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Official Data Protection Codex

CLUBGG PRIVACY POLICY

Last Updated: September 2026. This Privacy Policy details our comprehensive standards for collecting, processing, and safeguarding player information across all ClubGG applications and sweepstakes services.

Sections

1. Scope & Governance 2. Information We Collect 3. How Information is Used 4. Anti-Collusion & Integrity 5. Data Sharing & Third Parties 6. Cross-Border Transfers 7. Retention & Storage 8. Your Data Protection Rights 9. Age Verification & Minors 10. Contact & Inquiries

1. Scope & Regulatory Governance

This Privacy Policy applies to all services, desktop clients, mobile applications (iOS and Android), web portals, and sweepstakes tournament hubs operated by ClubGG ("Company", "we", "us", or "our"). When you access the ClubGG platform, register a user profile, host a private poker club, or enter sweepstakes satellite events, you entrust us with personal information. We maintain rigorous compliance with the California Consumer Privacy Act (CCPA/CPRA), the General Data Protection Regulation (GDPR), and all applicable United States federal and state data privacy standards.

By accessing ClubGG, you acknowledge that you have reviewed, understood, and consented to the operational practices delineated in this document.

2. Information We Collect

We collect distinct categories of information to ensure account security, fair dealing, and seamless transaction processing:

  • Directly Provided Identifiers: Email address, player screen nickname, avatar images, date of birth, mailing address (required for live tournament passport awards), and phone numbers.
  • Third-Party Single Sign-On (SSO): When authenticating via Apple ID, Google, or Facebook, we obtain your unique platform identification token and email address in strict accordance with your authorization settings.
  • Financial & Subscription Data: In-app purchase receipts, subscription status (e.g., Platinum VIP tier), billing transaction IDs, and payout compliance records. ClubGG does not store raw credit card numbers; all payments are processed through PCI-DSS Level 1 certified gateways.
  • Hardware & Telemetry Data: IP addresses, operating system version, device identifiers (UUID), screen resolution, connection latency, and localized GPS coordinates (used to confirm sweepstakes jurisdictional eligibility).

3. How We Process & Utilize Collected Data

The information we compile is utilized strictly to provide, maintain, and enhance the ClubGG gaming environment, including:

  • Creating and managing your user profile and club administrator permissions.
  • Validating your age (21+) and territorial eligibility for sweepstakes tournament satellites.
  • Delivering automated hand history generation, VIP HUD statistics, and multi-table synchronization.
  • Notifying you of tournament schedule updates, satellite qualifications, and account security notifications.
  • Complying with anti-money laundering (AML) and know-your-customer (KYC) regulatory mandates.

4. Anti-Collusion & Integrity Engine Telemetry

To uphold absolute game fairness certified by BMM Testlabs, ClubGG deploys automated machine-learning heuristics. Our integrity engine monitors real-time hand decisions, bet sizing timing, multi-accounting indicators, and suspicious table interactions. This telemetry is processed solely to detect illicit automated bots, real-time assistance (RTA) software, and collusive syndicate actions.

5. Data Sharing & Third-Party Disclosure

We do not sell, rent, or trade your personal information to third-party advertisers. Information is only shared under limited circumstances:

  • Official Partners & Organizers: Event verification partners (such as the World Series of Poker / WSOP and MSPT organizers) when processing live event buy-ins and travel passports won through our platform.
  • Service Providers: Cloud infrastructure providers (AWS, Cloudflare), KYC verification providers, and anti-fraud analysts who operate under strict non-disclosure and security covenants.
  • Legal & Regulatory Authorities: Where compelled by valid subpoena, court order, or applicable statutory requirements to protect the safety and legal standing of our community.

6. Cross-Border Data Transfers

ClubGG maintains distributed cloud server nodes globally. Personal information collected within North America, Europe, or other territories may be transferred, stored, and processed securely across international borders with TLS 1.3 cryptographic protocols and Standard Contractual Clauses (SCCs).

7. Data Retention & Cryptographic Storage

We retain account data for the duration that your profile remains active. Upon account deactivation or closure, records are retained only for the period necessary to comply with legal, tax, and anti-fraud regulations. All session keys and identity tokens are stored using military-grade 256-bit AES encryption.

8. Your Statutory Data Protection Rights

Depending on your jurisdiction of residence, you possess specific legal rights regarding your information:

  • Right of Access: Request a full machine-readable copy of your personal data held in our systems.
  • Right to Rectification: Request corrections to inaccurate, outdated, or incomplete personal records.
  • Right to Erasure ("Right to Be Forgotten"): Request permanent deletion of your profile, subject to non-discretionary regulatory retention duties.
  • Right to Opt-Out: Unsubscribe from promotional announcements or marketing dispatches at any time.

9. Protection of Minors

ClubGG is strictly designed and operated for individuals aged 21 years or older (or the applicable legal age of majority in your jurisdiction). We do not knowingly solicit or collect personal information from individuals under 21. Any account discovered to have been registered by an ineligible minor will be promptly terminated and associated records expunged.

10. Contacting Our Data Protection Officer

For inquiries regarding this Privacy Policy, data subject access requests, or regulatory questions, reach out to our dedicated compliance team via the in-app support center or directly through our authenticated portal.

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