🔒 Privacy Policy

Thank you for using pokertools.online! To ensure the proper functioning of our services, it is necessary to process personal data in some cases. Fairness and transparency are our top priorities—therefore, we would like to inform you here about which data we process, for what purpose, and on what legal basis.

Additionally, we would like to inform you about your rights under the European General Data Protection Regulation (GDPR) and the (German) Federal Data Protection Act (BDSG).

This privacy policy applies to the digital services of pokertools.online, hereinafter also referred to as the "Website", and the associated subdomains.

🏢 Responsibility

If you have any questions, comments, or wish to exercise your rights, please contact:

Dominik Johs
Auwaldstr. 1A
76661 Philippsburg
E-Mail: info@pokertools.online

📜 Your Rights

As a data subject, you have the right to assert your data subject rights with us. In particular, you have the following rights:

  • In accordance with Article 15 GDPR and Section 34 BDSG, you have the right to request information about whether we process personal data related to you and, if so, to what extent.
  • You have the right, in accordance with Article 16 GDPR, to request the correction of your data from us.
  • You have the right, in accordance with Article 17 GDPR and Section 35 BDSG, to request the deletion of your personal data from us.
  • You have the right, in accordance with Article 18 GDPR, to request the restriction of the processing of your personal data.
  • You have the right, in accordance with Article 20 GDPR, to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.

If you have given us separate consent to process your data, you may revoke this consent at any time in accordance with Article 7(3) GDPR. Such revocation does not affect the legality of the processing carried out based on the consent before the revocation.

Complaint to a Supervisory Authority

If you believe that the processing of personal data concerning you violates the provisions of the GDPR, you have the right, in accordance with Article 77 GDPR, to lodge a complaint with a supervisory authority.

Right to Object

If you believe that the processing of personal data concerning you violates the provisions of the GDPR, you have the right, in accordance with Article 21(2) and (3) GDPR, to object to the processing.

General Information on Legal Bases, Storage Duration, Recipients, and Data Transfers to Third Countries

📜 Legal Basis

We process personal data in compliance with the relevant data protection regulations, particularly the GDPR and the BDSG. Data processing by us takes place only on the basis of legal authorization.

When using this website, we process personal data only with your consent (§ 25(1) TDDDG or Article 6(1)(a) GDPR), to fulfill a contract to which you are a party, or at your request to carry out pre-contractual measures (Article 6(1)(b) GDPR), to fulfill a legal obligation (Article 6(1)(c) GDPR), or if the processing is necessary to protect our legitimate interests or the legitimate interests of a third party, provided that your interests or fundamental rights and freedoms, which require the protection of personal data, do not override them (Article 6(1)(f) GDPR).

🕖 Duration of Storage

Unless otherwise indicated in the following notes, we store the data only for as long as is necessary to achieve the processing purpose or to fulfill our contractual or legal obligations. Such legal retention obligations may arise in particular from commercial or tax law provisions.

📊 Categories of Data Recipients

We use data processors in the context of processing your data. Processing operations carried out by such processors include, for example, hosting, authentication, [...].

🌎 Data Transfer to Third Countries

Our data processing may involve the transfer of certain personal data to third countries, i.e., countries where the GDPR is not applicable law. Such a transfer is permissible if the European Commission has determined that an adequate level of data protection exists in such a third country. If no such adequacy decision by the European Commission is in place, a transfer of personal data to a third country will only occur if there are suitable safeguards in accordance with Art. 46 GDPR or if one of the conditions of Art. 49 GDPR is met.

In the absence of an adequacy decision and unless otherwise specified below, we use the EU Standard Contractual Clauses as appropriate safeguards for the transfer of personal data to third countries. You have the opportunity to obtain or review a copy of these EU Standard Contractual Clauses. Please contact the address provided under Contact for this purpose.

If you consent to the transfer of personal data to third countries, the transfer is based on the legal grounds of Art. 49(1)(a) GDPR.

Data Processing in Detail

🖥️ Provision of the Website

When using our website for informational purposes only, general information that your browser transmits to our server, as well as to data processors, is stored automatically.

What data is processed?

The data transmitted by your browser may include the following information:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time
  • Content of the request
  • HTTP status code
  • Adwmount of data transferred
  • Previously visited page (Referrer URL)
  • Information about browser and operating system

On what legal basis is the data processed?

Data processing is carried out to safeguard our legitimate interests in the secure and efficient provision of the website and is based on the legal grounds of Art. 6(1)(f) GDPR.

Processing of this data is neither legally nor contractually required. The website's functionality cannot be ensured without this processing. We are unable to identify you as a data subject based on the stored information. Therefore, Articles 15 to 20 GDPR do not apply according to Art. 11(2) GDPR, unless you provide additional information that enables your identification to exercise the rights laid down in these articles.

How long is the data stored?

The data is processed exclusively by our data processors and is only stored as long as necessary for the described purposes.

Which data processors are involved?

Bunny.net CDN & Bunny.net Storage

We use hosting products from BunnyWay d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia, to provide our website.

BunnyWay is a Slovenian hosting provider that offers solutions for delivering websites and web applications. We use the services bunny.net CDN and bunny.net Storage for the efficient delivery of our website. A CDN (Content Delivery Network) is a worldwide network of servers that stores and delivers static copies of our website on servers in different countries. This allows for faster content delivery and better website performance. BunnyWay is headquartered in Ljubljana, Slovenia. Slovenia is part of the European Union, and BunnyWay's services are subject to EU data protection laws.

BunnyWay is the recipient of your personal data and acts as a data processor on our behalf. This aligns with our legitimate interest according to Art. 6(1)(f) GDPR, as it allows us to avoid operating our own CDN. We have entered into a data processing agreement with BunnyWay for the use of BunnyWay products (Art. 28 GDPR). This is a data protection legally required contract that ensures BunnyWay processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

✍️Registration and Login

When registering a user account on our website or using our website as a logged-in user, additional personal data is collected and transmitted to additional data processors.

What data is processed?

  • Unique user ID
  • Username
  • E-Mail-Adress
  • Password (encrypted)

On what legal basis is the data processed?

Data processing is carried out to safeguard our legitimate interests in the secure provision of the website and is based on the legal grounds of Art. 6(1)(f) GDPR. Processing of this data is neither legally nor contractually required. The website's functionality cannot be ensured without this processing.

How long is the data stored?

The stored data is retained until you delete your user account.

Which data processors are involved?

Google Firebase Authentication

We use the service Google Firebase Authentication by Google Ireland Limited, Gordon House, 4 Barrow Street, D04 E5W5 Dublin, Ireland (“Google”), to perform authentication processes and manage user accounts.

Firebase Authentication is a login and authentication service provided by Google. To simplify the login and authentication process, Firebase Authentication can use third-party identity services and store the information on its platform.

To use Firebase Authentication for our purposes, the following data is transmitted to and stored by Google: unique user ID, username, email address, and password (encrypted). For more information on Google Firebase and privacy, please visit https://policies.google.com/privacy and firebase.google.com.

Google is the recipient of your personal data and acts as a data processor on our behalf. This aligns with our legitimate interest under Art. 6(1)(f) of the GDPR, allowing us to avoid the need to provide our own authentication system. Google may process your data, including in the USA. As an active participant in the EU-US Data Privacy Framework (DPF), Google ensures that the transfer of personal data from EU citizens to the USA is specifically and securely regulated. Additionally, Google has implemented compliance measures for international data transfers based on the EU Standard Contractual Clauses (SCCs). These measures apply to all global activities where Google processes personal data of individuals in the EU. For more information, please visit: https://cloud.google.com/terms/sccs

Google Single-Sign-On

We offer a registration and login with Google Single-Sign-On. Google Single-Sign-On is a login and authentication service provided by Google Ireland Limited, Gordon House, 4 Barrow Street, D04 E5W5 Dublin, Irland („Google“) which allows you to log in with a Google account.

To use Google Single-Sign-On for our purposes, the following data is transmitted to us by Google: Unique user ID, display name, email address, profile picture.

The login or registration with Google Single-Sign-On is carried out completely via the Google system. During the login or registration process, you are redirected to a Google page. Google may therefore collect data that your browser transmits to Google. This includes, for example, the data listed under "Provision of the Website".

Google may process your data in the USA. As an active participant in the EU-US Data Privacy Framework (DPF), Google ensures that the transfer of personal data from EU citizens to the USA is specifically and securely regulated. Additionally, Google has implemented compliance measures for international data transfers based on the EU Standard Contractual Clauses (SCCs). These measures apply to all global activities where Google processes personal data of individuals in the EU. For more information, please visit: https://cloud.google.com/terms/sccs

💻️ Provision of Backend Services

The data you enter while using our website is stored in the backend services we developed for this site. This data is not shared with third parties and is stored on servers in Germany. To ensure certain functionalities of the website, personal data is also processed.

What data is processed?

  • Unique user ID
  • E-Mail-Adress

Additionally, our backend services collect the data that your browser transmits by default (see section "Provision of the Website") and process it in the form of server log files.

On what legal basis is the data processed?

Data processing is carried out to safeguard our legitimate interests in the secure, efficient, and functionally correct provision of the website and is based on the legal grounds of Art. 6(1)(f) GDPR. Processing of this data is neither legally nor contractually required. The website's functionality cannot be ensured without this processing.

How long is the data stored?

These data are stored until you delete your user account. The server log files we collect are deleted after 7 days, unless there are specific indications of a legitimate suspicion of unlawful use, requiring further examination and processing of the information.

Which data processors are involved?

Hetzner

We use hosting products from Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (“Hetzner”), to provide our backend services.

Hetzner is a German hosting provider offering server and cloud solutions for the provision of websites and web applications. Hetzner stores the data we transmit for processing on servers in Germany.

Hetzner is the recipient of your personal data and acts as a data processor for us. This aligns with our legitimate interest under Art. 6(1)(f) GDPR in not having to operate our own servers. We have entered into a data processing agreement with Hetzner for the use of Hetzner products (Art. 28 GDPR). This is a data protection-required contract that ensures Hetzner processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

🐞 Performance Monitoring and Error Analysis

We use tools on our website for performance measurement and error analysis. These tools allow us to measure the website's performance and analyze errors to improve user-friendliness. The tools may process personal data.

What data is processed?

  • IP-Adress
  • Activities performed on the website (anonymized)

According to our data processor, the IP address is used solely for location determination (country of origin) and is not stored.

On what legal basis is the data processed?

Data processing is carried out to safeguard our legitimate interests in optimizing our services and is based on the legal grounds of Art. 6(1)(f) GDPR.

How long is the data stored?

The data we collect for error analysis and performance measurement is deleted within 90 days at the latest.

Which data processors are involved?

New Relic JS Agent

We use a JS agent from New Relic, Inc, 188 Spear Street, Suite 1000, San Francisco, CA 94105, USA (“New Relic”), to monitor the performance and correct functionality of our website.

The New Relic JS Agent allows us to assess and improve the stability of our services by monitoring the system and code errors.

The New Relic JS Agent collects and stores data about website usage as well as the IP address. According to New Relic, the IP address is used solely for location determination and is not stored. Therefore, we cannot identify you as a data subject based on the stored information. Consequently, Articles 15 to 20 GDPR do not apply according to Art. 11(2) GDPR.

New Relic is the recipient of your personal data and acts as a data processor on our behalf. The legal basis for the processing is your consent according to Art. 6 para. 1 lit. a GDPR. New Relic may also process your data in the USA, among other locations. As an active participant in the EU-US Data Privacy Framework (DPF), New Relic ensures that the transfer of personal data from EU citizens to the USA is specifically and securely regulated. Additionally, we have entered into a data processing agreement with New Relic for the use of New Relic products (Art. 28 GDPR). This is a data protection legally required contract that ensures that they process the personal data of our website visitors only according to our instructions and in compliance with the GDPR. This contract is based on the EU Standard Contractual Clauses (SCCs).

Cookies and other Technologies

To ensure the proper functioning of our website, we use various technologies to store data on your device. We use these technologies solely to ensure the proper functionality of the website. Storing the data listed below on your device is therefore technically necessary and does not require your consent.

Firebase Authentication

Name: firebaseLocalStorageDb
Type: IndexedDB
Purpose: To determine if you are already logged in, Firebase Authentication stores information about the currently logged-in user in this database.
Storage Duration: Current Session

Name: firebase-heartbeat-db
Type: IndexedDB
Purpose: To protect your service from abuse, Firebase Authentication performs regular connection checks (so-called Heartbeats). Information about these Heartbeats is stored in this database.
Storage Duration: Persistent

PokerTools.online

Name: pto-db/expandings
Typ: IndexedDB
Purpose: To determine which folders you have expanded in the Range Editor, we store this information in your browser to ensure a seamless workflow when you visit the website again.
Storage Duration: Persistent

Name: pto-db/routes
Type: IndexedDB
Purpose: To direct you to the correct location when you visit the website or switch between functionalities, we store the last used routes in your browser to ensure a seamless workflow.
Storage Duration: Persistent

Name: pto-db/settings/language
Type: IndexedDB
Purpose: To determine the language you prefer, we store this information in your browser.
Storage Duration: Persistent