PRIVACY POLICY

At HeroPoker, we
respect your privacy and are committed to protecting your personal information.
We have created this Privacy Policy to let you know what information we collect
when you visit the HeroPoker website, participate in the Games on our website
and make use of our online service (collectively, the "Service"), why
we collect this information and how we use the collected information. By using
the Service, you consent to the data practices prescribed in this Privacy
Policy. We may periodically make changes to this Privacy Policy by posting such
changes on this page without notice to you. It is your responsibility to review
this Privacy Policy frequently and remain informed about any changes to it, so
we encourage you to visit this page often.

This Privacy Policy
is governed by our Legal Terms and Conditions posted at www.HeroPoker.net. You
agree that in the event of a conflict between this Privacy Policy and our Legal
Terms and Conditions, our Legal Terms and Conditions shall prevail. Please see
our Terms And Conditions for further information.

The terms “we”,
“us”, “our” and the Company shall mean HeroPoker and the term “you” shall mean
you, being the user of the Service. The capitalized words and phrases used
herein shall have the meaning ascribed to them in our Legal Terms and
Conditions unless otherwise defined herein or the context otherwise requires.

## 1. Information Collected.

We consider
information that may be used to identify an individual, including, but not
limited to, first and last name, credit card information, home or other
physical address, email address, phone number or other contact information to
be "Personal Information." You may be asked to provide Personal
Information when you use our website, register for an account or to use our
services, download our Software, correspond with us by email, or provide us
with feedback regarding this website or our products and services. The Personal
Information that we collect may include: contact information, shipping
information, billing information, transaction history, website usage
preferences, and feedback regarding our products and services. In addition,
when you interact with the Service, our servers keep an activity log unique to
you that collects the information including: source IP address, time of access,
date of access, web page(s) visited, language use, operating system and type of
browser used. This is not considered Personal Information. In general, you can
visit our website without telling us who you are and without revealing any
Personal Information about yourself. We do not collect Personal Information
about you on the Service unless you voluntarily provide it to us.

## 2. Means of Collecting & Processing Data

We may automatically
collect certain data as discussed above and receive Personal Information about
you where you provide such information through the Service or other
communications and interactions with HeroPoker. We may also receive Personal
Information from online vendors and service providers that refer you to the
HeroPoker website. In addition, we may engage the services of third-party
service providers to provide technical support, process your online
transactions and maintain your online accounts. We will have access to any
information you provide to such vendors, service providers and third-party
e-commerce services so that we can process your transactions, maintain your
accounts, meet certain business requirements and provide you with promotional
offers and information regarding HeroPoker and our products and services. We
use this Personal Information to process your transactions and support your use
of the Service. Subject to our Legal Terms and Conditions and paragraphs 3 and
4 below, this information may be disclosed only to our staff and to third
parties involved in the completion of your transactions or in support of your
use of the Service.

## 3. Information Use

We use your Personal
Information to deliver the products and services you purchase, and to provide
customer support, to process any of your online transactions, to answer your
questions, and for any other purpose related to the operation of the Service
and the programs, products and services offered on the HeroPoker website. Your
Personal Information may also be shared with our affiliates, subsidiaries or
agents for technical support and to process transactions you initiate on the
Service and deliver the products and services you purchase. From time-to-time,
we may request information from you via surveys or contests. Participation in
these surveys or contests is completely voluntary, and, therefore, you may
choose not to disclose such information. Information requested may include
contact information (such as name and shipping address), and demographic
information (such as your zip code or postal code, your age or approximate age).
By accepting any contest prize or winnings from us, you hereby authorize us and
consent to our use of your name and likeness for advertising and promotional
purposes without any additional compensation to you, except where prohibited by
law. Unless you have elected not to receive promotional information, we may
also use your Personal Information (including your email address) to provide
you with information regarding our products, services and promotions. Personal
Information as well as any other information collected on the Service may be
disclosed to our staff, affiliates and/or agents so that they can contact you
regarding our products, services, or promotional offers, respond to your
requests, provide certain services to you and operate the Service. We will not
sell, lease or share your Personal Information except as set forth in this
Privacy Policy and our Legal Terms and Conditions, as applicable.

## 4. Certain Excluded Disclosures

We may disclose your
Personal Information as set out in our Legal Terms and Conditions, if requested
to do so by legal authorities or required to do so by law, or if we believe in
good faith that such action is necessary to: (1) conform to applicable laws or
to comply with any legal process served on us, the HeroPoker website or the
Service; (2) protect and defend our rights or property; or (3) act to protect
the personal safety of users of the Service or the public. If we should ever
file for bankruptcy or be acquired by a third party, merge with a third party,
sell all or part of our assets, or otherwise transfer substantially all of our
assets to a third party, you hereby agree and consent to any sale, transfer or
assignment by us to such third party of your Personal Information and all other
information you have provided to us through the Service.

## 5. Access

If you are
interested in confirming the accuracy of the Personal Information we have
collected about you, or if you would like to update your Personal Information
or delete your Personal Information, you may contact us at any time by sending
an email to legal@HeroPoker.net. If you have any concerns regarding our use of
your Personal Information, you may contact our customer service by email at
legal@HeroPoker.net. You may choose not to receive promotional communications from
us at any time by sending us an email to legal@HeroPoker.net.

## 6. Cookies

Cookies are small
text files that are stored on your computer when you visit certain web pages
that record your preferences. We use cookies to track your use of the HeroPoker
website. We also may use cookies to improve the Service and make it easier for
you to use. You have the ability to accept or decline cookies. Most web
browsers automatically accept cookies, but if you prefer you can usually modify
your browser setting to decline cookies. If you choose to decline cookies, you
may not be able to fully experience the interactive features of the HeroPoker
website and the Service.

## 7. Consent to Use of Anti-Cheating Software.

Our Software package
used to access and use the HeroPoker service ("Service") contains
certain features designed to detect use of automated programs that enable
artificial (non-human) intelligence to play on our site. Use of such
"bot" software programs violates our Legal Terms and Conditions, and
is detrimental to other players. By installing our Software and using the
Service, you consent to our Software performing the functions described in this
section. Our Software may perform any or all of the following functions in
order to detect the use of illicit automated programs and ensure that we
maintain a "cheat free" environment for all users: (1) scan your list
of active software applications while you are using the Service; (2) scan your
list of active processes while you are using the Service; and (3) scan the files
in your HeroPoker-related program folders to ensure that only
"non-hacked" versions of our Software are being used. If any of the
foregoing processes reveals a suspect application or process, our Software may:
(1) scan the files associated with the suspect application or process and
compile a composite mesh (i.e. a profile that characterizes the files
associated with the application or process) to be matched against profiles for
known illicit automated programs; and (2) capture a screenshot of your desktop
and transmit these to HeroPoker for review. Our Software will not perform any
random search of large portions of your hard drive or other files, and will not
transmit any information to us or to any third party other than the information
necessary to identify use of illicit automated program as described above. Our
Software will not alter any files or information on your computer and will not
interfere with the operation of any of your applications. You may terminate use
of our Software at any time by uninstalling the HeroPoker Software package.

## 8. Security

We understand the
importance of information security and the methods required to secure
information. We store all of the Personal Information we receive directly from
you in a password-protected database residing within our secure network behind
active state-of-the-art firewall software. The HeroPoker website and the
Service support SSL Version 3 with 128 bit encryption.

## 9. Protection of Children

The Service is not
intended for or directed to persons under the age of 21. Any person who
provides their information to us through any part of the Service represents to
us that they are 21 years of age or older. It is our policy to endorse the
Children's Online Privacy Protection Act of 1998 (US) and to use our best
efforts to comply with this Act.

## 10. International Transfers

Personal Information
collected on the Service may be stored and processed in any country in which we
or our affiliates, subsidiaries, suppliers, contractors or agents maintain
facilities, and by using the Service, you consent to any transfer of
information outside of your country.

## 11. Third-Party Practices

We cannot ensure the
protection of any information or images that you provide to a third-party
website that links to or from the HeroPoker website or any information
collected by any third party administering our affiliate program or any other
program, since these third-party websites are owned and operated independent of
us. Any information collected by these third parties is not governed by this
Privacy Policy but by the privacy policy, if any, of such third party. If you
have questions about a third party's information practices, please read its
privacy policy, if any. We assume no responsibility or liability whatsoever for
the practices, actions or policies of such third parties, and we are not
responsible for the content or privacy practices of such websites.

## 12. Legal Disclaimer

The Service operates
"AS-IS" and "AS-AVAILABLE," without liability of any kind.
We are not responsible for events beyond our direct control. Because of the
complex and constantly changing nature of our technology and business, we
cannot guarantee nor do we represent that there will be error-free performance
regarding the privacy of your Personal Information, and we will not be liable
for any indirect, incidental, consequential or punitive damages relating to the
use or release of your Personal Information.

## 13. Consent to Privacy Statement

By using the
Service, you agree to this Privacy Policy. This is our entire and exclusive
Privacy Statement and it supersedes any earlier version. Your continued use of
the Service constitutes your agreement to this Privacy Policy, as may be
amended from time to time.