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PRIVACY STATEMENT
Privacy: BluffSpotPoker.com is committed to safeguarding the information its users entrust to it. As a sign of our commitment to protect consumer privacy, BluffSpotPoker.com has submitted a certification for participation in the Safe Harbor program between the United States and the European Union. BluffSpotPoker.com subscribes to the Safe Harbor principles published by the U.S. Department of Commerce.

The Personal Information We Collect: BluffSpotPoker.com may collect personally identifiable information from users in a variety of ways, including online and offline subscription and order forms, paper or telephone submissions, and other instances where users are invited to volunteer such information. Additionally, contact information may be collected during any correspondence relating to member support, as well as in connection with products and services offered on BluffSpotPoker.com sites. We collect your name, business name and type, address, phone number, email address, billing information including credit card number and expiration date. We only use your name, address, billing information/credit card information to process your order. The addresses are used for customer support, required notifications, product and policy updates and marketing releases. Under no
circumstances will we use this information for anything else not described in this privacy notice. All users may at any time opt-out of our marketing by clicking the unsubscribe link located at the bottom of all marketing and membership notices.

Financial Information: Whenever users sign up for any product or service through BluffSpotPoker.com, we require financial information such as a
credit card number and billing address before we will process that application. We will not sell, share or rent any financial information collected except as disclosed in this policy or as necessary to fulfill orders.

Protocol (IP) Addresses: IP addresses are collected from all visitors to the BluffSpotPoker.com site. IP addresses are used to administer the daily operations of our site, to help diagnose problems with our servers, and to help prevent fraud.

Data Integrity: We make diligent efforts to maintain accurate information on our users. To prevent unauthorized access, maintain data accuracy, and
ensure the correct use of information, BluffSpotPoker.com has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect. If applicable, each new user email address is verified prior to receiving authorized passwords. ICANN mandated WhoIs verification notices are sent out annually for review to ensure accuracy.

Data Security: BluffSpotPoker.com has put stringent security procedures in place to protect information collected about our users. We constantly
monitor our systems, which are protected using industry-standard security measures. Secure Sockets Layer ("SSL") connections are used to communicate to our system to protect user financial information as well as encrypting vital information that users input through BluffSpotPoker.com's web sites. However, BluffSpotPoker.com cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure.

Cookies: BluffSpotPoker.com uses "cookie" technology in order to enhance our users' online experience and for authentication purposes, associating them with your personally identifiable information. They are also used for measuring certain traffic patterns, and to preclude you from having to re-enter your user ID or password during multiple visits to the site. Additionally, cookies can track your progress in online promotions so you receive coupons that may be available to you. Cookies may also be used by advertising service vendors that place ads on our site and to authenticate access to additional services provided by BluffSpotPoker.com at other web sites. Web browsers may be set to disable cookies, but please note that certain BluffSpotPoker.com services may not function correctly if cookies are not enabled.

How Information is used: BluffSpotPoker.com may contact users regarding products and services offered by BluffSpotPoker.com and its trusted affiliates, business partners, and independent contractors. We may also use information collected through our Web site for research regarding the effectiveness of the Web site and related marketing, advertising and sales efforts. Information will only be made publicly available where mandated by governing agencies or as disclosed in the terms and conditions of our agreements with users. We will not post any testimonials or comments made by our users without their explicit permission. Electronic communications may be sent by BluffSpotPoker.com using users' personal contact information to inform them of important industry news or about general services and upgrades provided by BluffSpotPoker.com. If a user does not wish to receive these industry notices, simply click the "unsubscribe" link located at the bottom of any notice email. However, in order to fulfill our service obligations, BluffSpotPoker.com will continue to send emails regarding users' account administration or service interruptions for system maintenance.

Disclosure: Information collected from customers may be disclosed to independent contractors and business partners, who have agreed to hold this information in confidence, not use it for any purpose except to carry out the service they are providing for BluffSpotPoker.com, and honor our privacy and security policies in the way this information is handled. BluffSpotPoker.com may also disclose aggregate, anonymous data based on information collected from customers to actual or prospective investors and partners. Should the sale of BluffSpotPoker.com's business ever occur, collected Customer information may be transferred along with the sale but the information will be treated in the same manner as this privacy policy.

Contact Information: ("ICANN"), the Internet Corporation for Assigned Names and Numbers, the organization which assumes responsibility for domain name allocation, requires accredited registrars to collect certain information about users during the domain name registration process. This information includes Registrant's full name, mailing address, phone number, email address, and, where provided, facsimile number. This collected information may be used, for example, to communicate when necessary with respect to transactions conducted through the Site. Additionally, contact information may be collected during any correspondence relating to customer support, as well as in connection with products and services offered on the Site.

3rd Party: If you opt to order third-party products or services made available through our site, we may fill in blanks on the order form for your convenience, using account data that you have previously provided us. When you click to place your order, the data will be sent those 3rd parties. These 3rd parties have agreed to hold this information in confidence, not use it for any purpose except to carry out the service they are providing us, and honor our organization's privacy and security policies in the way this information is handled. BluffSpotPoker.com does screen and choose its business partners and affiliates with our privacy goals in mind.

Miscellaneous Information: Certain additional non-personal types of information are collected and stored whenever users interact with us. This information is collected to better develop and offer those products and services which are most desired within our industry. For example, our servers track the page to which user link from BluffSpotPoker.com and the type of Web browser used. No personally identifiable information will be linked to this aggregated information, which may be shared with partners, market researchers and other third parties on an aggregate, non-personally identifiable basis.

Sites Other Than BluffSpotPoker.com: We strongly recommend that users review the privacy statement and policies of any online service prior to submitting personal information. BluffSpotPoker.com has no control over and is not responsible for the gathering practices of other Web sites, including those to which we may link and those which may link to us.

Enforcement: To better protect user privacy we closely monitor our privacy practices and privacy statements through in-house automated and manual procedures. For further protection there are independent recourse mechanisms available to investigate and resolve complaints, such as those provided by BBB Online or ICANN.

Revisions or Changes: Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

How to Contact Us: Should questions concerning this privacy policy arise, please send us an email at compliance@BluffSpotPoker.com . Please specify "Privacy Statement" in the subject line of this e-mail.

UPDATED: 03/2009