PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE USING OUR WEBSITE OR SUBSCRIBING TO OUR SERVICES.  This Privacy Policy describes how Octopi Poker Studios, Inc. (“we” or “us”) manage(s) and process(es) personal information, on our main website www.octopipoker.ai and referral websites www.octopipoker.com, www.octopi.poker, www.octopipokerstudios.com, www.octopipokerstudios.ai, and www.octopistudios.poker (collectively the “Websites”); in providing online poker training tools through our software platform (the “Platform”);  and in managing our business and other relationships (collectively the “Services”).

We are committed to ensuring the privacy, security, and integrity of the personal information that visitors to our Websites (“Visitors) and subscribers to our Services (“Customers”) share with us or that we otherwise collect as we provide our Services.  As described more fully below, we use personal information on a very limited basis to provide our Services, and we refrain from either using web-tracking technologies or selling the personal information we collect.  

1. INFORMATION WE COLLECT

We may collect personal information directly from Visitors and Customers in the provision of our Services.

Below is a description of the different types of information we process or manage and the sources from which we collect that information:

1. Visitors:  When you contact us through the Websites, we may collect your email address and your name.

2. Customers: When you contact us, create or modify your account, and use our Services, we may collect an email address; your name; a username and password; your social media account URLs; your follower or following status on our Websites; any information you voluntarily share with us including but not limited to hand histories; comments and messages sent to other Visitors and Customers using our Services; ; your credit card information; the times, dates, and specific actions you took on the Platform; and any feedback you provide on technical issues you encounter on the Platform.  

Except for the above-listed items, we do not collect information through the Websites or Platform.

2. COOKIES AND OTHER TECHNOLOGIES

In addition to the personal information described above, we may collect personal information in the management and use of our Websites, software platform and Services.

We may collect the IP address of your computer in order to enable us to better manage Website and software platform traffic and to gather other analytics on the Websites and software platform.  

We may also use “cookies,” which are small data files placed and stored on your computer.  Cookies are used as follows:

(a)        Utility Purposes: To enable our Websites and Platform to function and manage each session use;

(b)        Recognition Purposes: To recognize you as a regular end user;

(c)        Identification Purposes: To remind us of who you are;

(d)        Traffic Measurement Purposes: To measure traffic patterns for use as a research tool to understand how our end users’ habits are similar or different from one another; and

(e)        Research Purposes: To conduct other research on our Websites and Platform.

You can set your browser to notify you when you receive a cookie, in order to give you the chance to determine whether or not to accept it.  If you do not accept cookies, some pages of the Website and Platform may not display properly.

We do not use web-based tracking technologies in our business.  If we decide to employ web-based tracking technologies in the future, we will notify you of the change and provide information about the technologies we are using, how we use those technologies, how the technologies may affect you, and what you can do to modify or control them.

3. HOW INFORMATION IS USED

We will use personal information only for the purposes disclosed at the time of collection or as otherwise set out in this Privacy Policy, unless we have your consent for another use, or unless such other use is required by law.  The purposes which we use personal information include the following:

1. Provision of Services: To provide Services to our Visitors and Customers;

2. Collect Subscription Payments: To collect subscription payments from our Customers;

3. Maintain, Update and Improve Technology: To maintain, update, and improve the Platform and Website;

4. Analyze the Data: To analyze the anonymized, aggregated data set;

5. Technical Support: To provide technical support to Customers in response to any technical issues found on the Platform or Websites;

6. Relationship Management: To manage our relationships with our Visitors and Customers;

7. Communication: To communicate with our Visitors and Customers;

8. Defense and/or Compliance: To defend our legal rights or comply with our legal obligations;

9. Necessity: For all other necessary business purposes; and

10. Legally Required: As otherwise required by law.

We do not use or process information for targeted advertising, sale, or profiling purposes.  

4. DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information only as described below:

1. Performance of Services: To our employees, contractors, and third-party services providers, only as necessary to perform the Services;

2. Compliance: To our employees, contractors, and third-party service providers, if required by law, or if we believe that the disclosure is required or necessary to protect our rights and/or comply with a judicial processing or legal process served on us;

3. Merger or Acquisition: To third-party service providers, successors, and assigns, as part of the transaction in the case of a merger, sale, or other asset transfer of our business, or if we are involved in any transaction in which we will not continue our business or will be transitioning our Services to a third party;

4. Cooperate in Anti-cheating Efforts: To third-party online gaming businesses, industry organizations, or designated monitors, only as necessary to cooperate in industry monitoring efforts to prevent cheating;

5. Legally Necessity: To our employees, contractors, and third-party service providers, only as necessary to address legal concerns or liabilities, respond to suspected illegal activity or fraud, defend against legal claims, or respond to a potential threat to the physical safety of a third party; and

6. Consent: We may share personal information with third parties upon receipt of your consent as required by law.

Except as expressly stated above, we do not disclose personal information to third parties.  

5. SHARING PERSONAL INFORMATION WITH LAW ENFORCEMENT

Please be advised that we may be required to share personal information in response to lawful requests by public authorities, including but not limited to national security or law enforcement requirements.  

6. YOUR RIGHTS AND CHOICES

You should direct all questions about how we collect and use your personal information to our Privacy Officer at privacy@octopipoker.ai.

You can add and update the personal information we have collected.  Please direct all such addition or update requests to privacy@octopipoker.ai.

You have the right to request access to or the deletion of your personal information. Please see “How to Submit a Verifiable Request” for further instructions on how to make your request.  

7. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

Depending on your state or other location of residence, you may have the following rights with respect to your personal information:

1. Disclosure: Right to request that we disclose personal information or categories of personal information that we collect, use, disclose, and sell; the purposes for which the categories of information collected by us are used; the sources of information from which we collect personal information; and the specific pieces of information we have collected on you;

2. Deletion: Right to request that we delete personal information we have collected from you;

3. Opt-Out: Right to request that we opt you out of the sale, disclosure, or processing of your personal information;

4. Opt-In: Right to opt in for sensitive personal information processing;

5. Non-Discrimination: Right to non-discrimination;

6. Correct:  Right to correct inaccurate personal information;

7. Limit:  Right to limit the use and disclosure of sensitive personal information collected about you; and

8. Automated Decision Making: Right to opt out of automated decision making.  

We make every effort to extend all of the above-stated rights to all consumers, regardless of their state or other location of residence.  

However, given the nature of our Services and business, we may be subject to certain exemptions from these rights and be unable to extend them to you in all cases.

If you submit a request and we are unable to act for one of the reasons listed above or another reason, we will advise you accordingly and provide the reason for our denial.  We will not discriminate against you because you exercise your rights.

8. CATEGORIES OF PERSONAL INFORMATION, SOURCES, USE, DISCLOSURE

The categories of personal information we have collected in the past twelve (12) months are as follows:

Category of Personal Data	Examples	How We Used It	From Whom it was Collected	Whom We Disclosed It To
Identifiers	Name Email address	To contact Visitors and confirm their placement on the waitlist for our beta release	Visitors	Service Providers
Personal Data	Name	Not applicable	Visitors	Service Providers

        

9. PROCESS USED TO VERIFY A REQUEST

If you make a request regarding the exercise of your privacy rights, you will be required to submit several pieces of information including but not limited to your name and email address. We will use this information to search our systems and determine if we have information about you.  If we are able to locate information about you, we will fulfill your request.  If we are not able to match all pieces of information you submit, we may provide you with a report that includes the categories of information we collect, use, disclose and sell.  

If you are an authorized agent, you will be required to submit your name and email address, as well as the name and email address of the person on whose behalf you are making a request.  If we are able to locate the information about the person on whose behalf you are making the request, we will fulfill your request.  As an authorized agent, you will also be required to complete a form certifying you have the right to make this request on behalf of the third party.  

10. HOW TO SUBMIT A VERIFIABLE REQUEST

You can make or submit a request related to the exercise of your privacy rights by sending an email to privacy@octopipoker.ai.

11. ALTERNATIVE FORMAT REQUESTS

If you have a physical disability you have the right to request this privacy policy in an alternative format.  To make a request for an alternative format, please submit your request to our email address at privacy@octopipoker.ai.

12. NEVADA RESIDENTS

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties.  The right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please submit your request to us by sending an email to privacy@octopipoker.ai.

13. CHILDREN’S INFORMATION

Our Services are not directed to or intended for children under the age of eighteen (18), and we do not knowingly or intentionally collect personal information from children.   If you learn that a child has provided us with personal information without their parents’ advance consent, you may contact us as provided in Section 21 below.  If we learn that we have collected any personal information in violation of applicable law, we will promptly delete such information.

14. DATA TRANSFER, STORAGE, & PROCESSING

If you are accessing our software platform or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that your personal information may be transferred to, stored, and processed in the United States.  We take steps to ensure that the service providers that we work with utilize industry best practices for maintaining data privacy and security.  

15. SECURITY

We have implemented commercially reasonable security measures and follow generally accepted industry standards to protect all personal information in our possession, which includes employing commercially reasonable administrative, physical, and technical safeguards to maintain the confidentiality and security of all personal information.  However, despite all of our efforts, no security measures are completely secure.  Although we make every effort to protect personal information, we cannot guarantee its absolute security.

16. DATA RETENTION

We delete or destroy personal information when it is no longer necessary for the purpose in which it was collected, unless we are required by law to keep it for longer.  We destroy documents containing credit card information after it is no longer needed.  We keep Customer PII records for the length of the customer relationship and for a maximum of 1 year after we cease to provide Services, unless we are otherwise required to retain your personal information for longer, in which case we will retain your personal information for only as long as we are required by applicable law.  

17. CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time at our sole discretion and without prior notice.  If we make any material amendments, we will advise you about those changes by notifying you in a prominent place on our software platform.  You should check back with us from time to time in order to confirm that there have been no significant changes.

Please note that the use of information that we gather is subject to the Privacy Policy then in effect at the time of use.  

18. CONTACT US

If you have any questions or concerns over this Privacy Policy or if you need further information regarding the access to your personal information, or how your personal information is used, you may contact us at: privacy@octopipoker.ai

19. CORPORATE INFORMATION

Octopi Poker Studios, Inc. is incorporated in Delaware and has a registered address in the state of Nevada.  

20. EFFECTIVE DATE

This Privacy Policy was last modified on September 4, 2023.