Privacy Policy

1. Operator Identity and Contact

Rubicon Global Holdings Group LLC (“Rubicon,” “LudAlea,” “we,” “us,” or “our”) operates LudAlea Dealer's Choice and is responsible for the personal information described in this Privacy Policy. This Policy applies to LudAlea's websites, applications, games, and related services (collectively, the “Service”).

2. Account Information

When you register or manage an account, we collect information such as your email address, display name, authentication credentials in protected form, account identifiers, account creation and update times, and account status. We also process sign-in, sign-out, session, and account-recovery information.

We receive this information directly from you and generate some account and session records as you use the Service. Please do not share your password with us or other players.

3. Profile and Social Information

Depending on the features you use, we process your handle, display name, biography, avatar, optional location text, favorite games, profile visibility, friends and other social connections, invitations, blocks, mutes, equipped cosmetics, badges, and profile activity. We also process relationship and interaction records needed to apply social and privacy controls.

4. Gameplay Information

We process the games and variants you view or play; lobbies, tables, seats, waitlists, and tournaments you join; invitations and matchmaking activity; game settings; cards and authorized game state; actions, timers, results, histories, statistics, disconnections, and reconnects; and server events needed to operate authoritative gameplay.

Some gameplay and result information may appear to other players or spectators as part of the experience. We limit private-card and protected game state to authorized views, subject to security, integrity, moderation, and legal needs.

5. Communications and User Content

We process chat messages, reactions, display names, profile text, feedback, support requests, moderation reports, and other content you submit, along with related timestamps, recipients, table or feature context, attachments, and moderation status. Do not include sensitive personal or financial information in public profiles, chat, feedback, or reports.

6. Device and Technical Information

When you access the Service, we and our infrastructure providers may process IP address, browser and operating-system information, device type, language, approximate location derived from IP address, referring page, request and response timestamps, request IDs, network and connection status, cookie and session identifiers, local preference data, and diagnostic, performance, error, and access logs. We do not ask for precise device location for currently supported gameplay.

7. Security and Integrity Information

We process authentication events, session and authorization records, rate-limit events, reports, blocks, mutes, enforcement history, audit events, and signals associated with spam, abuse, cheating, collusion, unauthorized automation, exploits, account compromise, or other security risks. Integrity review may consider gameplay patterns, account relationships, device and network signals, and virtual-economy records.

8. Purposes for Processing

We use personal information to:

• create, authenticate, secure, and support accounts;
• provide authoritative games, Practice mode, multiplayer, social, and profile features;
• maintain Play Chip, progression, achievement, inventory, and reward records;
• personalize settings and remember supported preferences;
• communicate service, safety, support, and policy information;
• moderate content and investigate fraud, cheating, abuse, exploits, and incidents;
• debug, analyze, maintain, and improve reliability, accessibility, and player experience;
• protect our rights, users, systems, and the public; and
• comply with applicable law and valid legal requests.

Where applicable law requires a legal basis, we rely as appropriate on performing our agreement with you, our legitimate interests in operating and securing the Service, legal obligations, and consent where requested. You may withdraw consent for future processing when consent is the applicable basis, without affecting prior lawful processing.

9. Play Chip and Economy Records

We maintain Play Chip balances and ledger events, table buy-ins and returns, supported transfers, gameplay results, grants and corrections, progression, achievements, rewards, cosmetics, inventory, and equipped-item records. We use these records to display your virtual economy, resolve discrepancies, prevent abuse, and preserve game integrity.

Play Chips and virtual items have no cash or real-money redemption value and cannot be cashed out. The current Service does not require bank-account or payment-card information for supported gameplay.

10. Practice Mode and AI Player Processing

Practice mode uses AI-controlled opponents. Other supported experiences may also use them. We process the selected game and configuration, AI identity and seat, available game state, authorized actions, action timing, results, and technical diagnostics to run and improve those experiences. AI players are automated participants, not people. Current Practice mode is private and non-social and does not change Play Chips, progression, achievements, or cosmetic inventory.

11. Cookies and Session Technologies

We use cookies and similar session technologies that are necessary to authenticate users, maintain sessions, route requests, secure the Service, and remember supported settings. For example, a protected HttpOnly cookie supports refresh sessions, and browser storage may retain table preferences, mutes, temporary acknowledgments, and private notes on your device.

You can control cookies and site storage through your browser. Blocking required session technologies may prevent sign-in or other features from working. We do not describe an advertising-cookie program because the current Service does not use one.

12. Cloudflare and Infrastructure Processing

LudAlea uses Cloudflare and other infrastructure to deliver and protect the Service. Cloudflare may process IP addresses, request headers, security signals, traffic and timing data, and limited request or response information while providing content delivery, TLS, network routing, bot and abuse detection, and denial-of-service protection. Hosting, database, storage, logging, and network systems also process information needed to serve requests and maintain the Service.

13. Service Providers

We disclose information to vendors and contractors that provide infrastructure hosting, database and storage, network and security, diagnostics and monitoring, communications, and operational support. They may process information only for the services they provide to us, subject to contractual or other appropriate restrictions. The providers and locations used may change as the Service evolves.

14. Legal and Safety Disclosures

We may preserve or disclose information when we reasonably believe it is necessary to comply with applicable law, legal process, or a valid government request; enforce our Terms or other agreements; detect, investigate, or prevent fraud, cheating, abuse, security incidents, or illegal conduct; protect the rights, safety, and property of users, LudAlea, or others; or establish, exercise, or defend legal claims. We may notify affected users when permitted and appropriate.

15. Business Transaction Disclosures

If LudAlea is involved in a proposed or completed merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction, information may be reviewed, transferred, or disclosed to counterparties and advisers subject to appropriate confidentiality and legal safeguards. A successor may continue to process information under this Policy unless it provides notice of a change.

16. Public and Social Profile Information

Your handle, display name, avatar, biography, optional location text, equipped cosmetics, badges, progression, selected statistics, gameplay activity, and social relationships may be visible to other users when a feature presents them as public or social. Table participation, chat, reactions, results, and spectator-visible events may be visible to the relevant table or audience.

Review information before sharing it. Privacy, blocking, and mute controls limit supported interactions but cannot prevent another person from recording information they were permitted to see or erase copies already made outside LudAlea.

17. Data-Security Safeguards

We use administrative, technical, and organizational measures designed to protect personal information. Depending on the system, these measures include encrypted network transport, protected session cookies, authentication and authorization controls, least-privilege access, network protections, logging, monitoring, backups, and incident-response practices. No transmission or storage method is completely secure, so we cannot guarantee absolute security. Contact us promptly if you believe your account or information is at risk.

18. Data Retention

We retain personal information for as long as reasonably necessary to provide the Service and for the purposes described in this Policy, including account administration, game and economy integrity, security, moderation, dispute resolution, legal compliance, and enforcement. Retention periods vary based on the record's purpose, sensitivity, legal requirements, and whether it is needed to protect users or the Service.

When information is no longer reasonably needed, we take steps to delete or de-identify it. Limited copies may remain in backups until they are overwritten under normal cycles, or be retained when required for legal, safety, fraud-prevention, or recordkeeping reasons. We may retain aggregated or de-identified information that no longer reasonably identifies you.

19. Account Deletion and Privacy Requests

You may ask to access, correct, or delete account information, or ask a question about our practices, by emailing [email protected]. Include the email associated with your account and enough detail for us to understand the request. Do not send your password.

We may need to verify your identity or authority before acting. We will respond as required by applicable law. Deleting an account may not require deletion of information that must be retained for security, integrity, legal, or other permitted purposes, and some content may be de-identified instead. Account deletion ends access to Play Chips, progression, virtual inventory, and other account features, none of which can be cashed out.

20. California Privacy Rights Where Applicable

If and to the extent California privacy law applies to LudAlea and your information, a California resident may have the right to request that we disclose categories and specific pieces of personal information collected; sources, purposes, and recipients; and to request correction or deletion, subject to legal exceptions. California law may also provide rights concerning sale, sharing for cross-context behavioral advertising, certain uses of sensitive personal information, and nondiscrimination for exercising applicable rights.

The sections above describe the categories we collect, their sources and purposes, and the categories of recipients. Submit a request at [email protected]. An authorized agent may submit a request where permitted, but we may require proof of authority and verification of the resident. We will not discriminate against you for exercising a right provided by applicable California law.

21. No Sale of Personal Information to Advertisers

LudAlea does not sell personal information to advertisers.

The current Service also does not use personal information for cross-context behavioral advertising. If our practices materially change, we will update this Policy and provide any choices required by applicable law before the change applies.

22. Children’s Privacy and the 18+ Service

LudAlea is an 18+ product and is not directed to children. You must be at least 18 to create an account or use the Service. We do not knowingly collect personal information through the Service from anyone under 18. If you believe a person under 18 has provided personal information, contact [email protected] so we can investigate and take appropriate action.

23. International Users and Transfers

LudAlea is operated by a United States company. If you access the Service from another country, your information may be transferred to, stored in, or processed in the United States and other locations where our providers operate. Privacy laws in those locations may differ from those in your country. Where applicable law requires a transfer safeguard, we will use an appropriate legal mechanism.

24. Automated Systems and AI

AI players use automated systems to choose gameplay actions in Practice mode and may be used in other supported experiences. Those systems affect virtual game play; they do not make decisions about credit, employment, housing, education, or other similarly significant matters.

We may also use automated rules and signals to route requests, maintain server game state, apply rate limits, identify suspicious activity, prioritize moderation or security review, and enforce clear technical safeguards. You may contact us if you have a privacy question about automated processing associated with your account.

25. Third-Party Links and Services

The Service may contain links to or interoperate with third-party services. Their privacy practices are governed by their own policies, not this Policy. Review those policies before providing information. We are not responsible for a third party's independent practices, except where applicable law provides otherwise.

26. Changes to This Policy

We may update this Policy to reflect changes in the Service, our practices, or applicable requirements. We will post the revised Policy and update the “Last Updated” date. If a change is material, we will provide additional notice when reasonably appropriate. The revised Policy applies from its stated effective date.

27. Contact Information

For privacy questions or requests, contact: