1. Introduction

1.1. This Privacy Policy sets out the way in which WSOP Academy™ ("we" or "us") processes your Personal Data. WSOP Academy™ is operated by BRACELET IP LIMITED, a company incorporated in the Republic of Ireland with its registered office in Suite C, Third Floor, Apex Business Centre, Blackthorn Road, Sandyford, Dublin 18, Ireland D18 DP3C which, together with its affiliates, in turn forms part of NSUS Group.

1.2. WSOP Academy™ collects, Processes and retains Personal Data, and takes the steps below with the intent to protect such Personal Data.

1.3. By utilising our Services, you acknowledge that you have read the terms of this Privacy Policy. If you do not wish to provide your Personal Data on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website/App or provide your Personal Data to us otherwise. However, if you do not provide your Personal Data, you may not be able to use all of the Services.

1.4. Capitalised terms not defined in this Privacy Policy shall be as defined in the WSOP Academy™ Terms & Conditions (the "Terms & Conditions") which are available at https://www.wsopacademy.com/terms-and-conditions.

1.5. Definitions:

The following terms "Anonymisation", "Controller", "Processor", "Data Subject", "Data Portability" "Personal Data", "Processed/Processing", "Pseudonymisation", "Cross-Border processing of Personal Data", "Aggregate," "Sensitive Data," and "Supervisory Authority" used in this document shall have the same meaning as the same or similarly defined terms in the GDPR and other applicable privacy laws, such as the CCPA.

• "Group" means the NSUS group companies.
• "Services" means all the functionality of the WSOP Academy™ App and wsopacademy.com (the "Website").
• "You" means the player, the 'Data Subject' who is using the services of WSOP Academy™.
• "Visitor" means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Website or Service.

2. The Personal Data we collect

We collect data about you in different ways. For example, we collect data:

• Directly from you. This includes when you make an account, sign up to get our emails, make a purchase from us, or contact us.
• Automatically. This includes through cookies, server logs, and other tools on our website or apps.
• From other sources. These can include our affiliates, vendors, publicly available sources, and other companies.

2.1. Account Registration and Use. As part of providing you with the Services, we collect basic account data where available, such as email address, username or nickname, account ID, account status, avatar/profile image, authentication or login information, and related account settings.

2.2. Quiz, Lessons and App Progress. We collect information about your use of the Services, including Poker IQ quiz answers, lesson progress, XP, achievements, leaderboard activity, time logged in, and other app interactions.

2.3. Payments and Subscriptions. We may collect subscription status, in-app purchase entitlements, and transaction identifiers needed to provide the Services. Payments made through Apple®, Google®, or other payment providers are processed by those platforms or providers in accordance with their own terms and privacy policies. WSOP Academy™ does not directly collect your payment card or bank account details.

2.4. Analytics and Technical Data. We collect technical and analytics information about your use of the Services and Website/App, including device information, IP address, log data, cookie or similar technology data, and interaction data. This may include analytics collected through Google® Tag Manager and Segment on wsopacademy.com.

2.5. Aggregated Data. We may collect, use and share aggregated statistical data that does not directly identify you.

2.6. Sensitive Data. We do not intentionally collect government ID, precise geolocation, financial account credentials, payment card or bank details, or other Sensitive Data unless expressly stated or required by law.

3. How we will use your Personal Data

3.1. When providing our Services, we collect, retain and process your Personal Data in accordance with relevant privacy laws. We have set out below, in a table format, a description of how we will use your Personal Data and the lawful basis we rely on to do so.

3.2. If at any time you wish us to stop Processing your Personal Data for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so, if so eligible. Please note that this may mean that your Account will be closed. You may contact us at [email protected].

3.3. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for new purposes is compatible with the original purpose, please contact us.

3.4. In the event that we need to use your Personal Data for an unrelated purpose, then we will notify you by a Privacy Notice whereby we will inform you of the changes and seek any additional consent that may be required.

4. Disclosing your Personal Data

4.1. We may disclose your Personal Data to the following third parties where needed to provide, support, secure, operate, improve, or comply with obligations relating to the Services:

• Any company within our Group (including to its employees and subcontractors) which assists us in providing the Services or which otherwise has a need to know such information;
• Any company providing a linked service or platform, including GGPass, Apple®, Google®, or another partner where needed to provide the Services;
• Any service provider which assists us in providing the Services, including hosting, infrastructure, authentication, analytics, customer support, marketing, payment, security and operational service providers;
• Analytics and tag-management providers, including Google® Tag Manager and Segment where used;
• Any contractors or other advisers auditing any of our business Processes or who have the need to access such information for the purpose of advising us;
• Any law enforcement, regulatory body, authorised entity, or competent authority where required or permitted by law;
• Any potential purchaser of WSOP Academy™ or any investors in it or in any company within our Group (including in the event of insolvency); and
• Any third party where you consent or direct us to share the data.

4.2. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with instructions.

5. International Transfers

5.1. Companies within our Group and some of our external third parties are based outside the EU/EEA so their processing of your Personal Data will involve a transfer of data outside the EU/EEA.

5.2. Whenever we transfer your personal data out of the EU/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for Personal Data; or
• We will use Standard Contractual Clauses which give Personal Data the same protection it has in the EU.

5.3. In accordance with Art. 45 of GDPR we provide your personal data to our inter-company recipients, other third parties and suppliers in the following countries:

• Canada, based on the adequacy decision of the European Commission of 20 December 2001;
• South Korea, based on the European Commission's decision of 17 December 2021;
• United Kingdom, based on the European Commission's adequacy decision of 28 June 2021;
• Switzerland, based on the European Commission's decision of 26 July 2000.

In accordance with art 46 (2) of GDPR we may provide your personal data to our identity verification and mailing system services suppliers, and partners in prevention of fraud/ cheating in the following countries based on Standard Contractual Clauses:

• Philippines;
• United States of America.

6. Data Subject Rights

6.1. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Under certain circumstances you have rights under data protection laws in relation to your Personal Data.

Some jurisdictions provide you with the following rights:

• The right to access and confirm our processing of your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you, confirm that we are Processing your data, and check that we are lawfully processing it.
• The right to rectification of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• The right to erasure of your Personal Data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• The right to restrict processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• The right to object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• The right to data portability of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

You have the right to opt out of promotional emails. You can stop receiving promotional emails by following the unsubscribe instructions at the bottom of those emails. If you choose not to receive such emails, we may still send you service-related communications.

The right to obtain a list of third parties to which we have disclosed Personal Data. Some jurisdictions also allow you to obtain a list of the categories of third parties to which we have disclosed Personal Data. You can find that information in the section above called "Disclosing your Personal Data".

6.2. If you wish to exercise any of the rights set out above, you may contact us by email: [email protected]. We will retain your information for as long as your account is active, as needed to provide you services, or to comply with our legal obligations, resolve disputes and enforce our agreements as described in section 11.

6.3. You may also update, correct, or delete your Account information and preferences at any time by accessing your Account settings by following the next steps: Profile > Settings > Manage Account. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. Where appropriate and possible we shall apply Anonymisation or Pseudonymisation to Personal Data to reduce the risks to Data Subjects.

6.4. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

6.5. We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

6.6. In some circumstances, you may designate an authorized agent to exercise rights on your behalf. If you are an authorized agent, you must provide a written and notarized letter giving you permission to act on another's behalf.

6.7. If you disagree with our denial of a request, you may also appeal our decision by contacting us with the subject line "Appeal."

6.8. Should we fail in abiding with the required data protection obligations, you shall have the right of complaint to the Data Protection Commission.

7. Contacting us

7.1. If you have any questions, comments, or complaints on our privacy practices, or if you need to access this Policy in a different form due to a disability, please contact us at [email protected] and we will seek to promptly determine and correct the problem.

8. Cookies

8.1. If our Website/App uses cookies, Google® Tag Manager, Segment, or similar technologies, we will provide clear information about those technologies and, where required, request your consent before using non-essential cookies or similar technologies. If we use tags for targeted advertising or cross-context behavioural advertising in the future, we will provide any required notices, consents, and opt-outs.

9. Minors and Children's Privacy

9.1. Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18 or the age of majority in your country of residence, whichever is higher ("Minors"), and we do not knowingly collect Personal Data from Minors. Users are required to confirm they are 18 or older during onboarding. WSOP Academy™ v1 does not collect date of birth or perform KYC age verification. If you are a Minor, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from a Minor, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child who is a Minor has obtained an Account on the Service, then you may alert us at [email protected] and request that we delete your child's Personal Data from our systems.

10. Security

10.1. We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. WSOP Academy™ has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services Processing Personal Data, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

10.2. No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, however, we shall ensure that adequate security mechanisms designed to protect Personal Data will be used to prevent Personal Data from being stolen, misused or abused, and to prevent Personal Data breaches. If you believe your Personal Data has been compromised, please contact us at [email protected].

11. Data Retention

11.1. Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes, including for the purposes of satisfying any legal, regulatory, platform, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

11.2. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

12. Data Protection Officer/Representative

12.1. Our data protection officer who is responsible for matters relating to privacy and data protection at WSOP Academy™ can be reached at: [email protected].

12.2. In accordance with the applicable legal regulations governing the protection of Personal Data, each request/inquiry will be resolved without undue delay and as required by applicable law.

12.3. When contacting and posting such requests, we will invest reasonable efforts to confirm your identity and to prevent unauthorized Personal Data processing.

13. Changes to this Privacy Policy

13.1. We may update this Policy from time to time. The updated Policy will be made available through the Services or on the Website, together with its effective date.

14. GGPass Service

14.1. GGPass offers a Single Sign-On (SSO) for enhanced onboarding and account management across other platforms within the GGNetwork.

14.2. By utilising GGPass to facilitate access to other platforms within the GGNetwork, You agree to the transferring of your data to a third party. The legal basis for the transferring of that data is your Consent. The third party acts as a separate Data Controller, and any data processing performed by it is done independently of Us. GGPass branding is displayed during the login/account process. Please see GGPass's privacy notice for more information on how they handle Your Personal Data.

14.3. User information that may be transferred through the GGPass service to WSOP Academy™ includes basic account data where available, such as email address, username or nickname, avatar/profile image, account ID, account status, and authentication or login information.

14.4. GGPass does not share your Social Security number, government ID, payment card details, bank account details, financial account credentials, precise geolocation, KYC data, or date of birth with WSOP Academy™.

15. Validity

This document was updated on 11 June 2026 and is effective from that date.

Contact: Data Protection Officer
Email:[email protected]
Company Address: Suite C, Third Floor, Apex Business Centre, Blackthorn Road, Sandyford, Dublin 18, Ireland D18 DP3C

16. Additional Information for US Residents

Certain US jurisdictions require us to disclose the following information on our privacy practices. If you are a US resident, the following disclosures apply to you in addition to the rest of the Policy.

16.1 Additional Sharing Details

Some jurisdictions require us to disclose whether the following categories of Personal Data are collected, shared with third parties for a business purpose, shared, sold, or transferred for valuable consideration. The table below indicates the categories of Personal Data we collect and transfer in a variety of contexts. We do not sell your Personal Data for money or share your Personal Data for cross-context behavioral advertising based on the current v1 setup. If the Website or Services use tags for targeted advertising or cross-context behavioral advertising in the future, we will provide any required notices, consents, and opt-outs.

16.2 Deidentified Information

To the extent we store and use deidentified Personal Data, we will not try to reidentify the information, except to test our deidentification methods. If we share deidentified data, we will obligate the recipient not to try to reidentify the data.

16.3 Financial Incentive Program

WSOP Academy™ offers XP, achievements, rankings, and similar in-app progress features for completing lessons and challenges successfully ("Incentive Programs"). These features are part of the Services and may be considered a loyalty or financial incentive program under certain US state laws. Information used in connection with these features may include basic account data and app activity, such as username or nickname, account ID, quiz answers, lesson progress, XP, achievements, leaderboard activity, and other in-app results. WSOP Academy™ does not sell or share Personal Data collected through these features for cross-context behavioral advertising. The value of these features is reasonably related to the value of the Personal Data used to provide and administer them. You may stop participating by discontinuing use of the relevant Services or by deleting your account, subject to the Terms & Conditions. Under the current v1 setup, XP is an in-app progress number only and is not redeemable for money, prizes, freerolls, tickets, coupons, or other financial benefits.