Privacy Policy

1. Introduction

ScallyWagers ("we", "us", "our") operates the websites scallywagers.com, scallywagers.poker, and scallywagers.gg, and related applications (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information when you use the Service.

By using the Service, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Service.

2. Information We Collect

2.1 Information You Provide

• Account registration: email address (required), phone number (optional), display name, nickname, and profile photo.
• Group and event data: group names, descriptions, house rules, event details (dates, times, game types, buy-in amounts), and location information provided by hosts.
• Tournament data: blind structures, tournament configuration, elimination records, payout information, and results as entered by hosts and tournament directors.
• Communications: poll responses, feedback text, and support communications.

2.2 Information Collected Automatically

• Usage data: pages visited, features used, timestamps of activity, device type, browser type, and operating system.
• Connection data: IP address, WebSocket connection metadata for real-time tournament features.
• Cookies: session cookies required for authentication. We do not use tracking cookies, advertising cookies, or third-party analytics cookies. See our Cookie Policy for details.

2.3 Information from Third Parties

Payment data from Stripe: subscription status, billing dates, and transaction identifiers. We do not receive or store credit card numbers, bank account numbers, or full payment method details.

3. How We Use Your Information

We use your information exclusively to provide, maintain, and improve the Service:

• To create and manage your account
• To deliver group management, scheduling, tournament, and statistical features
• To send transactional notifications you have opted into (RSVP requests, reminders, tournament updates)
• To process subscription payments through Stripe
• To generate aggregated, anonymized analytics to improve the Service
• To respond to support requests and feedback
• To enforce our Terms of Service and protect against misuse
• To comply with legal obligations

We do not use your information for advertising, profiling, behavioral targeting, or any purpose other than delivering the Service.

4. Information We Share

4.1 We Do Not Sell Your Data

ScallyWagers does not sell, rent, license, or trade your personal information to any third party for any purpose. This is an absolute commitment, not a conditional one.

4.2 Service Providers (Transactional Data Only)

We share the minimum data necessary with the following service providers to deliver the Service:

4.3 What We Never Share

We never share with any third party:

• Tournament results, payout amounts, or financial history
• Group membership rosters
• Player statistics or achievement data
• Event locations or addresses
• Poll responses or free-text feedback
• Any data for advertising, profiling, or marketing purposes

4.4 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

5. Data Within the Service

5.1 Visibility to Other Users

Certain information you provide is visible to other users of the Service in the context of your groups:

• Your display name and profile icon are visible to members of groups you belong to
• Tournament results (finish positions, payouts) are visible to group members
• Achievement badges are visible on your profile within a group
• League standings are visible to group members and, if configured by the host, via a public standings URL

5.2 Spectator Access

When a host marks a tournament as public, limited tournament data (as configured by the host) is visible to unauthenticated spectators via a tournament URL or QR code. No spectator personal information is collected. Spectators do not see player profiles, historical data, or any information beyond what the host has explicitly enabled for public view.

5.3 Event Location Privacy

Event locations (typically a host's home address) are visible only to players who have confirmed their RSVP for that event, not to all group members. Hosts may further restrict location visibility through event settings.

6. Communication and Consent

6.1 No Unsolicited Contact

ScallyWagers does not send any communication to individuals who are not registered users with active notification consent. Invitations to join the platform are sent by existing users through their own personal communication channels, not through ScallyWagers' messaging infrastructure.

6.2 Per-Group, Per-Channel Consent

All notification channels are off by default for every group. When you join a group, you choose which channels to enable for that group. You may revoke consent for any channel in any group at any time without leaving the group.

6.3 Message Content

All messages sent through the Service use predefined templates. No freeform content from other users is transmitted through our messaging infrastructure. Every message includes the appropriate unsubscribe mechanism for its channel.

7. Data Retention

7.1 Active Accounts

While your account is active, all data associated with your account is retained and accessible to you.

7.2 Lapsed Accounts

If your subscription lapses, your data is retained intact for eighteen (18) months. During this period:

• Your account is in read-only mode
• You may log in to view your data and request an export
• You may resubscribe at any time and resume with full history
• You may request immediate deletion at any time
• No new events, tournaments, or group activity is permitted

At twelve (12) months post-lapse, we send a courtesy notification that your data will be anonymized in six months. At seventeen (17) months, a final reminder is sent.

7.3 Automatic Anonymization

At eighteen (18) months post-lapse, your account is automatically anonymized. This process is irreversible:

• All personally identifiable information (email, phone, name, nickname, avatar) is permanently removed
• Your tournament results, finish positions, and payout records are preserved with your identity replaced by "Former Member"
• Your group membership records are marked as anonymized
• Your achievements and personal statistics are deleted
• Your poll responses are retained with the user reference removed
• Your blind structures marked as public are preserved anonymously; private structures are deleted

8. Your Rights

8.1 Access and Export

You may request a complete export of your personal data at any time through your account settings.

8.2 Correction

You may update your personal information at any time through your account settings.

8.3 Deletion

You may request deletion of your account at any time. Deletion requests are honored immediately. Upon deletion:

• All personally identifiable information is permanently removed
• Records are anonymized (displayed as "Former Member")
• This action is irreversible
• Group ownership is transferred to the next eligible member or the group is archived

8.4 Communication Preferences

You may modify your notification preferences per group, per channel at any time through your account settings or by using the unsubscribe mechanism in any message.

8.5 GDPR Rights (European Users)

If you are located in the European Economic Area, you have additional rights under the General Data Protection Regulation, including the right to access, rectification, erasure, restriction of processing, data portability, and objection to processing. To exercise these rights, contact us at the address below.

8.6 CCPA Rights (California Users)

If you are a California resident, you have rights under the California Consumer Privacy Act. As stated in Section 4.1, we do not sell personal information. To exercise your other rights, contact us at the address below.

9. Data Security

We implement reasonable technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS) and at rest
• Access controls limiting data access to authorized personnel
• Audit logging of all administrative access to user data
• Regular security reviews of infrastructure and code
• Incident response procedures for potential data breaches

No method of transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

10. Data Breach Notification

In the event of a data breach that compromises your personal information, we will:

• Notify affected users within seventy-two (72) hours of confirmed breach discovery, via email and in-app notification
• Provide a description of the nature of the breach, the categories of data affected, and the measures taken in response
• Notify relevant supervisory authorities as required by applicable law

11. Children's Privacy

The Service is intended for users aged eighteen (18) and older. We do not knowingly collect personal information from children under 18. If we become aware that we have collected data from a child under 18, we will take steps to delete such information promptly.

12. Compliance Reference Content

The Service may provide general informational content regarding gambling laws in certain jurisdictions. This content is provided for informational purposes only and does not constitute legal advice. It may not be current, complete, or accurate for your specific jurisdiction or situation. It is not a substitute for consultation with a licensed attorney.

13. International Data

The Service is operated from the United States. If you access the Service from outside the United States, your information may be transferred to, stored in, and processed in the United States. By using the Service, you consent to such transfer and processing.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email to registered users and posted on the Service with an updated effective date. Continued use of the Service after changes constitutes acceptance of the revised Privacy Policy.

15. Contact Information

For questions, concerns, or requests related to this Privacy Policy or your personal data, contact:

ScallyWagers
PO Box 784 — Moultonborough, NH 03254
info@scallywagers.com

For data deletion or export requests, you may also use the self-service tools in your account settings.