fraud, and comply with app store and legal requirements.

12Updates to This Privacy Policy

We may update this Privacy and Cookies Policy from time to time to reflect legal, technical, or business developments. When we make changes, we will post the updated Policy and update the "Last Updated" date. If changes are material, we may provide additional notice, such as an in-app notice, website notice, or email notification, where appropriate.

Your continued use of Appeak Poker after an updated Policy becomes effective indicates that you have read and understood the updated Policy, to the extent permitted by law. If we materially change how we use personal data and consent is required, we will seek consent as required by applicable law.

13Contact Us

If you have questions, concerns, or requests regarding this Privacy and Cookies Policy or our handling of personal information, please contact us:

We will respond to privacy-related inquiries as required by applicable law and will do our best to address your request promptly and transparently.

Last Updated: November 9, 2026