Privacy Policy

 

General

 

Comunix Ltd. (“Comunix”) operates a social Poker game with a live video chat platform (the “Service”). Comunix takes its user's privacy very seriously and is committed to protecting its information in compliance with applicable laws and regulations. This Privacy Policy has been created to inform you about how we collect, store, use and share the information you provide in connection with the 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 agree to any provision in this Privacy Policy, please stop using the Service.

We may amend this Privacy Policy from time to time without notice and you are expected to check this Privacy Policy frequently. Your continued use of the Service indicates your agreement with the most updated version of this Privacy Policy.

Please note that we will not share any of your personal information or other identifiable (by itself or together with additional information) information protected under applicable privacy laws and regulations (including without limitations the EU’s GDPR (”GDPR”)) (“Personal Information”) with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by "opting in". Among others, you may opt-in by providing us with your phone number for the purpose of receiving commercial offers or other notifications and updates.

 

The Information We Collect and How We Collect It

 

We only collect Personal Information to the extent necessary to fulfill one or more of the Service’s functions and activities.

If you use the Service through a third-party platforms (such as Facebook), we may receive certain Personal Information about you from such platforms.

As an example only, we may collect the following Personal Information from you directly or receive it from third parties: (i) profile picture; (ii) username, password and user ID number (e.g. your Facebook ID number); (iii) user ID number and other public data of your friends on social platforms; (iv) e-mail and other contact details you provided; (v) contact lists; (vi) location data; (vii) gender; and (viii) age and birth date.

We may also collect certain information about your activities on or through the connected third-party applications or through your use of the Service and other publicly-available information.

We may also collect information through your use of the Service such as if you participate in player forums and message boards, post comments to other users, send private messages or invitations to other users, chat with users or post information.

We may receive certain billing and payment information if and when you pay any amount to Comunix or otherwise transfer funds through the Service. We will not store your financial information, however, our payment processors may share non-financial information with us related to your purchases, like your name, billing address, etc.

Finally, we may use various tracking technologies to collect certain kinds of technical information, including without limitations: (i) the type of device you are using; (ii) your operating system version and platform type; (iii) your mobile device’s identifiers; (iv) your browser types and language; (v) referring and exit pages, and URLs; (vi) domain names and landing pages, pages viewed and other browsing information.

We may collect the above information directly or through our third party suppliers.

Transfer of Information Internationally

When you use our services, your Personal Information may be sent to other countries including without limitations to the United States or out of the United States to other countries. We may store Personal Information about players on servers located in the United States and in other countries. When we transfer your Personal Information internationally we will take reasonable steps to ensure that your Personal Information is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your Personal Information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident. If you are a resident in a jurisdiction, where a transfer of your Personal Information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer for us to provide you with our services.

 

Cookies

 

A 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 you access the Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of the Service, tailoring recommendations to interests, and making the Service easier to use. Third-party advertisers on the Service may also use, place or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies. You may disable cookies 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, however, if you do not accept cookies you may not be able to use all features of the Service.

We and our third-party service providers may also employ other similar technologies including, without limitations: (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 or our advertising partners to advertise more efficiently and effectively by excluding our 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 which help us to reduce fraud, remember your in-game preferences and speed up load times.

 

How We Use and Share Your Information

 

We may collect and store your information for the following purposes: (i) creating game accounts and enable the Service; (ii) improve, optimize and personalize the Service; (iii) identify and suggest connections with other users; (iv) enable users to communicate with each other; (v) provide technical support; (vi) protect the safety and rights of users; (vii) protect our rights and enforce this Privacy Policy and our Terms of Use; (viii) prevent fraud or potentially illegal activities; (ix) manage and deliver contextual and behavioral advertising; (x) notify users of new products or services, updates or other offers; or (xi) comply with our legal obligations, resolve disputes.

Anonymous, statistical or aggregated information may be shared by us with our partners for legitimate business purposes.

Please note that other users will be able to see descriptions of your game activity and your public profile information and to communicate with you within the Service.

We may record games played through the Service at our discretion and use such recording for our business purposes in accordance with applicable laws and regulations. Among others, we may broadcast, display, show and otherwise share live or recorded games from worldwide tables and tournaments. We may do this through any commercial or other channels such as (without limitation) Facebook live, Youtube, Twitch, etc. For the avoidance of any doubt, games played in private tables will not be broadcasted (however such games may be recorded).

Third-Party Advertising

We do not actively share Personal Information with third-party advertisers for their direct marketing purposes unless you give us your consent. When advertisers place ads in the Service, they may collect or we may share certain performance data (e.g. a number of clicks on advertisements), aggregated and/or de-identified information about users, certain technical information (e.g., IP addresses, social network ID and other contextual data about your gameplay.

The information collected as set forth above may be used in order to measure the effectiveness of ads, offer targeted advertising and/or perform web analytics.

Advertisers may collect this information through the use of tracking technologies like cookies and web beacons (see above). If you do not want to receive tailored advertisements from third parties, please follow the instructions below.

 

Third-Party Service Providers

We may share information with third-party suppliers and partners to perform services on our behalf, like processing payments, analyzing data, optimizing gameplay, e-mail delivery, hosting services, customer service and to help us in our marketing efforts. We require such third parties to maintain the confidentiality of the information we share with them and not to use your information for anything other than to provide services on our behalf.

 

Sale or Merger

In the event that we consummate a merger or an acquisition by another company or otherwise undergo a change of control, we may disclose or transfer all of your information, including Personal Information, to the successor company.

 

Other Cases in Which We May Share Your Information

We may also share your information: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any laws or regulations; (iii) where we believe that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions; (iv) when we believe that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) to protect the rights or property of Comunix and other applicable third parties, including to enforce our Terms of Use.

 

Accessing and Managing Your Information

 

We may also share your information: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any laws or regulations; (iii) where we believe that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions; (iv) when we believe that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) to protect the rights or property of Comunix and other applicable third parties, including to enforce our Terms of Use.

 Accessing and Managing Your Information

Under applicable data protection laws and regulations, including the GDPR, you have the right to:

(i)              access your personal data and receive a copy thereof, i.e. obtain information on whether we process your personal data and specific information about any such processing;

(ii)            rectify (amend) your personal data, i.e. request to amend inaccurate personal data;

(iii)           erase your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under the applicable law apply);

(iv)           restrict the processing of your personal data, provided that one of relevant grounds for such actions apply (and that no exclusions under the applicable law apply);

(v)             complain to a supervisory authority;

(vi)           withdraw your consent.

You may exercise any of your rights in relation to your personal data by written notice to us at support@getcomunix.com.

How We Protect Your Information

 

Comunix has made reasonable technical and organizational measures designed to secure your information from accidental loss and from unauthorized access. While we take reasonable precautions against possible security breaches of our Service, no website or Internet transmission is completely secure, and Comunix cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.

How Long We Keep Your Information

How long we retain your Personal Information depends on why we collected it and how we use it. We will not retain your Personal Information for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain all or part of your Personal Information for a few years after you have decided to close your account if this is necessary to meet our legal obligations or to exercise legal rights..

CCPA Notice (California)

This part of our privacy policy contains disclosures and provisions required by the California Consumer Privacy Act of 2018 (the “CCPA”) and applies only to “Personal Information” that is subject to the CCPA and only to California residents.

Collection, Disclosure or Sale of Personal Information

In the last 12 months, we collected the categories of Personal Information about California residents as described in this Privacy Policy including in this CCPA Privacy Notice. Our use of such Personal Information may qualify as a “Sale” under the CCPA since the data we provide to third parties, including to our clients and partners might help us to generate valuable consideration. Even if our own use of Personal Information does not constitute a “Sale” under the CCPA, our clients and partners may use our technology to buy or sell Personal Information as defined by the CCPA. If you wish to opt-out of the use of your Personal Information for interest-based advertising purposes, you may do so by contacting us at support@getcomunix.com.

Categories of Personal Information We Collect

1.              Personal and online identifiers (such as name, emails, unique online identifiers like cookies, mobile advertising IDs, etc.). Please note that we will not, however, sell any personal identifiers such as names and emails and they will be used only for our internal purposes as described in greater depth in other parts of our Privacy Policy.

2.              Internet or additional electronic network activity information (such as browsing history, interactions with a website or advertisement).

3.              Geolocation information.

4.              Inferences are drawn from the above information about your predicted characteristics and preferences.

5.              Other information about you that is linked to the personal information above.

Such Personal Information was received from the categories of sources of information set forth below, was collected for all of the purposes set forth below and was sold, used or shared to the third parties listed below:

1.              Categories of Sources: We collect this personal information from the following categories of sources: our users and our partners.

2.              Why We Collect, Use, and Share California Information: We use and disclose the personal information we collect for our commercial and business purposes, as described in greater depth in other parts of our Privacy Policy. These commercial and business purposes including, without limitation: (i) Providing our products and services, (ii) Other business purposes as identified in the CCPA, which include: advertising or marketing services, auditing related to our interactions with you, legal compliance, detecting and protecting against security incidents, fraud, and illegal activity, performing services (for us or our service providers) such as account servicing, processing orders, and payments, and analytics, internal research for technological improvement, internal operations, activities to maintain and improve our services and other certain one-time uses.

3.              Recipients of California Personal Information: To the extent our use of Personal Information constitutes a “Sale” under the CCPA, we “sell” Personal Information to our partners. We disclose (or might disclose) the categories of Personal Information designated above to the following categories of third parties, for the above commercial and business purposes: Service providers (as defined by the CCPA), government entities (upon request and to the extent we are obligated to do so), services providers such as fraud protection vendors and data analytics companies.

Your Rights Regarding Personal Information

 

If you are a California resident, you may exercise the following rights regarding your Personal Information, subject to certain exceptions and limitations: (i) the right to know categories and specific Personal Information we collect, use, disclose, and sell about you over the past twelve (12) months, categories of sources from which we collected your Personal Information, our purposes for collecting or selling your Personal Information, the categories of your Personal Information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared Personal Information, (ii) the right to request that we delete the Personal Information we have collected from you or maintain about you, (iii) the right to opt-out of any “sale” of your Personal Information and (iv) the right not to be discriminated against for exercising any of your rights under the CCPA.

To exercise any of the above rights, please contact us at support@getcomunix.com.

Minors under 16

 

Without derogating from any of our statements above, we do not sell the personal information of consumers that we know to be under 16 years of age.

LGPD Notice (Brazil)

Brazil's new privacy legislation, the General Data Protection Law (LGPD) was approved on 14th August 2018 and is expected to come into effect on May 3, 2021 as per the terms of the Provisional Measure No. 959, which remains pending of analyses by the National Congress. If the Provisional Measure is not approved, amended or analyzed by the scheduled deadline, the LGPD will become effective on August 15, 2020.

Due to the fact that the LGPD is similar to the GDPR in many ways (despite some differences), we believe that we are in a good position to achieve full compliance with the provisions of the LGPD before it enters into force, including without limitations, allowing all data subjects which personal data will be protected under the provisions of the LGPD to exercise their rights, including the right to request that personal data will be erased, the right to data portability and data access.

In performing personal data processing which is subject to the LGPD, we will adhere to key differences between the LGPD and other legislation acts such as the GDPR, among others with respect to the required procedures for reporting a data breach, the legal basis available to us for the collection, processing and sharing of personal data, the various rights of data subjects, etc.

We may, at our discretion, decide to implement data protection principles, procedures and processes which are more protective to you than is required from us by the applicable privacy data legislation. For example, we may decide to follow the GDPR data breach reporting obligations which are stricter than the requirement under the LGPD. In no event shall our decision to follow such stricter policies grant you any rights which are not granted to you under the data protection legislation applicable to you.

Changes to Our Privacy Policy

 

If we decide to make material Changes to Our Privacy Policy, we will tell you and other players by placing a notice on Comunix.com or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Comunix websites. You should periodically check www.getcomunix.com and this privacy page for updates.

 

For any questions, comments or concerns about our Privacy Policy or any other issue (including without limitations in order to exercise any of your rights with respect to the managing of your Personal Information) please contact us at support@getcomunix.com