política de privacidad

Last Updated on May 22nd, 2023 

Introduction and Overview

AlgoSoftware DMCC (“Company”, “we”, “us” or “our”) provides services and technologies to facilitate analytics and training to help users improve their card game strategy.

Specifically, the current platform offered by Us is called Flophero (“Flophero” or “Platform”).  The Platform may be accessed through the Company website and/or such other online or mobile applications that may be available from time to time, which may also provide additional information or enable non-users of the Platform to engage with Company, and which may be subject to separate or additional policies or terms of use.

  • By accessing and using Flophero you may be submitting certain types of information about yourself or through which you may be identified or identifiable (“Personal Data”). Please read this Privacy Policy carefully, as it describes how we may collect, use, store, transfer, modify, disclose and otherwise use your Personal Data (hereafter referred to as “Processing” or “Process”) and your rights in this regard. It is also important that you read, understand and agree to our Terms and Conditions, available here.  If you do not agree to this Privacy Policy and the Terms and Conditions, you may not access or use the Platform. 

We have developed this Privacy Policy so that we can provide you with a clear, concise and transparent overview of the following:

  • the types of Personal Data that we collect from you and how we collect it;
  • how we use and otherwise Process your Personal Data;
  • the reasons, or “lawful bases”, that we rely on for Processing your Personal Data in the manner that we do;
  • how we store and the measures we take to protect your Personal Data;
  • how long we retain your Personal Data;
  • your rights in relation to the Personal Data we have about you;
  • how you can contact us to ask any questions about this Privacy Policy, your rights under it, or to make any complaints about how we are Processing your Personal Data.

Further information about all of the above points is set out in the following sections.



What Types of Personal Data Do We Collect and How Do We Collect It?

There are three basic categories of Personal Data that we may collect and manners in which we may collect it.  These are:

  • Personal Data you choose to give us.
  • Personal Data we obtain when you access or use the Platform.
  • Personal Data we receive from third parties.
Personal Data You Choose to Give Us

When you access or use the Platform, we may collect and Process certain Personal Data that you choose to give us.  This may include:

  • your name and contact details (e.g. email address and phone number);
  • a unique user name and password;
  • your city and country of residence;
  • your nationality;
  • your age;
  • historical information about your use of similar third party platforms or websites, which may include your relevant user name, and game and outcome metrics and data;
  • a profile picture;; and
  • such other information as we may deem to be reasonably required or desirable in connection with your use of the Platform from time to time.

We may collect some of the above Personal Data provided by you, for example, where you decide to register as a user of the Platform.  By choosing to provide us with any such Personal Data, you are consenting to us Processing it in the manner described in this Privacy Policy, and as also may be further explained or notified to you on the Platform from time to time.

Personal Data We Obtain When You Access or Use the Platform

When you access or use the Platform, we may collect information about which specific pages/areas you’ve used or visited, how you’ve used or interacted with them, how often you visit them, and other types of automated data collection. This may include:

  • Usage information, for example how you interact with the Platform, your activity on it, how often and the duration of time that you use it;
  • Device information (this may include device type, operating system version, language, etc.);
  • Network information, such as your internet and/or mobile network connections, service providers, IP address and signal strength;
  • Location information, such as the geographic location where you are accessing the Platform from, or to facilitate any agreed monitoring analytics of registered users of the Platform; and
  • Information collected by cookies and similar technologies (for example your activity, browser, and/or device), subject to your ability to manage your cookie preferences through the settings on your browser or device.
Personal Data We Receive From Third Parties

Depending on the nature of your access and use of the Platform, we may also receive Personal Data about you from third parties which have legally acquired such information and have the legal right to share it with us.  For example, through social media platforms such as when you elect to register to use the Platform through your relevant account with such social media platforms.  We may also receive data regarding usage information and other related information from third party analytics providers.   


How Do We Use and Otherwise Process Your Personal Data?

We may use the Personal Data that you have given us to:

  • Reply to any contact inquiries you have made to us;
  • Send you updates by way of email and/or deliver our newsletters, if you have subscribed for this;
  • Operate and further develop, maintain and improve the Platform, which may include using the Personal Data to further develop Platform algorithms;
  • Send you notifications related to your use of the Platform and respond to any support-related inquiries you may have initiated;
  • monitor and analyze your usage trends;
  • provide you with the services that you have subscribed for on the Platform in accordance with their respective Terms and Conditions;
  • verify your identity when accessing the Platform in order to prevent fraud or other unauthorized access and/or illegal activity;
  • enhance and/or customize your use and experience with the Platform; and
  • enforce our Terms and Conditions and any other applicable policies (such as usage policies).

We may share your Personal Data with third party processors to whom we have outsourced certain activities from time to time.  Where we do so, we will ensure that such third party processors have in place adequate security standards and measures to protect your Personal Data that are as least as stringent as the ones that the Company uses.  We may also share your Personal Data with third parties for legal reasons, such as where we may need to (i) comply with any valid legal process, government or regulatory authority request, or any applicable law or regulation; (ii) investigate or enforce potential violations of our Terms and Conditions in relation to the Platform; (iii) protect the legal rights, property, and/or safety of us, our users, or other third parties; or (iv) detect and resolve any fraud, security or legal violation concerns.

From time to time, and in order to fulfil the purposes for processing your Personal Data as described in this Privacy Policy or to facilitate your use of the Platform in accordance with its Terms and Conditions, we may transfer your Personal Data to other countries. If and when we do this, we will rely on certain lawful bases to justify such transfer (these lawful bases are further described in the section below).  This may include your consent and our reliance on certain model contractual clauses that set forth privacy protections and security standards.  Some countries where we might transfer your Personal Data may have privacy laws and regulations that are different from (and may be less stringent than), the laws of your home country.


What Reasons, or “Lawful Bases”, Do We Rely on for Processing your Personal Data?

There may be different reasons (or “lawful bases”) that we rely on to establish the grounds for Processing your Personal Data.  These may include:

  • Your consent. You are able to remove your consent at any time. You can do this by contacting us through the details set out below.
  • The Processing is necessary to protect public interest, including the public health.
  • Where the Personal Data has already become public through an act or disclosure that you have made.
  • We have a contractual or legal obligation or right that requires the Processing to take place, or the Processing is necessary to perform a contract to which you are a party or which a third party has entered into on your behalf (for example, your employer has entered into an agreement with us for use of the Platform and you are designated as one of the authorized users).
  • We have a legal obligation, or the Processing is needed in connection with legal proceedings or judicial or security-related reasons.
  • We have a vital interest, or we need to Process the Personal Data to perform a public task.
  • The Processing is for archival, scientific, historical or statistical studies in compliance with applicable laws.
  • We have a legitimate interest in conducting the Processing.

Wherever possible and practical, we will endeavour to obtain and rely on your consent as our primary lawful basis for Processing your Personal Data. 


How Do We Store and Protect Your Personal Data?

The Company takes the safety and security of your Personal Data seriously.  We will ensure that your Personal Data is securely stored, and that adequate security measures and standards are in place to protect it from unauthorized use or disclosure.


How Long Do We Retain Your Personal Data?

We will only retain your Personal Data for the period of time that it is reasonably necessary to fulfil the actual purposes that we collected it for.  So for example, if you register to use the Platform, we will retain the Personal Data you provided for this purpose for at least so long as it is necessary to facilitate your access to and use of the Platform.  When any such purposes come to an end, we will then safely and securely dispose of your information by deleting it from our systems, or for certain information we may retain this in an anonymized format to use for purposes such as the further development of the Platform and training of Platform algorithms.   However, notwithstanding the above, we may be required to retain your Personal Data (or parts thereof) in order to fulfil our obligations in respect of any applicable legal or regulatory requirements about information retention, in which case we will retain your Personal Data in accordance with such requirements. 


What Are Your Rights in Relation to the Personal Data We Have About You?

Under applicable data protection laws and regulations, you have certain rights in relation to the Personal Data that we hold about you.  These rights include:

  • Your right of access – this means that you have the right to ask us for copies of the Personal Data that we hold about you.
  • Your right to rectification – this means that you have the right to ask us to correct Personal Data you think is inaccurate or to complete Personal Data that you think is incomplete.
  • Your right to erasure – this means that you have the right to ask us to erase your Personal Data or parts of it, in certain circumstances.
  • Your right to restriction of Processing – this means that you have the right, under certain circumstances, to ask us to restrict the Processing of your Personal Data.
  • Your right of objection – this means that you have the right to object to the Processing of your Personal Data in certain circumstances.
  • Your right to data portability – this means that you have the right to ask that we transfer the Personal Data you gave us to another organisation, or to you, in certain circumstances.

You may contact us at any point using the details below to exercise these rights.


Third Party Websites or Links

From time to time, the Platform may contain links to other websites and/or applications. We make no representations or warranties as to the content, privacy practices and other practices of any such websites or applications operated by third parties and we do not assume responsibility for the content or practices of such websites, nor should you consider any such links as an endorsement by the Company. You should check the terms and conditions and privacy policies of all third party websites you visit to understand their terms and procedures, as they may differ from ours. If you visit any third party linked website or application, you do so solely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive material, and to ensure that their privacy practices are adequate for your purposes. The Company is not responsible for anything that may happen when you use or rely on any third party linked websites or applications.


Governing Law, Jurisdiction and Language

This Privacy Policy will be governed by the laws of the Dubai International Financial Centre (“DIFC“). Any dispute regarding this Privacy Policy will be subject to the exclusive jurisdiction of the Courts of the DIFC.

This Privacy Policy may be published in English and Arabic. If there is any inconsistency between the English text and the Arabic text, the English text will prevail.


Contact Information

You can contact us regarding this Privacy Policy at [email protected]