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APT Privacy Policy

Identity of Data Controller. For the purposes of this privacy policy (“Privacy Policy”), the “data controller” (i.e. the person responsible for the capture, storage and use of your personal information) shall mean, as may be applicable depending on the location in which the Event (defined below) is held, APT Events (collectively the “Event Company”, “we”, “our” or “us”) or a subsidiary of the Event Company, the holding company of the Event Company and any subsidiary of any such holding company.

References to “Tournament” hereunder shall mean any live poker tournaments and cash games (each a “Tournament”) forming part of any APT live events, such as but not limited to the Asian Poker Tour.

Our Commitment to Our Players’ Privacy. We are committed to maintaining the confidentiality of the personal information collected by us, utilising information security technology and procedures, to fulfil the requirements of the relevant gambling regulatory authorities.

Purpose of this Privacy Policy. The purpose of this Privacy Policy is to enable you to understand how we collect, store, use and safeguard your personal information and to explain your rights in relation to that information and its use.

What do the Capitalised Terms Mean? Unless we give them a specific meaning in this Privacy Policy, capitalised terms shall have the meaning given to them in the APT Terms and Conditions which takes precedence over any conflicting provision of this Privacy Policy.

Your Agreement to the Privacy Policy

1. Agreement: By using APT services or attending an Event, you (“User” or “you”) agree to the terms of this Privacy Policy as may be amended by us from time to time, save that we will ask you separately, when you provide us with your details whether you consent to receiving promotional communications from: (a) us; and also (b) from third party providers of goods and services with whom we may share your details. Amendments: We reserve the right to amend this Privacy Policy from time to time. Amendment will come into effect immediately upon such change being notified on the APT site (“Site"). We therefore encourage you to visit this Privacy Policy from time to time to make sure that you are aware of the current version and any changes that we may make. 

What information is collected and for what purpose

2. Registration Details: As part of the process to open an APT Account, use of the APT System and to allow us to provide our Services to you, we will ask you to provide us with certain personal information, including but not limited to your name, date of birth, email address, country of residence and nationality as well as certification that you are at least 18 years old or older in jurisdictions in which the Event is held where the minimum age for attendance is greater than 18. The name you register with us must be your own name. In addition, it is important that you complete the account details with valid information, since it will be used in the course of verifying your identity and for the other purposes described in this Privacy Policy. You must advise us of any relevant changes to your personal information as provided to us and we do not accept liability for any harm that you may suffer as a result of you failing to notify us of any changes to the personal information that you have provided to us. Data Retention: We retain your personal information for as long as necessary for the purposes set out in this Privacy Policy. We do not collect any more personal information from our users than is necessary for our purposes and our data management policies include the deletion of any personal information we no longer required. Purposes: We, members of our Group of companies, our affiliates and third parties providing services to us or to you on our behalf will use your personal information for the purpose of conducting our business and enabling your use of the APT System and/or your attendance and participation at an Event. Specifically, this includes the following purposes, but we also reserve the right to use your personal information for any other purposes that are reasonably ancillary to the business of sponsoring, hosting, administering or organising Events:

  • to confirm financial transactions
  • to assess your gambling activity for responsible gaming purposes
  • to provide the APT Services to you
  • identification, verification and vetting purposes
  • statistical analysis and research
  • research and development
  • marketing, market research, customer surveys and customer profiling
  • data analysis
  • to comply with licensing and regulatory requirements
  • to combat against security risks and fraudulent activity.
Conditions for Processing Personal Information

3. Conditions: We will process your personal information for a variety of reasons, each of which is prescribed by relevant data protection laws.

Consent

Our processing of your personal information will primarily be necessary for us to provide you with the services. On occasion we may ask for your consent to processing personal information in a discrete manner, in this instance your personal information will be processed in accordance with such consent, and you will be able to withdraw this consent in writing at any time. By way of example, your consent will be needed to send you marketing and promotional communications.

Fulfilment of a contract, compliance with a legal obligation.

It may also be necessary for us to process your personal information where it is necessary for the performance of a contract (such as the APT Terms and Conditions) or in order for us to comply with our various legal and/or regulatory responsibilities, including, but not limited to, complying with the conditions of applicable licences whether held by us or some other third party in whose venue the Event is held.



Legitimate interests 

Finally, we may also process your personal information where we deem such processing to be in our (or a third party's) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your personal information to companies in our Group following a restructure or for internal administrative purposes; (ii) where we identify certain companies that can offer you additional benefits to our services or provide us with valuable information about your use of our services; (iii) detection and retention of information pertaining to those with responsible gambling issues; (iv) safeguarding the integrity of our Events by combating, reporting and sharing information related to fraud, illegal activity or identity theft; (v) adhering to regulatory and statutory requirements; (vi) devising a tailored reward scheme for players.

Information Sharing, Disclosures and Recipients

4. Specific Disclosures. We may disclose your personal information as follows:

  • to any recipient if required to do so by law or by regulatory authority;
  • to any regulatory body or licensing body or authority;
  • to third parties for the purposes of settling or making payments in relation to any winnings you may be entitled to from participating in an Event; 
  • to third parties who provide services to us or on our behalf;
  • to third parties for marketing purposes, provided you have consented or not objected, as the case may be;
  • to any third party that purchases us or our business or any part of us or our business;
  • if we believe in good faith that such action is necessary: i. to comply with any law or comply with legal process served on us; ii. to protect and defend our rights or property;
  • with your consent; or
  • for the purposes of disaster recovery.
Confidentiality

5. What Do We Do? We have undertaken substantial efforts to protect the confidentiality of the identity, preferences and other information we have collected about individual Users and we will not knowingly allow access to this information to anyone outside of our Group, other than to User themselves or as described in this Privacy Policy. We have made a substantial investment in our server, database, backup, firewall and encryption technologies to protect the information that we collect and process. These technologies are deployed as part of state of the art security architecture.



What Can You Do? You should also play your part in protecting your personal information. Any Login Credentials are confidential and you are obliged to keep your Login Credentials secret and confidential at all times and to use your best efforts to protect their secrecy and confidentiality.

Limits of Confidentiality

6. Legally Required Disclosures. We may be required, under certain circumstances, to disclose personally identifiable information about our Users and we may not be permitted to inform you that we have done so. We will use reasonable endeavours to limit such disclosure to the following: (a) where we believe in good faith that we are required to do so in response to a subpoena, warrant or other legal process or obligation upon us; or (b) where reasonably necessary to identify, contact or bring legal action against persons or entities to preserve and/or enforce our rights. Further, we can, and you authorise us to, disclose your User identification, name, date of birth, street address, city, county, post code, country, phone number, email, account activity, to our third party agents or official government bodies as we, in our sole discretion, believe necessary or appropriate in connection with an investigation of money-laundering, fraud, intellectual property infringement, piracy or other unlawful activity or activity that may expose us to legal liability.

Legally Required Disclosures

7. Group Marketing. We may use your email address and phone number for the purpose of providing you with news, promotions and other marketing offers from us. If you no longer wish to receive these promotional communications, newsletters and marketing offers, you may opt-out of receiving them either when you register with us initially, or subsequently by following the ‘opt-out’ instructions included in each communication. You are also, in addition, entitled at any time to notify us that you do not wish to receive any promotional communications from us and you may do this by emailing us at Support.

8. Third Party Offers of Goods and Services. Where you have provided us with your consent to do so, we may also share your email address and phone number with third parties so that they may send you offers of their goods and services. If you request not to receive these offers we will remove your details from our marketing distribution lists and from any future lists we may share with our marketing partners. However, you will need to unsubscribe separately from marketing communications sent by partners who have received your contact details from us prior to your request to be removed from these lists.

Your Rights in Relation to Your Information

9. Right to request information about you.  We aim to keep our information about you as accurate as possible. You can contact us at any time to review, change, obtain a copy of your information or have your details altered or corrected in accordance with your rights under Applicable Law. In this event we may require evidence of and be satisfied as to your identity before we take any requested action. To contact us so as to exercise any of your rights as set out in this Clause, please email Support. We may, in certain circumstances, levy a small charge to cover the cost of administration regarding any request made by you in this regard or deal with your query in accordance with Applicable Law.    

10. Additional Rights.  You have the following rights in relation to your personal data:

  • a right to object to processing that is likely to cause or is causing damage or distress;
  • a right to object to decisions being taken by automated means;
  • a right in certain circumstances to have inaccurate personal data rectified, blocked, erased or destroyed; and
  • a right to claim compensation for damages caused by a breach of data protection law.

 If you are unsure about your rights or are concerned about how your personal information may be processed you should contact the relevant Data Protection Authority. If you contact us in relation to your rights we will do our best to accommodate your request or objection. Please note, however, that not all rights are absolute. 

Cookies

11. Cookies are text-only strings of information that are downloaded to your personal desktop, laptop computer or mobile device (each a “Device") when you visit a website. They are then sent back to the originating website on each subsequent visit, or to another website that recognises those cookies. 

 Cookies are very useful and are used for many different purposes. These include allowing you to navigate between pages efficiently, remembering your preferences, and generally improving user experience. Sometimes cookies are used to help ensure that adverts you see online are relevant to you and your interests. We use cookies in order to track referrals to our Sites, to remember your preferences, and to generate anonymised statistical data, which we use to improve the user experience on our Sites. We also use cookies to measure the effectiveness of our advertising campaigns, to limit the number of times you see an advertisement, to remember that you have visited a website, and to provide advertisements that are more relevant to your interests.

Further Information

12. We are happy to provide you with further information on how we protect and use your personal information. Please contact Support.