Effective date: January 1, 2013

Privacy Policy

Combay, Inc. (“Mega Poker”) provides this Privacy Policy (“Policy”) to inform you of our guidelines and practices regarding the collection, use and disclosure of personal information we receive from users of our games and related services provided to you through our web site, social networking web sites or any mobile versions thereof (“Services”).

Definitions

Unless otherwise defined, terms used in this Policy have the same meanings as in our Terms of Service (“Terms”). As used in this Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

Scope

This Policy is applicable only to information we collect through your use of the Services.

Acceptance

By using the Services, you agree to this Policy. If you do not agree to this Policy, please do not use the Services.

Notification of Changes

We reserve the right to modify this Policy at any time and for any reason. We will notify you of any significant or material changes by posting the new Policy online. We advise you to consult this Policy regularly for any updates or changes. Your continued use of the Services signifies your acceptance of any changes we may make to the Policy.

International Transfer of Data

Mega Poker stores and maintains its data on servers located in the United States. If you are located outside the United States and choose to provide information to Mega Poker, we will transfer your personal information to the United States and process it there. By using our Services, you acknowledge that information may be transferred to (and stored and maintained on) computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may be less protective than those in your jurisdiction, and your submission of such information represents your agreement to such transfer.

Information We Receive

Our principal goals in collecting information are to provide and improve our Services, and to enable users to enjoy and easily navigate the Services. When you interact with the Services, we collect and store user information as described below.

Information You Provide

Users provide Mega Poker with information by using the Services. When you use any of our Services, the information you allow Mega Poker access to is determined by the privacy settings you establish for your account or mobile device. To review or change these settings, you must change the privacy settings for your account. In connection with your use of the Services, we may ask you for personally- identifying information which can be used to contact or identify you. This may include your:
• first and last name
• password (and similar information that helps us maintain security in account access)
• date of birth (to verify the age of and/or better understand the demographics of our users)
• contact information (which may include your email address and/ or phone number)
• Facebook user name, profile picture, and friend list geographical data
• billing information (which includes your credit card information, home and/or business postal addresses)
We also may retain other non-identifying information you provide as part of the administration and personalization of your account. This includes, but is not limited to, your:
• zip code
• gender
• individual preferences and settings

Information We Collect When You Interact With the Services

When you use the Services, our servers automatically record certain technical information that your browser sends whenever you visit a website and usage statistics about your interactions with our Services (“technical and usage data”). This includes, but is not limited to:
• your computer’s Internet Protocol (“IP”) address
• the type of browser used to access the Services
• the webpage you were visiting before you came to the Services
• time you spent on the Services
• date and time of access, and other statistics
We collect this information through the use of server log files and cookies (a small data file stored on your computer’s hard disk). We use persistent cookies to save your registration ID and login information to facilitate future logins to the Services. We use session ID cookies (cookies which are deleted from your computer when you log off from the Services and then close your browser) to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage and web traffic routing on the Services. We may associate this information with your personally-identifying information for our internal use.
You can set your browser to remove, block, or create a prompt to accept cookies. If you disable cookies, you may lose some features or functionalities of the Services, as our cookies are necessary to recognize you and enable your activities on the Services.

Phishing

Identity theft and the practice of “phishing” is of great concern to us, and safeguarding your information to help protect you from identity theft is a top priority. Mega Poker does not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, please visit the Federal Trade Commission’s website (http://www.ftc.gov/).

How We Use Your Information

Mega Poker uses the information it collects about you to provide a secure, efficient and customized experience every time you use our Services. Below are some details on how we use each type of user information:
We use the personally-identifying information you have provided to us (sometimes in conjunction with non-identifying information) mainly to:
• facilitate and improve use of the Services
• complete your transactions
• provide technical support and respond to user inquiries
• prevent fraud or potentially illegal activities and enforce the Terms
• resolve disputes, collect fees, and troubleshoot problems
• identify and suggest connections with other users of the Services
• solicit input and feedback to improve our products and services and customize your user experience
• contact and inform users about new products or promotional offers
• provide newsletters, marketing or promotional materials and other information that may be of interest to you
When we take some non-identifying information about you (e.g. your zip code) and combine it with other identifiers (e.g. your street address) in a way that allows you to be personally identified, it is considered a part of your personally-identifying information. But when taken alone or combined only with other non-identifying information (e.g. your viewing preferences) the same pieces of information are considered non-identifying information.
We may combine some of your personally-identifying information with non-identifying information, and aggregate it with information collected from other users to analyze how our Services. We do this to improve the quality of the Services and provide you with a better experience. We may also use the combined information without aggregating it to serve you personally (e.g. to deliver a product to you according to your preferences or restrictions).
We use the technical and usage data we collect to monitor and analyze use of the Services, for their technical administration, to increase their functionality and user- friendliness and better tailor them to our users’ needs. For example, some of this information is collected so that when you visit the Services again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this data to verify that visitors to the Services meet the criteria required to process their requests.
We do not treat technical and usage data as personally-identifying information or use it in association with other personal information, though we may aggregate, analyze and evaluate the data for the same purposes as we use other non-identifying information.

How We Share Information

We may share your information with third parties other than Mega Poker when we believe that sharing is permitted by you, reasonably necessary to offer our services, or when legally required to do so. We direct all third parties to maintain the confidentiality of the information disclosed to them, and not to use your information for any purpose other than to provide services on Mega Poker’ behalf.

1. Mega Poker Users

When you join the Services, other users may see your username and the other information about you. We encourage users to think carefully about what personal information they disclose in their profile pages. We may display your personal information in your profile page and elsewhere in connection with the Services. Any information you choose to provide should reflect how much you want other users to know about you. We recommend that you choose a username is that not your real name to protect your anonymity and sensitive information.

2. Industry Analysis of User Metrics

We may share aggregated data that includes your personal information, non-identifying information and technical and usage data with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services.

3. Service Providers

We may engage third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform tasks (which include, but are not limited to, maintenance services, database management, web analytics and improvement of the Services) or to assist us in analyzing how our Services are used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may also provide personal information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.

4. Compliance with Law Enforcement

We will disclose any information about you to government or law enforcement officials or private parties that we, at our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including, but not limited to, court orders, search warrants, and subpoenas), to protect the rights and property of MegaPoker or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

5. Business Transfers

Mega Poker may sell, transfer or otherwise share some or all of its assets, including your personal information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. If material changes to Mega Poker’ privacy practices occur as a result of a business transition, we will notify our users of the business transition prior to transferring your personal information by updating this Policy online to reflect the changes.

How You Can Change or Remove Information

If you would like Mega Poker to delete the data we have collected about you that we have received through Facebook, please contact us with your request to do so at privacy@combay.com. However, if your information is entirely deleted your account may become deactivated, and you will no longer have access to the Services.

How We Protect Information

Mega Poker is committed to safeguarding your information. While we employ administrative, physical and electronic measures designed to protect your information from unauthorized access once we have received it, we cannot guarantee security in the transmission of data. We will make any legally mandated disclosures of breaches in the security, confidentiality, or integrity of your electronically stored unencrypted “personal data” (as defined in pertinent state statutes on security breach statements) to you by conspicuous posting on the Services without unreasonable delay in the most practical time possible subject to (i) the legitimate needs of law enforcement or (ii) any measures required to determine the scope of the breach and restore the satisfactory integrity of the data system.

Links to Advertisers and Other Third Party Sites

The Services may contain links to advertising or other websites. If you choose to click on a banner ad or other type of advertisement, or click on another third party link, you will leave our site and be directed to that third party’s website. The fact that Mega Poker may provide a link to a website or display a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. Mega Poker does not exercise control over third party websites, and therefore cannot accept responsibility for their actions regarding your personal information. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. You should read the privacy policies or statements of the other websites you visit before submitting any personal information.

Our Policy Toward Children

Our Services are not directed to children under the age of 13. Mega Poker does not knowingly collect personally identifiable information from children under the age of 13, and children under the age of 13 should not use our Services at any time. If Mega Poker becomes aware that it has unintentionally gathered personal information about a child under 13, we will take reasonable measures to promptly delete such information from our files.

If you have any questions about this Policy, please contact Mega Poker at privacy@combay.com.