Paybackgames recognizes that your privacy is serious business. Since we believe you have the right to keep personally identifiable information private,
we also want you to understand what personal information we collect and how we use it.
explains how we manage and safeguard personal information in the course of operating our business. We are dedicated to adhering to the following
principles that relate to the collection, use, retention and disclosure of Personal Information (defined below).
Paybackgames is accountable for all Personal Information in its control. This includes information under the direct control of Paybackgames, as well as
Personal Information that Paybackgames may transfer to its affiliates or to third party service providers for servicing, processing, storage or other
purposes that facilitate Paybackgames's business operations. Paybackgames will use contractual or other measures to require third parties that
process information or provide services on our behalf to maintain a level of privacy protection comparable to our own practices. By way of example,
Paybackgames uses third parties such as payment processing service providers, printing and mailing services, data storage and destruction facilities
and outsourced technology support service providers.
Numerous individuals within Paybackgames are responsible for the day-to-day collection and processing of Personal Information, including technical
and administration personnel trained for this purpose. However, Paybackgames has a designated Privacy Officer who is responsible for
manner in which Paybackgames handles or manages Personal Information should be directed to our Privacy Officer who can be reached as follows:
Paybackgames Privacy Officer
2. COLLECTION OF INFORMATION
Paybackgames collects information from its customers through various websites it operates. Information is collected on the sites when a user creates a
user account, through contact forms and surveys, and through his or her interaction with the sites (for example, information about which games you
play, player rating information and player game statistics). Individuals may also disclose information about themselves when they use features on the
sites such as user forums, the "Invite Your Friends / Tell-A-Friend" feature or when they contact Customer Care. We collect the names and e-mail
addresses of individuals' friends when that individual uses the "Invite Your Friends / Tell-A-Friend" feature on the sites. We may also require you to
provide additional personal information, such as a copy of a driver's license, bank statement or utility bill in the process of address and identity
verification to confirm your eligibility to participate on our sites. Address and identity verification are a mandatory part of the withdrawal process.
A. What information is collected through the sites?
Types of Information
We collect two types of information from you when you visit the sites: information that does not identify you personally ("Non-Personal Information"),
and information that does identify you personally ("Personal Information").
(i) Non-Personal Information
Our Web servers may automatically record certain technical information related to your visit to the sites. This information is anonymous and does not
identify you personally. It includes things such as: the Internet domain for your Internet service provider; the Internet Protocol (IP) address of the
computer accessing the sites; the address of the last webpage that you visited prior to clicking through to the sites; the browser used and the type of
computer operating system that your computer is using; information about your computer hardware; the date and time that you visited the sites; and a
record of which pages you viewed while you were visiting the sites. Other information such as demographic information which does not identify an
individual is also considered Non-Personal Information. Gamer Information (described below) is also considered Non- Personal Information.
(ii) Personal Information
When you create a free, basic user account (a "Basic Account"), you consent to our collection of Personal Information including your email address. If
you choose to create an account which will allow you to enter cash games and tournaments (a "Real Money Account"), you will also be required to
provide additional information such as your name, gender, date of birth and mailing address. If you choose to make a deposit into your Real Money
Account, you will also be required to provide information relevant to your payment method (for example your credit card number and expiry date)
As noted above, the sites also provide you with certain ways to voluntarily give us your Personal Information. You may also use the features of the
sites to invite others to create Basic Accounts or Real Money Accounts. We may also collect Personal Information about you if you choose to send us
an email message using links contained on the sites. You may also disclose Personal Information when you post content to user forums on the sites or
when you contact Paybackgames's Customer Care representatives via live chat or email. Certain information about your activity on the sites is not itself
Personal Information (for example, information about your game play preferences) but may be combined with Personal Information by linking it to your
account information. For example, the following information ("Gamer Information") is publicly displayed on the sites and is not considered Personal
· your UserName or Alias
· your Skill Rating
· your Top Players Ranking (if any) and your Paybackgames Points balance
· your scores in games and tournaments
· your gaming preferences or your personal motto
· summary of your gaming activity, including when you joined, the number of games that you have played
· winnings from games and tournaments
· any personal information you chose to disclose in a chat window or Forums on the sites
We may include footage of game play in promotional materials such as trailers which may be displayed on the sites, or on websites run by other parties
including those of our marketing partners. For example, we may display "play of the week", "highlight reel" or similar content. This content may also
include the use of Gamer Information.
In order to provide a fair playing environment for all users and to protect the integrity of the sites, we also collect Personal Information which we use to
investigate complaints of cheating or behavior that we believe may be contrary to the Terms of Service, including the Code of Conduct. This may
include screenshots of players' computer desktops or footage of in-game play.
In addition to collecting Personal Information directly from visitors to the sites, we may also collect Personal Information from third parties such as
marketing partners who have been provided permission to share that information with us.
When you download any Paybackgames Widget or a Paybackgames application, you may also be provided with the opportunity to download software
provided by parties other than Paybackgames (for example, Xfire communications). Please note that when you install and use software provided by
B. What are "cookies" and how do the sites use them?
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your
computer. The cookie identifies your browser but will not let a website know any Personal Information about you, such as your name or address. These
files are then used by such websites as a kind of electronic identification tag when users revisit that site. Since cookies are only text files, they cannot
run on your computer, search your computer for other information or transmit any information to anyone.
personalize your settings and preferences. Most browsers are initially set up to accept cookies. If you wish, you can change your browser settings
either to notify you when you have received a cookie, or to refuse to accept cookies.
C. Personal Information about Children
Our sites comply with the Children's Online Privacy Protection Act ("COPPA"). We do not allow people less than 18 years of age to create accounts on
the site and we do not knowingly collect Personal Information from people under 18 years of age through our sites. In addition, in the event that a
visitor to our sites identifies him or her as a person under the age of 18, we will not collect, store or use any Personal Information of such individual. In
the event that we receive Personal Information that we discover was provided by a person under the age of 18, we will promptly delete all such
Personal Information not required for continuing business purposes.
D. Limits to Collecting Personal Information
We limit the type of mandatory information collected by us: we collect only the Personal Information that is required to operate our sites, ensure
compliance with our Terms and Conditions of use and manage our relationship with our customers, including the uses described in the following
paragraphs under the heading "Use and Disclosure of Personal Information", below.
3. USE AND DISCLOSURE OF PERSONAL INFORMATION
A. Internal Uses
We collect Personal Information to operate our sites including as required to open and maintain customer accounts with us, to contact customers
regarding updates of the sites, their account status, new products and services and upcoming events, to collect subscription and entry fees from users,
to process payments, to prevent fraud and to protect the integrity of the sites and to deliver prizes to users. We use your date of birth and address
information to ensure that you comply with our Terms of Service and are permitted to create an account where you reside. We also collect Personal
Information to facilitate a fair game play environment and for fraud prevention. We may also, but do not have any obligation to, use Personal
Information to contact customers regarding changes to the Terms of Service for the sites and any other policies or agreements relevant to the sites. If
an individual uses the "Invite Your Friends / Tell-A-Friend" feature, we will use the name and e-mail address that that individual provides to invite his or
her friend to create a user account.
In addition to the uses above, we use Personal Information for feedback and marketing purposes, to promote goods and services we believe you may
be interested in, to provide a product or service requested by you, to notify you of changes to our products and services, and to customize and improve
the content and layout of the sites. When you create your account, you can customize these preferences. If you wish to change your account
preferences to modify the ways that we contact you, please contact Customer Care or use the "unsubscribe" link included in all email messages sent
on our behalf.
B. Transfers to third parties
In addition to sharing information between Paybackgames entities for the purposes above, in order to fulfill such purposes and to better serve our
customers, we may transfer Personal Information to third parties who are legally or contractually obligated to keep such information private. For
example, as described above, Paybackgames uses third parties such as payment processing service providers, printing and mailing services, data
storage and destruction facilities and outsourced technology support service providers. Third parties to whom information is provided may be located in
the United States, Canada or elsewhere.
C. Disclosures to third parties
In addition to transfers of Personal Information, we may also disclose any Personal Information you provide us to third parties such as marketing
partners who provide products, information or services you have expressly requested and which we believe you may be interested in purchasing or
obtaining. In doing so, we will make reasonable efforts to ensure that these third parties only use the Personal Information for our stated purposes and
provide a method of opting out from receiving future communications from such parties, but we shall not be responsible for their handling or
dissemination practices with respect to Personal Information. If you wish to change your account preferences to not receive information from such third
parties, please contact Customer Care or use the "unsubscribe" link included in email messages sent by such parties. We may also disclose Non-
Personal Information to our business partners.
We may also disclose Personal Information to a third party pursuant to a subpoena, other form of legal process or request on behalf of any local,
provincial, state, or federal governmental department or agency to investigate, prevent, or take action regarding illegal activities, suspected fraud,
situations involving potential threats to the physical safety of any person, or as otherwise permitted or required by law.
4. OBTAINING CONSENT
In most cases, when we do collect Personal Information directly from an individual, the individual provides us with the information required for us to
effectively provide our business services, and as such, consent to the collection and use of Personal Information will be implied. If we choose to use
Personal Information already in our possession for a purpose that was not identified at the time we initially collected the information, we will seek the
consent of the affected individuals before using this information for the new purpose. Please note that if the new purpose is required or permitted by
law, Paybackgames is not required to seek the consent of the affected individuals and may not do so. Individuals may withdraw consent to the
collection, use and disclosure of their Personal Information at any time, subject to certain restrictions set out in applicable privacy legislation, but by
doing so may be unable to utilize the services and products offered on the sites by Paybackgames. When an individual uses the "Invite Your Friends /
Tell-A-Friend" feature, we rely on that individual to obtain the consent of their friend to allow us to use that information to invite them to create a user
5. MANAGEMENT OF PERSONAL INFORMATION
Paybackgames has policies and procedures as to how long it retains information that it collects. Personal Information that is no longer required to fulfill
the purposes identified when the information was collected is either destroyed, erased or rendered anonymous to prevent unauthorized parties from
gaining access to the information. We retain Personal Information received from third parties in accordance with our legal and contractual obligations.
Personal Information included in computer databases is typically stored in a secure data center with an extra copy of the data stored at an alternate
location of equal security to ensure that we will be able to retrieve the data even in the event of a disaster. These computer databases may be located
in Canada, the United States or elsewhere in the world. From time to time, we may transfer Personal Information stored in these databases (as
party service providers such as data storage companies, computer security specialists, database technicians or corporate affiliates of Paybackgames
may have remote access to Personal Information in our custody, but we use contractual and other safeguards to ensure that Personal Information
transferred to such parties is provided with a comparable level of protection as Paybackgames provides, regardless of the format in which the
Paybackgames has implemented a variety of security safeguards to protect Personal Information in our control against loss, theft, misuse and
interception by third parties. These safeguards include organizational, technical and physical measures designed to protect information from
unauthorized access, disclosure, copying, use or modification. Among the steps taken are:
· premises security;
· restricted file access to Personal Information;
· technology safeguards, including security software, firewalls to prevent hacking and other unauthorized computer access; and
· Internal password and security policies.
6. ACCURACY AND CURRENCY OF PERSONAL INFORMATION
Paybackgames is committed to open and fair privacy practices which comply with applicable privacy legislation.
Any individual may request access to their Personal Information held by Paybackgames by contacting Paybackgames's Privacy Officer in writing. After
receiving such a request, our Privacy Officer shall inform the individual of the existence, use and disclosure of their Personal Information and shall
allow the individual to access such information.
In certain circumstances, access to Personal Information may be denied. If we deny an individual's request for access to their Personal Information, we
will advise such individual in writing of the reason for the refusal and they may then challenge our decision.
Where Personal Information is used on an on-going basis, Paybackgames undertakes to correct any information that is shown to be inaccurate,
incomplete or not up to date. Otherwise, Paybackgames does not routinely update Personal Information unless it is necessary to fulfill the purposes for
which the information is collected. Paybackgames must be advised, by the individual to whom the information relates, of any correction to be made to
their Personal Information.
Upon notification from an individual of their desire to have any or all of their Personal Information in our records deleted or destroyed, Paybackgames
may undertake to delete or destroy all such information to the extent that retention of such information is not required by law, or for any other lawful
purpose, such as the investigation of claims or the defense of an action. In the event that an individual wishes to challenge Paybackgames's
compliance with any of these principles, they can contact Paybackgames's Privacy Officer using the contact information set out above. If
Paybackgames finds a complaint to be justified, appropriate measures will be taken, including, if necessary, amending our policies and practices.