PokerVault Privacy Policy

PKV Tech Inc., doing business as PokerVault ("PokerVault," "we," "us"), 5965 Village Way, Suite E105-247, San Diego, CA 92130, is responsible for the personal information described in this policy. Contact: [email protected].

If you allow location access, the App uses your device's precise location for the game features you use and to put nearby clubs, games, people, and posts first in Explore, Search, and your Feed; you can turn it off at any time in your device settings. If you don't, we use the hosting address you saved (for your own searches) and your rough, city-level area. Your rough area is never shown to anyone. It only changes the order of results and suggestions, including which nearby members' posts are suggested in the Feed, so your posts may be suggested to members near you. We do not ask for your date of birth; we see it only on the ID that prize winners upload for verification.

• Provide the Services: accounts, clubs, games, calculations, settlement statuses, feeds, notes, insights, and support.
• Feed and search: build your Feed (posts from your clubs, the people you follow, and you, in time order, plus, where allowed, a few suggestions from members and public clubs near you), run Explore and search, put nearby clubs, games, people, and posts first, measure what works, and catch spam.
• Run our sweepstakes: track Entries, enforce limits, match Store orders to your account to credit Entries (if an order cannot be matched, we email the checkout address once about linking it; that email is not marketing), send Entries to our administrator for random drawings, notify and verify winners, deliver prizes, publish winners and their chosen photos, and meet any state registration and bonding obligations.
• Tax and legal compliance: issue IRS Form 1099-MISC when required, screen prize winners against U.S. sanctions lists, respond to lawful requests, and keep required records.
• Store: process and ship orders, issue and redeem gift cards, and handle returns.
• Memberships: provide any paid membership you buy and manage its billing, renewal, and cancellation.
• Marketing: send you marketing emails, push notifications, and in-app messages about PokerVault products, services, and promotions; and personalize and measure our marketing. We do not send marketing text messages. See Section 7 to opt out.
• Phone verification: text a one-time code to the mobile number you add, so you can verify it. These texts are not marketing and never concern sweepstakes prizes. We do not send SMS alerts.
• Safety and integrity: detect and prevent fraud, duplicate accounts, bots, abuse, and violations of our Terms; moderate content (reported content is reviewed and violating content removed, typically within 24 hours).
• Improve PokerVault: diagnose crashes, fix bugs, and understand feature use.

We disclose personal information only as described here:

(a)Service providers that process information for us under contracts limiting their use of it, including: our sweepstakes administrator (Sweeppea, operated by MOMARES, LLC), which hosts free-entry requests on our behalf and receives the minimum entrant data needed to conduct random drawings; our identity-verification platform for prize winners; our Store platform and payment processors (Shopify); membership billing (Apple and Stripe); sign-in providers (Apple and Google); crash and performance reporting (Sentry); product analytics and session replay (PostHog); install attribution and ad measurement (AppsFlyer); cloud hosting, email, and push-notification delivery providers; text-message delivery for phone verification codes; our AI service provider for note summaries, OpenAI (only after you allow it); tax-document, identity-verification, and sanctions-screening providers; merchandise fulfillment partners and shipping carriers; and professional advisers. Service providers keep the information we share with them under our contracts and their own data retention policies.

(b)Other users. Your profile, posts, and comments are visible to other users as the App describes. Game records, including amounts entered, are visible to the other participants in that game and, as the App describes, to members of the club. You choose whether to share a payment handle with other players. When you add one, the App checks that it exists by looking it up on that payment service's public website (for example, Venmo), which sees the lookup.

(c)The public (winners only). Each confirmed winner's first name, last initial, and prize, and the photo the winner chooses under the signed Winner Publicity Release, are published on our winners page and may appear in our App, websites, emails, social media, and advertising, worldwide and permanently. We never publish a winner's full last name, address, city, contact details, or ID information. A winner with a personal-safety concern may ask us to replace their photo with a non-identifying image; the name, last initial, and prize remain listed.

(d)Regulators, tax authorities, and requesters. When a promotion's total prizes exceed $5,000, New York and Florida require us to file winners lists, including names and addresses, and to provide winners lists to members of the public who request them. We report prizes to the IRS and state tax agencies when the law requires.

(e)Legal and safety. To comply with law or legal process, to protect the rights, safety, and property of PokerVault, our users, or others, and to investigate fraud or security issues.

(f)Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to this policy.

(g)With your consent or at your direction.

We do not sell personal information for money, and we do not disclose personal information to third parties for their own direct marketing purposes. Our websites and Store may use advertising cookies and pixels to measure and show PokerVault ads on other platforms. Some state laws may treat that as "selling," "sharing," or "targeted advertising." You can opt out as described in Sections 7 and 11. We honor Global Privacy Control browser signals as an opt-out where state law requires.

Mobile information. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

• Marketing use. As our Official Rules state, when you enter a PokerVault sweepstakes we may use the information you provide to send you marketing emails, push notifications, and in-app messages. Unsubscribing never affects your Entries or eligibility.
• Prize notifications. We notify potential winners only by email from [email protected] and by in-app message. We do not text or call winners about prizes. These messages are not marketing.
• Minimum data to the administrator. For Entries earned in the App or Store, Sweeppea (MOMARES, LLC) receives a participant reference, first name, email address, and Entry count for each drawing, not your game records, notes, or verification documents. Free-entry requests are submitted on Sweeppea's website, collected on our behalf, and also covered by Sweeppea's privacy policy.
• Winner verification. Potential winners upload ID only to our third-party verification platform, which checks the document to confirm identity, age, and residency. It does not use facial recognition, and neither we nor the platform collect biometric identifiers. We never ask for ID by email, text, or social media. A Social Security number is requested only on IRS Form W-9, only if tax reporting is required by law, and only through our secure verification platform. Access is limited to named PokerVault staff responsible for verification and tax reporting.
• Winner listings are permanent. Under the signed Winner Publicity Release, winners consent to permanent, worldwide use of their first name, last initial, prize, and chosen photo. If a winner chooses the ID-crop photo, we keep only the cropped image of the face; the full ID image is deleted on the schedule in Section 8.

Our sweepstakes award Entries for some activities that involve providing personal information (for example, confirming your email or phone number or completing your profile) and for free entry requests. Entries have no cash value. Participation is voluntary: you can enter without providing anything beyond the free-entry information, and you may withdraw by deleting your account or asking us to delete your information (Entries already used in completed drawings cannot be withdrawn). Deleting your account voids the Entries in it once the deletion is final, as the Official Rules describe. We believe the value of the Entries offered is reasonably related to the value of the information provided, based on the cost of the prizes and of running the sweepstakes. Complete terms are in the Official Rules.

Do Not Track. Our websites do not respond to browser "Do Not Track" signals; we honor Global Privacy Control as described above. Third-party advertising and analytics partners may collect information about your activity on our websites over time and across other websites.

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit and at rest for verification and tax documents, multi-factor authentication and least-privilege access for staff, access logging, vendor security reviews, and secure deletion. No system is perfectly secure. We will notify you and regulators of a data breach as the law requires.

PokerVault is only for people who meet the minimum age for the state where they live: 18 (19 in Alabama and Nebraska; 21 in Arizona and Mississippi). We do not knowingly collect personal information from anyone younger. If we learn that we have, we will delete it and close the account. Parents or guardians can contact [email protected].

Depending on where you live (for example, California, Colorado, Connecticut, Oregon, Texas, Virginia, and other states with comprehensive privacy laws), you may have the right to: know or access the personal information we have about you; correct it; delete it; obtain a portable copy; opt out of "sales," "sharing," or targeted advertising; and opt out of profiling that produces legal or similarly significant effects (we do not engage in such profiling). We will not discriminate against you for exercising these rights.

(a)How to make a request: email [email protected] or use the in-App deletion tool. We will verify your request by matching information you provide with information we hold (for example, confirming control of your account email). You may use an authorized agent, who must provide your signed permission; we may still verify your identity directly.

(b)Timing: we respond within 45 days and may extend once by 45 days where permitted, with notice.

(c)Appeals: if we deny your request, you may appeal by replying to our decision or emailing [email protected] with the subject "Privacy Appeal." We will respond as your state's law requires and tell you how to contact your state Attorney General if you disagree.

(d)Sensitive information: we use government ID, Social Security numbers (only if collected for tax reporting), and account credentials only to verify winners, meet tax and legal obligations, secure accounts, and prevent fraud, and not to infer characteristics about you. If you allow it, we use precise location only for game features and to put nearby results first, never to infer anything else about you. We do not collect biometric identifiers or use facial recognition.

(e)California "Shine the Light" (Cal. Civ. Code § 1798.83): we do not disclose personal information to third parties for their own direct marketing purposes.

(f)Nevada: we do not sell covered information as defined in NRS 603A. You may still send an opt-out request to [email protected].

(g)Categories disclosed in the last 12 months: the categories in Section 2 have been disclosed for business purposes to the recipient categories in Section 4(a)–(f).

(h)Winner listings: a deletion request does not remove a winner's listing or photo where the law allows us to keep it to perform the signed Winner Publicity Release. Winners may still request the personal-safety photo replacement described in Section 4(c).

PokerVault is offered only in the United States, and we store and process information in the United States.

We will post any update here with a new version number and effective date. If a change is material, we will notify you in the App or by email before it takes effect and, where required, ask for your consent.

Privacy questions or requests: [email protected]. General support: [email protected]. Mail: PKV Tech Inc. (PokerVault), Attn: Privacy, 5965 Village Way, Suite E105-247, San Diego, CA 92130.