1. Introduction
At Playcer, we respect your privacy and are committed to protecting your personal data. Because Playcer is a platform that facilitates peer-to-peer social wagers, federal and state laws require us to collect specific, sensitive information to ensure that all users are of legal age, properly identified, and physically located in permitted jurisdictions. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services (the "Service").
2. Information We Collect
To provide a secure and legally compliant environment, we must collect the following categories of information:
2.1. Identity and KYC Data (Know Your Customer)
- Government-Issued ID: To verify your age and state of residence, we collect images of your Driver's License or State Identification Card.
- Biometric Data: If utilizing automated identity verification, we may collect facial recognition data (a "selfie") to match against your Driver's License.
- Contact Information: Full legal name, date of birth, email address, physical address, and phone number.
2.2. Location Data (Continuous Tracking)
- Precise Geolocation: To comply with the Interstate Wire Act and state gaming regulations, we collect continuous, precise, real-time location data (via GPS, WiFi triangulation, and cell tower data) while the app is in use. We also collect data regarding your device's network connections to detect VPNs or proxy servers.
2.3. Financial and Transactional Data
- Payment Information: Bank account details, debit card numbers, or other payment routing information used to fund your account or withdraw balances.
- Wager History: Records of the challenges you initiate, accept, and settle, including the amounts wagered and the opposing users.
2.4. Device and Usage Data
Device identifiers (IMEI, MAC address), operating system, IP address, and anti-spoofing diagnostic data.
3. How We Use Your Information
We do not sell your personal information. We use the data we collect primarily for compliance, security, and the facilitation of the Service:
- Legal Compliance: To verify your identity, age, and state of residence to comply with Anti-Money Laundering (AML) laws and jurisdictional gambling exemptions.
- Geofencing: To ensure you are physically located in a Whitelisted State before facilitating any wager.
- Fraud Prevention: To detect and prevent unauthorized access, location spoofing, collusion, and other illegal activities.
- Platform Operation: To securely hold funds in escrow, facilitate the settlement of bets, and provide customer support.
4. How We Share Your Information
Because Playcer is a third-party administrator, we rely on specialized, highly secure partners to help us run the platform safely. We may share your data with:
- Identity Verification Partners: Third-party KYC providers who securely process your Driver's License and verify your identity on our behalf.
- Geolocation Service Providers: Industry-standard compliance partners (e.g., GeoComply) who process your location data to authorize or block your access based on your physical location.
- Payment Processors: High-risk merchant services and banking partners that securely process your deposits, escrow accounts, and withdrawals.
- Law Enforcement and Regulators: We will disclose your information if required by law, subpoena, or request from state gaming commissions or federal authorities.
5. Data Retention and User Rights
While we respect your right to request the deletion of your personal data, please note that financial and gaming compliance regulations often legally require us to retain KYC, location, and transactional data for a minimum number of years (typically 5 to 7 years), even if you close your account. We will securely store this data for the legally mandated period and permanently destroy it once that period expires.
6. Data Security
Playcer implements bank-level encryption and robust security protocols to protect your sensitive identity and financial data. However, no electronic transmission or storage is entirely secure. By using the Service, you acknowledge the inherent risks of transmitting personal data over the internet.
A solid Privacy Policy relies heavily on the specific third-party vendors you use. Have you already selected your compliance partners for the ID scanning (KYC) and the geolocation tracking?