Privacy Policy

Maxime de Chalendar (“we”, “us” or “our”) respects your privacy and recognises the importance of providing a secure environment for your personal data. We are committed to being transparent about how we collect and process your personal data.

The purpose of this Privacy Notice is to inform you why and how we process information that can be linked or attributed to you (“Personal Data”) when you play VORTEX Poker or use its supporting website (“Services”), with whom it is shared, how long it is retained and what rights you have.

General information

Who is responsible for the processing of your Personal Data?

Maxime de Chalendar is the operator and data controller for VORTEX Poker. You can contact the operator about privacy or support at contact@vortexpoker.app.

What types of Personal Data do we process and how do we collect it?

When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect or ask you to provide special categories of Personal Data, such as health, religion, political opinions or sexual orientation.

Personal Data provided by you

• Account and profile: your in-game username and selected avatar. The App automatically creates a pseudonymous device-based Account; it does not require an email address, password, real name or social-network login.
• Customer support: the subject and content of your request, your email address and information you choose to provide when you contact us. Avoid sending payment-card details, passwords or other unnecessary sensitive information.

Personal Data we receive or generate from your use of our Services

• Account and gameplay: internal user and device identifiers, authentication tokens, account creation date, virtual-coin balance, owned cosmetics, game results, trophies, streaks, leaderboard rankings and rewards.
• Technical and diagnostic information: IP address, device and operating-system information, app version, request metadata, session/activity information and logs needed to run and protect the Service.
• App interaction and analytics: gameplay, screen, purchase and reward events, session/app lifecycle and frustration-interaction events; user properties such as username, balance, wins and notification permission status; device identifiers and approximate location derived by platform/analytics services. We do not collect precise GPS location for the Game.
• Notifications: an Apple push-notification token and permission status when the App registers for notifications.

Personal Data we collect from third parties

If you make an in-app purchase, Apple processes the payment under its own terms and privacy policy. We receive product and transaction identifiers and transaction/verification information to fulfill and validate the purchase, prevent fraud and handle refunds. We do not receive your payment-card details. Analytics and technical providers may supply the device, usage and diagnostic information described above.

For what purpose and on which legal basis do we process your Personal Data?

• Performance of a contract: create and administer your Account, run matchmaking and games, preserve progress, credit rewards and purchases, display standings and provide requested support.
• Legitimate interests: understand and improve the Service, diagnose faults, keep it secure, prevent fraud and abuse and resolve disputes. Our interests are balanced against your rights; you can object to processing based on legitimate interests as described below.
• Legal obligations: meet applicable accounting, transaction, security and privacy obligations, including responding to requests to exercise your rights.
• Consent where required: processing that requires your consent under applicable law. Notification permission can be withdrawn in your device settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Do we engage in profiling or cross-company tracking?

We use gameplay and usage information to measure and improve VORTEX Poker. We do not use it to track you across apps or websites owned by other companies, operate advertising-audience or remarketing programs, sell Personal Data or make automated decisions producing legal or similarly significant effects. In-game results, rankings and reward eligibility are calculated from gameplay.

With whom do we share your Personal Data?

We do not disclose your Personal Data to parties who are not authorized to process it. Access is limited to the operator and service providers where needed for the purposes described in this notice.

• Apple: App Store distribution, purchases and Apple Push Notification service.
• Oracle Cloud Infrastructure and Amazon Web Services: backend hosting, game execution, hosted artwork and protected backups.
• PieSocket: game socket/message delivery.
• Amplitude: app analytics, configured in its European data zone.
• Mail service providers: delivery and handling of support messages, including the operator’s iCloud Mail mailbox.

We may disclose information in response to lawful requests from public authorities or courts, or when necessary to establish, exercise or defend legal claims. If the Service is transferred or reorganized, applicable data protection requirements continue to apply and relevant changes will be communicated.

Where will my Personal Data be processed?

The production backend is hosted in the European Union and Amplitude is configured in its EU zone. Providers may process some information in other countries. Transfers outside the European Economic Area are subject to applicable data protection requirements, including an applicable adequacy decision or required safeguards such as standard contractual clauses. Contact contact@vortexpoker.app for information about the safeguards applicable to your data.

How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain Personal Data longer than necessary to fulfill the purposes for which it was collected or our legal obligations. Afterwards, it is deleted or anonymized. Account/gameplay data is retained while needed to maintain the Account and its progress. Purchase records may be retained to validate entitlements, fulfill accounting obligations, prevent fraud and resolve disputes. Support records are kept while handling requests and related follow-up; logs and analytics follow their operational purpose and provider-specific retention settings. Protected backups follow the backup rotation and may temporarily retain records removed from active systems.

Retention is determined by the duration of the Account relationship, the need to maintain balances and purchase entitlements, the handling of support/disputes and applicable statutory recordkeeping periods. You may request deletion or ask about the retention applying to your data at contact@vortexpoker.app.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

• Access the Personal Data we hold about you, including information such as, for example, the source and the categories of the data, the purposes of the processing, the recipients (or categories thereof) and the respective retention period.
• Request the update or correction of your Personal Data so that it is always accurate.
• Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transmit your Personal Data to another controller.
• Request the deletion of your Personal Data if you think that it is no longer needed for the purposes indicated above. If you have created a Service account, you can delete your account at any time by submitting a deletion request. To submit this request, contact our support team or us at contact@vortexpoker.app
• Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy.
• Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the processing based on consent before its withdrawal.

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such a case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to contact@vortexpoker.app providing your name, your email address as well as a description of your request.

If you believe we have not complied with applicable data protection law, you may lodge a complaint with the CNIL in France or another competent supervisory authority.

How can you contact us?

Privacy questions, objections, access, correction and deletion requests: contact@vortexpoker.app. Please provide sufficient information to identify your Account, such as your in-game username and relevant support details; never send a password or payment-card number. We may need to verify your identity before acting.

How often do we update this Privacy Notice?

We regularly review this Privacy Notice. Relevant changes will be communicated through the App or website and, where applicable, to contact details you have provided. The effective date appears at the top of this page.

Service-specific information

VORTEX Poker Account and public standings

The current Account is device-based. Your username, selected avatar and game statistics may be visible to opponents and in seasonal leaderboards. The current App does not provide social-network sign-in, a friends list, public chat, cross-device account recovery or an in-app account-deletion control. To request Account closure or deletion, contact contact@vortexpoker.app; certain purchase/security records may be retained as required by law.

Customer service

Support messages are handled through the operator’s contact mailbox. We process the content and contact details you supply to answer your request, investigate the issue and provide follow-up.

Analytics, logging and game delivery

Amplitude processes the app events and linked account/device information described above to measure and improve the App. Hosting and game-message providers process identifiers, connection metadata and gameplay messages needed to operate the Game. Logs help investigate errors, purchase fulfillment and abuse. The App currently has no user-facing analytics preference control; privacy rights and objections can be exercised by email.

Push notifications

If authorized, VORTEX Poker may send game, reward and in-app offer notifications. You can disable these through your device’s notification settings. We do not collect your email address to play or automatically subscribe you to a newsletter.

Purchases

All purchases are optional and processed by Apple. VORTEX Poker stores the transaction information needed to validate and fulfill purchased virtual coins/cosmetics. These items have no cash value and cannot be transferred or cashed out.

Website cookies and advertising

The marketing website does not use analytics scripts, advertising pixels or cookies. Its server may process ordinary request information, including IP address, to serve and protect the website. The App’s local account/session storage is separate from website cookies. No third-party ads or advertising-identifier tracking are enabled in the current App.

Children

VORTEX Poker is intended for people aged 18 and over. We do not knowingly provide the Services to children. Contact us if you believe a child has supplied Personal Data so we can investigate and take appropriate action.