1. Overview

Please get a picture of how we process your personal data when you use or buy licenses for the HoldemResources Software (hereinafter "Software") or otherwise have a business relationship with us (Art 13, Art 14 GDPR; section 165 Abs 3 TKG ["Austrian Telecommunication Act"]).

• If you are merely visiting our website, please note section 3.
• For information on how your personal data is handled when purchasing licenses through our authorized resellers, please refer to section 4.

2. What data do we process when you use our Software?

When using our Software, the following data may be processed of the following data subjects:

• Users of the Software:
  • Name
  • E-Mail
  • License-Key
  • Machine-Key
  • Version Information
  • IP-Address

When you register for a trial or activate your license key within the software, we collect and transmit your name and email address. For license management and verification, the software will periodically transmit your license key, machine key, and software version information. Additionally, your IP address will be visible to our servers and logged for security purposes.

Processing this data is necessary for maintaining the Software's security of operation and functionality. The processing of this data is justified by our legitimate interest in the operation of our Software as well as contractual and legal obligations (Art 6 para 1 lit b, c and f GDPR).

In order to operate our Software, it may be necessary for us to disclose your information to the following recipients:

• Recipient of data: Hetzner Online GmbH

  • Purpose of data processing: Hosting-Provider
  • Legal justification: Legitimate Interest (Art 6 Abs 1 lit f GDPR)
  • Location: EU

• Recipient of data: Google LLC (Alphabet Inc)

  • Purpose of data processing: E-Mail-Services, Cloud-Service
  • Legal justification: Legitimate Interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data Privacy Framework

• Recipient of data: SENDINBLUE (Brevo)

  • Purpose of data processing: E-Mail-Services (Transactional and Newsletter)
  • Legal justification: Consent (Art 6 Abs 1 lit a GDPR); Data Processing Agreement pursuant Art 28 GDPR
  • Location: EU

3. What data do we process when you visit our website?

Please get a picture of how we process your personal data when you visit our website (Art 13, Art 14 GDPR; section 165 Abs 3 TKG). When you visit our website, the following personal data may be processed:

• E-Mail
• IP-Address

The following companies may receive your personal data, when you visit our website:

• Recipient of data: Hetzner Online GmbH

  • Purpose of data processing: Hosting-Provider
  • Legal justification: Legitimate Interest (Art 6 Abs 1 lit f GDPR)
  • Location: EU

• Recipient of data: Recaptcha (Google)

  • Purpose of data processing: Cyber Security
  • Legal justification: Legitimate Interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data Privacy Framework

• Recipient of data: Google Analytics version 4 (Google)

  • Information: EU-focused data and privacy
  • Purpose of data processing: Statistical Purposes
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data Privacy Framework

• Recipient of data: Paddle.com Market Ltd

  • Purpose of data processing: Reseller Store Integration
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: UK
  • Basis for transfer to third country: adequacy decision pursuant Art 45 GDPR

• Recipient of data: FirstPromoter.com

  • Purpose of data processing: Affiliate Management
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: EU

Additionally, when you use our chat support:

• Recipient of data: Discord Inc.

  • Purpose of data processing: Messenger-Service (Support)
  • Legal justification: Legitimate Interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data Privacy Framework

The processing of this data is necessary to manage the security of the operation of the website and to ensure the functionality of the website from a technical point of view. The collection of this data is partly carried out via technical cookies. These technical cookies are only used to the extent necessary (§ 165 Abs 3 TKG). The processing of this data is justified by our legitimate interest in operating our website (Art 6 para 1 lit f GDPR).

• Name of cookies: _fprom_*, source (FirstPromoter)

  • Purpose of data processing: Affiliate Services
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Duration of storage: 56 days

• Name of cookies: _ga, _ga_* (Google Analytics)

  • Purpose of data processing: Statistical Purposes
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data Privacy Framework
  • Duration of storage: 1 Year

4. How is my personal information handled when I purchase through a reseller?

We partner with authorized resellers to securely process your orders. These resellers act as the "Merchant of Record." This means they handle all payment details, collect any applicable sales taxes, and issue your invoice directly. We never see or store your credit card information.

When initiating an order on our website, you will be either forwarded to a reseller or interact with their site through an overlay window to complete the purchase. You can find additional information about our resellers below:

• Paddle.com Market Ltd.

  • Consumer Terms
  • Privacy Policy

• Bright Market, LLC (Fastspring)

  • Consumer Terms
  • Privacy Policy

For order fulfillment purposes, we receive certain billing information from our resellers, such as your name, email and billing address. This information is used solely to process and manage your software license and is stored in accordance with this privacy policy. Data may be retrieved and processed from the following sources:

• Source of data: Paddle.com Market Ltd

  • Categories of data: Name, E-Mail, Address
  • Purpose of data processing: order fulfillment, license management
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: UK
  • Basis for transfer to third country: adequacy decision pursuant Art 45 GDPR

• Source of data: Bright Market, LLC (Fastspring)

  • Categories of data: Name, E-Mail, Address
  • Purpose of data processing: order fulfillment, license management
  • Legal justification: Legitimate interest (Art 6 Abs 1 lit f GDPR)
  • Location: USA
  • Basis for transfer to third country: EU-US Data privacy framework

5. For what purposes do we process your data when we have a business relationship or you use our Software?

In the course of our business relationship with customers or users, we process data on the basis of contractual (processing of the contractual relationship, pre-contractual obligations, billing for services, dispatch of documents, communication for the processing of the contract) and legal obligations (legally required storage within the meaning of section 132 BAO; section 212 UGB ["Austrian Commercial Act"]) (Art 6 para 1 lit b and c GDPR) as well as on the basis of our legitimate interests or on the basis of legitimate interests of third parties (Art 6 para 1 lit f DSGVO), namely:

• for the purpose of internal administration and management of the business case to the extent necessary (e.g.: Processing your business case, forwarding your business case to various departments, filing, archiving purposes, correspondence with you);
• for the purpose of providing the Software and support;
• all of your data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or othertransaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices;
• we point out, that we may process data for advertising purposes on the basis of legitimate interests (Art 6 para 1 lit f GDPR). You may object to this form of data processing at any time (Art 21 para 2 GDPR);
• for the purpose of law enforcement;
• for the purpose of conducting investor due diligence;

in each case to the extent necessary. The processing of your data serves the initiation, maintenance, and handling of our business relationships. If you do not provide us with this data, we will unfortunately not be able to provide you with the Software.

The processing of your data can also be based on consent (Art 6 para 1 lit a GDPR). This consent can be revoked at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

6. How long do we store your data?

We will only store your data for as long as is necessary for the purposes for which we collected your data. In this context, legal storage obligations must be taken into account (for example, for reasons of tax law, contracts and other documents from our contractual relationship must generally be stored for a period of seven years (section 132 BAO)). In justified individual cases, such as for the assertion and defense of legal claims, we may also store your data for up to 30 years after termination of the business relationship.

We store data of interested parties (e.g. visitors of the website) for up to one year from the time of the last contact by the interested party.

7. Does automated decision-making and/or profiling take place (Art 13 (2) lit f GDPR)?

No automated decision-making or profiling takes place in our company.

8. What rights do you have with regard to data processing?

We would like to inform you that you have the right, provided that the legal requirements are met:

• You have the right to request information about which of your data is processed by us (see in detail Art 15 GDPR).
• You have the right to request the correction or completion of incorrect or incomplete data concerning you (see in detail Art. 16 of the GDPR).
• The right to have your data deleted (see in detail Art 17 GDPR).
• The right to object to processing of your data that is necessary to protect our legitimate interests or those of a third party (see in detail Art 21 of the GDPR). This applies in particular to the processing of your data for advertising purposes.
• You have the right to receive the transfer of the data provided by you in a structured, common and machine-readable format.

If we process your data on the basis of your consent, you have the right to revoke this consent at any time by e-mail. This will not affect the lawfulness of the data processing carried out up to this point (Art 7 (3) GDPR).

9. Do you have a right to complain?

If, contrary to our expectations, there is a violation of your right to lawful processing of your data, please contact us by mail or e-mail. We will make every effort to process your request promptly. You also have the right to lodge a complaint with the supervisory authority responsible for data protection matters. In Austria, this is the: Data protection authority (“Datenschutzbehörde”) based in Vienna, Austria.

10. Opportunity to get in contact

If you have any further questions about the processing of your data, please feel free to contact our data protection coordinator using the contact details below.

11. Controller

Controller in the sense of Art 4 Z 7 GDPR is:

HoldemResources GmbH
FN 576331x, Vienna, Austria
support@holdemresources.net

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