In the following, we, REEL Germany Limited, hereby inform you about how your personal data is collected and processed as a result of using our websites sh.pokerstars.de and sh.pokerstarsvegas.de (collectively, the "Site"). Personal data are all data that identify you personally or relate to you in person, including, where applicable, with the help of other information or resources, which we use at our general discretion based on a cost/benefit analysis to identify players, e.g. name, address, email addresses, user behavior.
Unless we give them a specific meaning in this Privacy Policy, capitalized terms shall have the meaning given to them in our End User License Agreement.
The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is REEL Germany Limited, Villa Seminia, 8, Sir Temi Zammit Avenue, Ta' Xbiex, XBX 1011, Malta, registration number C54851, ("REEL Germany"). Alternatively, we can be contacted via Support.
Where the terms "PokerStars" or "PokerStars Vegas" or "we" or "us" are used in this Privacy Policy, they refer to REEL Germany. References to "Group" mean the group companies that are controlled, directly or indirectly, by Flutter Entertainment Plc. Please note, your personal data may be shared within the Group for the purposes set out in this Privacy Policy (as well as third parties that supply services to the Group in order to fulfil such purposes).
The Data Protection Officer of REEL Germany can be contacted here.
Our commitment to protect our player's data. We are the owner and operator of the Site. We are committed to maintaining the confidentiality of the personal data collected by us, utilizing 'best in class' information security technology and procedures, all in accordance with European Union standards of data protection and the requirements of our 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 data and to explain your rights in relation to that information and its use.
Our legal obligations. When processing your personal data, we will comply with the provisions of GDPR and the German Federal Data Protection Act (BDSG), applicable to our German license through which you access and use our Service (collectively "Applicable Law"). Your personal data may also be processed by us or transferred to other members of our group of companies, our affiliates, agents and third parties providing services to us, in jurisdictions outside the European Economic Area. In this case, we will comply with the provisions of GDPR which guarantee that personal data will only be transferred to such jurisdictions that demonstrably have a level of protection comparable with GDPR.
(1) When internet users visit the Site purely for information purposes, in other words without registering or giving us information in any other way, we only collect the personal data transmitted to our servers by their browser. If you would like to view our Site, we collect the following data required by us for technical purposes in order to show you our Site and guarantee stability and security:
(2) The data is erased again as soon as you leave our Site. The legal basis for this processing is set out in Art. 6 (1) sentence 1 letter f GDPR. Our legitimate interest is based on the aforementioned purpose of displaying our Site and guaranteeing stability and security.
(1) You can contact our Support at any time. This is possible even if you haven't registered.
(2) When making contact via email, we receive:
If you have a player account with us, we would also ask that you inform us of your Stars ID when getting in touch.
In some cases, we also ask you to provide additional proof of your identity so we can check whether the enquiry genuinely comes from you. Where this proves necessary, we will notify you accordingly and explain in detail what proof of identity we require from you.
(3) To contact us via our customer service form under the "Help" menu on PokerStars DESH Software, you need to be a registered player. As a result, we will have access to the following personal data:
We will send our response to contact made in this way to the email address registered on your Stars Account.
(4) The collection and processing of personal data described in the preceding paragraphs is carried out in accordance with Art. 6 (1) sentence 1 letter b) GDPR to enable us to handle your request. Your messages will be erased in accordance with the erasure periods described in Section 9.
(1) In order to play the games that we offer, you need to register with us by giving your country of residence, email address, a self-defined username and password. You do not need to use your real name, a pseudonym is fine.
(2) In addition, we also have an obligation for money-laundering purposes to collect the following personal data from you:
(3) We also need to verify these data (pursuant to Maltese law in the event of the accumulated collection of €2,330.00 (or the equivalent in the player's selected currency), pursuant to German law prior to opening the Stars Account) and therefore have an obligation to request the following documents from you which may contain additional personal data (e.g. size and/or eye color):
(4) We may also request the submission of documents for identity purposes including a photo of the User together with his or her identification document before the Stars Account is credited with a bonus.
(5) We also request your mobile number for verification purposes. We use this in particular in such cases for verification calls to check that the Stars Account actually belongs to the person indicated where we may have a suspicion that this is not the case.
(6) In addition, for the purposes of protecting under-aged persons (prohibition from gaming) you need to confirm at registration that you are of legal age. We verify this using the date of birth you provide and the copy of your ID document.
(7) When processing payments – i.e. deposits and withdrawals on your Stars Account – we will also ask you at the point of registration for certain payment data, namely the name of your bank, its country of origin, IBAN and BIC. If you select VISA or MasterCard as the payment method, then we will also collect your credit card number, expiry date and CVC, although the latter is not saved but merely used for verification purposes.
(8) While playing our games, we will monitor your payment and gaming behavior and any changes in your Stars Account settings with the aim of preventing money laundering and the financing of terrorism plus fraud and manipulation. The legal basis for this is set out in Art. 6 (1) sentence 1 letters b), c) and e) GDPR regarding the fulfilment of contractual obligations, compliance with legal provisions and the performance of tasks in the public interest. To this end, we will collect the following personal data:
We also use the data mentioned above, or some of these data, to improve and further develop our offers. In addition, we use all or some of the aforementioned data to guarantee network and information security – including preventing unauthorized access to our electronic communication network. Both of these fall within our legitimate interests. The legal basis for this is therefore set out in Art. 6 (1) sentence 1 letter f) GDPR.
(9) The collection and processing of data as described above is carried out and is required for the purposes described previously and summarized again below and for the purposes relating to the corresponding legal basis:
Note that if you self-exclude yourself on our Site for responsible gaming reasons, such restrictions may be extended to or be replicated on accounts that you may hold with other Group companies. We will share information about your self-excluded status within the Group in order to help with the identification of individuals who may be at risk of problem gambling and may take suitable action where necessary.
(10) For information on the processing of your personal data on the grounds of player protection to establish a financial limit, time-out or self-exclusion, please visit our Responsible Gaming page. This processing is carried out at your request, in other words with your consent pursuant to Art. 6 (1) sentence 1 letter a) GDPR.
(11) Finally, we use your email address and telephone number to send you direct publicity for our services by electronic means, in particular for current interesting offers or bonus programs. The legal basis for this is set out in Art. 6 (1) letter f) GDPR. You can object to this use of your email address and telephone number for marketing purposes at any time, for example by pressing on the "unsubscribe" link at the end of each newsletter.
(12) We can link your personal data, collected in accordance with this Privacy Policy as a result of your use of our Service, with other data collected in connection with the use of other services offered by other companies within the Group and with all products either of a complementary or supplementary nature, including mobile and social networking services. We process this linked data pursuant to this Privacy Policy and only use them for the purposes described herein.
(13) The erasure of your personal data collected for the aforementioned purposes shall be carried out in accordance with the erasure periods set out in Section 9.
(1) Consent to the collection of location data for mobile gaming
If you would like to use our services on a mobile device, you need to consent to our use of location data and other operating system data that might be recorded by your device in order to determine your geographic location. If you do not permit access to your location data, we cannot provide the services on your mobile device.
(2) Obtaining consent for marketing purposes
The above notwithstanding, we will ask separately for consent to use your personal data for marketing purposes, in particular for:
(3) Right to withdraw
You have the right to withdraw your consents to the uses described above at any time, pursuant to Art. 7 (3) GDPR, by sending a blank email with the word "Remove" in the subject line to Support. In this case, we will remove your data from our marketing distribution lists and, above all, from all future lists we may send to our marketing partners. We will also inform all third parties to whom we have disclosed your data that you have withdrawn your consent and instruct them to erase your data where this is prescribed by law. The withdrawal of a consent shall not affect the legality of the data processed prior to that withdrawal.
(4) Erasure without withdrawal
Unless you withdraw your consent, your personal data collected for the aforementioned purposes shall be erased in accordance with the retention periods set out in Section 9.
(1) In addition to the data indicated above in Section 3, when you use our Site cookies are also stored on your computer or mobile device. Cookies are small text files that are saved on your hard disk or mobile device and are assigned to the browser you use and through which certain information flows to the place set by the cookie. Cookies cannot execute programs or transmit viruses to your device. They serve to make the internet offer overall more user-friendly and effective.
(2) Use of cookies on the Site
a) The Site uses the following types of cookies, whose scope and function are explained in the following:
Precisely which cookies are used on our Site and what type of cookie they are can be found in our Cookie Policy.
b) Session cookies are automatically deleted when you close the browser. These save what is known as a session ID to which gathers together various requests made by your browser in a single session. This means your computer can be recognized when you return to our Site. Session cookies are deleted when you log out or close the browser. Which session cookies are used on the Site can be found in our Cookie Policy.
c) Persistent cookies remain on your hard disk/mobile device beyond your browser session and are automatically deleted after a prescribed period which can vary depending on the cookie. You can delete the cookies at any time via your browser's security settings. We use these persistent cookies to facilitate your use of our Site and the offers found thereon by saving information and settings so that you do not need to re-enter them each time. Using persistent cookies, we can identify whether you have an account with us on subsequent visits. In all other cases, you will need to log in before each visit. In addition, persistent cookies enable us to record statistics on the use of our Site, for instance to measure the effectiveness of advertising campaigns on our Site, and to optimize our offering so we can personalize it to you. Which persistent cookies are used on our Site can be found in our Cookie Policy.
d) Some of the cookies installed on our Site are known as Flash cookies (for example, the Adobe Flash Player cookie). Flash cookies are not recorded by your browser but by your Flash plug-in. In addition, we use HTML5 storage objects which are stored on your end device. These objects store the necessary data irrespective of which browser you use and have no automatic expiry date, in other words they remain on your end device permanently. Which Flash cookies and HTML5 storage objects are used on our Site can be found in our Cookie Policy.
e) Strictly necessary cookies are essential to enable you to navigate on a website and use its functions or to be able to access a service you receive - for example saving items that you place in an online shopping basket. Which strictly necessary cookies are used on our Site can be found in our Cookie Policy.
f) Functionality cookies enable the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For example, a website might be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located, remember changes you have made to the text size, fonts or other parts of web pages that you can customize, and provide services you requested, such as watching a video or commenting on a blog. The information collected by these cookies is often anonymized so that your online activities cannot be tracked on other websites. Which functionality cookies are used on our Site can be found in our Cookie Policy.
g) Performance, i.e. analysis cookies collect information about how you use a website, for instance which (sub) pages you visit most often and whether you receive error reports from them. They do not collect any information that identifies you as the User. All of the information collected by the cookies is aggregated and therefore anonymous. Their only purpose is to improve the performance of the website. Which performance cookies are used on our Site can be found in our Cookie Policy.
h) Targeting or advertising cookies are used to deliver adverts that are more relevant to you and your interests. They are also used to measure the effectiveness of the advertising campaign and limit the frequency you are shown a particular advertisement. These cookies are usually placed by advertising networks with the consent of the website operator. They remember that you have visited a particular website and this information is shared with other organizations, such as advertisers. Targeting or advertising cookies are quite often linked to website functionality provided by other organization. More information about the online behavior of advertising cookies and online data protection can be found in a guide on the internet advertising industry available at youronlinechoices.com. Which targeting or advertising cookies are used on our Site can be found in our Cookie Policy.
i) We use several partners to supplement our offer and help us make the Site and the offers on it more interesting for you. These partners install third-party cookies on our Site. Some of these third-party cookies are performance (analysis) cookies, namely Hotjar, Google Analytics, Clicktale and Maxymiser, and others are targeting or advertising cookies such as GiDClient, adqID, AdNetik/Digilant, Cognitive Match and Double Click, promo, sti, pti, date and pstrk-Cookies. A complete list of all third-party cookies used on our Site and descriptions of the type and function of these cookies can be found in our Cookie Policy.
3) You can configure your browser settings as you wish and for example accept third-party cookies or decline all cookies, only allow them in individual cases or automatically erase cookies when closing the browser. If you do not wish to process Flash cookies you need to install a corresponding add-on, e.g. "Better Privacy" for Mozilla Firefox or the Adobe Flash Killer cookie for Google Chrome. You can prevent the use of HTML5 storage objects by using the private mode in your browser. However, we advise you that in this case you may not be able to use all functions of our Site and the offers thereon unrestrictedly. We recommend regularly deleting your cookies and browser history manually. Additional information on cookies and configuring related browser settings can be found at www.allaboutcookies.org.
(4) The collection and processing of your data using the described cookies for the relevant purposes mentioned above is based on the legal basis of Art. 6 (1) letter f) GDPR. This is necessary to protect our legitimate interests and those of third parties.
(1) You have the following rights in relation to us in regard to your personal data:
(2) If you wish to assert one or several of these rights, please contact our customer service team by regular post from your postal address registered with us to the postal address of REEL Germany set out above, or by emailing Support from the account registered with us indicating the following information:
(3) Some of the rights asserted in paragraph 1 only apply under certain circumstances and in particular limits (see the description of the individual rights under (1) or, by way of example, also in Art. 21 (1) sentence 2 GDPR regarding the further processing of your personal data despite an objection). Where we are not able to comply with your request, we will inform you of the relevant reasons why.
For information on the General Data Protection Regulation (GDPR) and how it may affect you, please visit our FAQ.
We store your personal data only for as long as we require it for the purposes set out in this Privacy Policy. In accordance with our internal data management guidelines, we erase all personal data no longer required for the purposes for which they were collected. However, we may deviate from the above where we are subject to a longer statutory retention obligation. For instance, we have an obligation based on commercial and tax law provisions to retain your contact and payment details for a period of ten years. Under the provisions of the law combatting money laundering, we have an obligation to retain your personal data collected in fulfilment of our player due diligence requirements for a period of five years after your account is closed. When you close your account with us, the account will be classed as "closed" and the associated personal data are securely stored and only processed for the purposes set out in law up until the time the retention period has lapsed. This data is then erased securely. Please note that information relating to self-excluded accounts will not be deleted and will be retained for much longer than the specified periods above in compliance with our regulatory obligations.
(1) In some cases, we use external service providers (processors or third parties) to process your personal data. These parties are selected and commissioned by us carefully. Where these parties are processors, the service providers are bound by our instructions and are regularly audited. In all cases when data is shared, we always ensure that a corresponding agreement is in place with the data recipients that ensures that the disclosed data is transferred securely and that we only share personal data in the smallest extent necessary.We do not sell your data to third parties under any circumstances.
(2) We work with the following processors and/or third parties, among others, and where necessary disclose your personal data to these parties under certain circumstances:
(3) Occasionally we receive a request from criminal prosecution, regulatory and supervisory authorities to disclose players' data. We always ensure that the office requesting the data holds the relevant legal authority to do so and where applicable only forward the minimum amount of information required in a secure manner. We also disclose your personal data to criminal prosecution, regulatory and supervisory authorities if we are of the opinion that a criminal act has been committed or might be committed.
As a general rule your personal data will not be disclosed to third parties located in third countries (i.e. non-EU or non-EEA states). As a general rule, all processing operations take place within the European Union and the European Economic Area.
We use suitable technical and organizational security measures to secure your data against any accidental or deliberate manipulation, partial or complete loss or destruction or against unauthorized access by third parties. For example, we use a role and rights concept, according to which only designated departments of the controller have access to your personal data and are permitted to process the same, such as customer service, accounts and payments and compliance. The computer/server on which we (or our processors) store your personal data is located in a secure, restricted-access environment. We have invested considerably in our server, database, data security, firewall and encryption technologies in order to protect the data we collect and process. These technologies are installed within state-of-the-art security architecture. In addition, we continually improve our security measures in line with technological advances.
We are happy to provide you with further information on how we protect and use your personal data. Please contact Support. Useful information on data protection and privacy can also be obtained from the office of the Federal Commissioner for Data Protection and Freedom of Information.
We reserve the right to update or modify this Privacy Policy from time to time. This may be due to further developments to our Site and the content offered thereon or as required on the basis of changes in statutory or official provisions. Modifications will take effect immediately following their announcement on our Site. We therefore encourage you to check this Privacy Policy from time to time to ensure that you are familiar with the current version and any changes we might make.
Current version: 1.3. Last update: July 2021