Privacy Policy

Last Updated: Octobor 13th 2018

For the Purpose of this Privacy Policy, the Data Controller of your personal data is Qufan Internet Technology Ltd. ("Us", "We", or "Our"). We operate the Pokio® application (the "Service"). Our Data Protection Officer is Miss Lulu Xu. If you have any questions about this Privacy Policy, please contact our Data Protection officer at dataprotection@pokio.com.

Our Commitment to Our Players' Privacy

We are the owner and operator of the websites located at www.pokio.com (the "Sites"). We are committed to inform you of our policies regarding the collection, use and disclosure of personal information when you use our Service. We will not use or share your information with anyone except as described in this Privacy Policy.

We use your personal information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

We will comply with the terms of applicable data protection regulations for the MGA licence through which you access and use our Service (as such regulations may be amended from time to time) (collectively, "Applicable Law"), when processing your personal information.

What do the Capitalised Terms Mean?

Unless we give them a specific meaning in this Privacy Policy, capitalised terms shall have the meaning given to them in our Privacy Policy.

Information Collection and Use

Purposes and Legal Bases of Data Processing

Consent

Data Retention

Disclosure of Personal Information

Business Transactions

Your Rights in Relation to Your Information

Behavioral Remarketing

Cookies

Confidentiality

Minors Privacy

Changes to This Privacy Policy

Contact Us

Information Collection and Use

When using our Service, We collect certain personal information that you voluntarily provide in order to register your Pokio account. Such personal information includes:

  Contact information: your name, surname, address, age, birth date, gender, email address, phone number, zip code.

  Financial information: in order to operate online payments, We collect your banking details and transactional information, such as the payments to and from your Pokio account.

  Furthermore, due to Anti Money Laundering legal requirements We are required by the law to ask you for supplementary documents such as identification documents including your photo, documents regarding your source of wealth, utility bill and others.

Log Data

When you access the Service by or through a mobile device, We collect certain information automatically, such as the type of mobile device you use, your mobile device unique ID, your mobile operating system, the type of mobile Internet browser you use and other statistics ("Log Data").

In addition, We may use third party services such as Google Analytics that collect, monitor and analyze this Log Data in order to increase our Service's functionality for example to ensure that the content on our Website is presented in the most effective manner for you and your computer or mobile device or to analyse how customers use our app and Website. These third-party service providers have their own privacy policies addressing how they use such information.

Location Information

Upon your specific consent We may use and store information about your location, such as IP address of your mobile device. We use this information to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at anytime, through your mobile device settings.

Purposes and Legal Bases of Data Processing

Personal data necessary for the navigation and use of Service is collected and processed by Us in order to fulfil Our obligations under the Terms and Conditions entered into by Our users as well as to fulfill our legal obligations, for the following purposes:

  To process the registration, set up and maintain your Pokio account (including age verification and other anti-money laundering checks);

  Administration and development of the Website and the Services, including operating your financial transactions;

  Enhancement of user experience, including the provision of personalized Services and improvement of the Website and the Service;

  Extrajudicial or judicial use for the protection of our lawful rights and interests.

Consent

We may process personal data only with your lawful consent for the following purposes:

  For the purposes of promotional communication, marketing and advertising of our services or third party services via SMS, telephone, e-mail, internet, fax, mail, social media and / or any other appropriate communication channels;

  For personified market research and / or analysis purposes to better understand your needs, preferences, interests, experiences and / or habits as a consumer.

You have the right to withdraw your consent at any time in writing to our contact details mentioned in this Policy. Withdrawal of your consent does not affect the lawfulness of the treatment of your data prior to its revocation. Your consent is also revoked in the same manner as provided.

Data Retention

We will retain your information only for as long as is necessary for the purposes set out in this Policy, in alignment with the Data Minimisation and Storage Limitation principles. If you have registered a Pokio account, We will retain your personal data during the period your account is active. Additionally, we align the retention of your information with potential differentiations arising from the exercising of your data privacy rights.

However, in some cases your personal information may be retained beyond that time period in order for us to comply with our legal obligations such as applicable gambling regulations, Know-Your-Customer and Anti-Money Laundering regulations and for us to defend our rights and legitimate interests before any competent court and any other public authority in case of any disputes. For more information about data retention terms in relation to specific personal data, please contact us at dataprotection@pokio.com.

Disclosure of Personal Information

We may employ third party service providers to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used. Such third parties are:

  Payment providers

  AML/CTF and anti-fraud services

  Platform Providers

  Services providers

These third parties have access to your personal information only to perform these tasks on our behalf and are obliged not to disclose or use it for any other purpose. We also enter into contracts with these third parties that compel them to meet the privacy standards required by law in handling your personal information.

When any of the third parties mentioned above are located outside of the European Union, we will take all reasonable steps possible to ensure that your data is treated as securely as it is within the European Union. Accordingly, we will enter into standard data protection clauses adopted by the European Commission which compel these third parties to meet the privacy standards required by law. For more specific information about the safeguards adopted in relation to any third parties located outside the European Union, please contact us at dataprotection@pokio.com. We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law, upon the reasonable requests of law enforcement or other Authorities or to protect the security or integrity of our Service.

Business Transaction

If Qufan Internet Technology Ltd is involved in a finalized merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

Your Rights in Relation to Your Information

You have right to:

  Request for access to your personal data and information related to their processing and obtain a copy thereof;

  Request for the rectification of any inaccuracies or any missing personal data of yours;

  Request for the erasure of your personal data;

  Request for the restriction of the processing of your personal data in cases explicitly provided for by law;

  Request for the portability of your personal data to another controller in a structured, commonly used and machine-readable format;

  Object to the processing of your personal data in cases explicitly provided for by law;

  Object to a decision taken solely on the basis of automated processing, including profiling, which has impact on you or significantly affects you.

Any requests relevant to the above are addressed in writing to our contact details mentioned in this Policy.

We will respond to any of your requests within one month from their receipt. Upon prior notice, this period may be extended by a further two months if necessary, taking into account the complexity of the request and the number of any other pending requests. In case of rejection of your request, we will provide relevant justification.

If your request does not meet the requirements of applicable law, We reserve the right either to: (a) impose a reasonable fee, taking into account the administrative costs of providing the information or communicating or executing the requested action, or (b) reject your request.

In the event of any violation of your personal data, which may place your rights and freedoms at a high risk, and provided that it does not fall under one of the exceptions expressly provided for by applicable law, we undertake to inform you without undue delay.

If there are any doubts as to the identity of the individual submitting the request, We reserve the right to request the provision of additional information necessary to confirm his/her identity.

If your rights are infringed, you have the right to file a complaint with Malta Office of the Information and Data Protection Commissioner or with any other competent supervisory authority.

Behavioral Remarketing

We use remarketing services from time to time to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

  Google

Google AdWords remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page.

Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy HYPERLINK "http://www.google.com/intl/en/policies/privacy/"& HYPERLINK "http://www.google.com/intl/en/policies/privacy/" Terms web page.

Cookies

10. Cookies are text-only strings of information that are downloaded to your personal desktop, laptop computer or mobile device (each a "Device") when you visit our Sites or apps. They are then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies.

Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes cookies are used to help ensure that adverts you see online are relevant to you and your interests.

We use cookies in order to track referrals to our websites, to remember your preferences, to make our websites more responsive, and to generate anonymised statistical data, which we use to improve the user experience on our websites. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website, and to provide advertisements that are more relevant to your interests.

Confidentiality

11. Qufan Internet Technology Ltd has undertaken substantial efforts to protect the confidentiality of the identity, preferences and other information it has collected about individual Users and will not knowingly allow access to this information to anyone outside Qufan Internet Technology Ltd group of companies, other than to the User or as described in this Privacy Policy. We have made a substantial investment in our server, database, backup, firewall and encryption technologies to protect the information that we collect. These technologies are deployed as part of state of the art security architecture.

You should also do your part in protecting your information. Your Login Credentials (as defined in our Terms and Conditions) are confidential and you are obliged to keep your Login Credentials secret and confidential at all times and to use your best efforts to protect their secrecy and confidentiality.

Minors Privacy

12. Our Service does not accept anyone under the age of 18 ("Minors").

Changes to This Privacy Policy

13. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

14. If you have any questions about this Privacy Policy, please contact us at dataprotection@pokio.com.