Last Update: 16.9.2024

Friends Play, and its subsidiaries (“Friends Play”, “we”, “us” or “our”), is a leading developer, publisher and marketer of interactive entertainment. This Privacy Policy explains data practices for the products, services, and websites provided by the Friends Play entities and labels listed here (“Services”). Please review this Privacy Policy carefully. Note that our data collection practices may vary based on your specific use of the Services. Additionally, the Services are governed by any other applicable terms and policies incorporated therein. This Privacy Policy serves as a supplement to any privacy disclosures provided in connection with your software product and those issued by your platform manufacturer.

This Privacy Policy does not apply to personal information that is collected from job applicants.

Notice at Collection of Personal Information: Please read the Categories of Information Collected and How We Use Personal Information and Our Legal Grounds sections for an explanation of what information we collect, and why, and the Data Rights section for information about how to exercise your privacy rights, including opting out of the sale or sharing of your personal information.

Categories of Information Collected

The type of information we collect depends on how you use the Services. Generally, we may collect the following information:

• Identifiers and Contact Information: Name, user name, nickname, postal and email address, phone number, unique IDs, mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address.

• Protected Characteristics: Age and gender.

• Commercial Information: Purchase and usage history and preferences, including gameplay information like hand history or tournament history.

• Billing Information: Payment information (credit / debit card information) and shipping address.

• Internet / Electronic Activity: Web / app browsing and gameplay information related to the Services; information about your online interaction(s) with the Services or our advertising; and details about the games and platforms you use and other information related to installed applications.

• Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls).

• Profile Inferences: Inferences made from your information and web activity to create a personalized profile that will help us identify goods and services that may be of interest to users.

• Audio / Visual Information: Account photos, images, and avatars, and gameplay recordings, and video footage.

• Sensitive Information: Exact location information (if you allow the Services to collect your location), account credentials (user name and password), and contents of communications via chat features and functionality.

How We Use Information and Our Legal Grounds

We use the information collected within Friends Play in the following ways, based on different legal reasons:

• Business Purposes: Provide the Services and support; fulfill orders and requests; improve the Services and our business; develop new products and services; improve your experience on the Services; protect the security for our users, employees, and Services; and develop internal marketing studies.

• Commercial Purposes: Market and advertise our and our partners’ products and services; send you promotional materials; and administer promotional activities or events.

We also use your information as permitted by law.

Sources of Information We Collect

How we obtain information depends on how you use the Services. We will collect information:

• you provide directly to us, such as during registration or when you contact us.

• about the games you play.

• from third-party platforms, when you play our games or access our Services with third-party accounts.

• automatically, including through cookies and other tracking technologies.

• from third parties, like advertising networks, business partners, affiliates, third party information providers, and other players.

When We Share Information

As detailed below, we share your information with:

• vendors that perform support and other services for us

• Friends Play group members

• advertising service providers and partners

• other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission)

• other users, such as when you participate in open communities or events, or information published on leaderboards

We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent’s) consent.

Public Postings

If you choose to share personal information, upload images or videos, or provide other content in public forums—such as message boards, chat rooms, comment sections, or profile pages—such information may be viewed, collected, and used by others. If your username or ID contains personally identifiable information, such as your name, this may be publicly visible on leaderboards or other areas as outlined in this Privacy Policy. Users of these public forums may be able to identify you, send you unsolicited messages, or copy and use any images, videos, or content you have shared. Please note that there is no expectation of privacy or confidentiality in any public forum. We strongly advise against sharing personal information in public forums or including it in your username or ID. You are solely responsible for any information or content you post publicly through our Services.

Data Rights

Depending on your location, you may have certain rights over your personal information, including the right to:

• Request access to or a copy of your personal information

• Request deletion of your personal information

• Request correction or modification of your personal information

• Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes

• Withdraw consent, if processing is based on consent

• Opt-out of the sale or sharing of your personal information (including targeted advertising)

• Opt-in/out of financial incentives

• Limit the use and disclosure of your sensitive personal information

You can make a data rights request in relation to your personal information here.

Manage Your Account, Communications, and Data

We provide several options for you to manage your Service account, communications you receive from us, and how we use your information. These include through the settings in your Service account; email unsubscribe and deletion tools; and opting out of interest-based ads.

Data Retention

We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

Children’s Privacy

Our Services are generally intended for a general audience, and we do not knowingly collect personal information from children under the age of 13 (or older, where applicable law provides for different protections). However, some Services may be directed to audiences of all ages, including children. For such, we may implement measures to limit the collection of personal information, including restricting data collection entirely, utilizing age-gating mechanisms that allow children to access the Services without the collection of personal information, or obtaining verifiable parental consent prior to collecting personal information from children. In the event that we become aware of the collection of personal information from a child without parental consent, we will take immediate steps to delete such information. We also encourage parents to instruct their children not to disclose personally identifiable information, such as real names, addresses, or phone numbers, without parental consent when using the Internet.

Data Security

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

International Transfers

We and our vendors and partners may process, transfer, and store information about you in connection with the Services in the United States and other countries that may not have privacy laws equivalent to the country where you reside. We take steps to apply appropriate safeguards when we transfer that information.

Other Friends Play Terms, Third-Party Terms, and Links to Other Sites

Use of our services and products may be subject to other terms and disclosures provided by us, platform manufacturers, and other partners, including: (i) the terms that accompanied your purchase; (ii) terms applicable to online Services; (iii) other terms and disclosures made available to you by us or third parties.  We are not responsible for practices on third-party sites that may be linked to the Services.

Contact Us

If you have questions about this Privacy Policy, please use https://www.bluffclub.com/user-data-deletion/ to contact our Data Protection Officer. You may also contact us or our Data Protection Officer by mail at the addresses below. Please identify your location in your message. You may also have the right to complain to a privacy authority. You may also contact us by email at [email protected].

Country: Bulgaria

Address : Sofia, Nikola Vaptsarov 25

Friends Play

For purposes of privacy laws, the data controller of your personal information is Friends Play. Depending on the Services, our labels and divisions may be considered data controllers, either together with Friends Play or by themselves. Data controller and representative information and contact details are listed here. References in this Privacy Policy to Friends Play should be interpreted as references to the applicable Friends Play entity identified as the controller of personal information for the particular Services you are using.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. As permitted by applicable law, your continued use of the Services indicates that you accept these changes.