Privacy Policy

1. Who we are and what this policy covers

Belote Pro is operated by Monti Games, ABN 52 253 846 298, Australia ("Monti Games", "we", "us" or "our"). Contact us at support@belotepro.com.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you use Belote Pro through belotepro.com, our mobile applications, Facebook Instant Games, and the account, support and social features that go with them (the "Service"). It also explains the choices and rights available to you. Features and the information collected differ by platform, country and the functions you use.

We are the controller of personal data for processing we determine under applicable European data-protection law, and we are responsible for it under the Australian Privacy Act 1988 (Cth). Some platforms, payment companies and advertising providers also process information for their own purposes under their own privacy notices. Mandatory rights under applicable local law continue to apply.

Reading this policy confirms that you have received information about our practices. It is not blanket consent to all processing. Where consent is required, including for personalised advertising, we request it separately and let you withdraw it.

2. Adult audience, platforms and regional features

Belote Pro is intended for adults aged 18 or older, or any higher minimum age required in your location. This is an operator rule that applies everywhere, including where the virtual-coin economy is not offered. We do not intentionally offer accounts to people below the applicable minimum age, and we do not ask for your date of birth; if we learn that an account belongs to someone under age, section 15 applies. On first start, the website and the mobile apps ask you to confirm that you are 18 or older; this is a self-declaration stored on your device, not an age verification.

Belote Pro is age-rated through the International Age Rating Coalition (IARC), whose certificate applies the ratings of the participating authorities (for example PEGI, ESRB, USK, ACB, ClassInd and GRAC) to each store listing. IARC Certificate ID: 587c01a2-0b4b-8e0e-8200-3f62397f9f0f. The rating shown in a store describes the content; our 18+ rule above applies regardless of that rating.

The Service contains advertisements and, where available, in-app purchases. What is available depends on your platform and location:

• On the web, Android and Facebook Instant Games the game includes a virtual-coin economy ("gems"): coin purchases, staked tables, pots, a daily bonus and rewarded advertisements.
• On iOS the virtual-coin economy is not offered at all: no purchases, stakes, pots, bonuses or rewarded advertisements. Interstitial advertisements may still be shown between matches.
• In locations we designate, purchases or the whole virtual-coin economy are switched off for players who appear to be there (section 3 explains the signals). Free card play, scores and rankings remain available.

Virtual coins, where available, cannot be redeemed for cash or real-world prizes. The Terms and Conditions explain these features in detail.

3. Information we collect

Account and profile information. An account identifier that we generate (guest accounts and linked accounts alike), a display name (one we generate such as "Guest-123456", or the name your sign-in provider supplies), an avatar (a preset picture, or the profile picture your sign-in provider supplies, which we copy at a reduced size), your account settings (public profile on or off, country detection on or off, whether you have acknowledged the notice about computer-controlled players), the sign-in method you linked and the identifier that provider uses for you, when the account was created and when it was last active, which platform it was created on and last seen on, and a durable device identifier described in section 8.

We do not store your email address, phone number or password. If you sign in with a social account or with email, the sign-in provider verifies you and tells us your provider identifier, name and picture; any email address in that response is discarded (the part before "@" may be used once as a fallback display name for a brand-new account). Passwords, where you use one, are held only by the sign-in provider.

Gameplay and social information. Matches you play (variant, result, rounds, scores, contracts, declarations, the cards played and their timing while a match is live), statistics derived from them (wins, losses, capots, streaks), your skill rating and rank, your Fair-Play reputation (whether you finished or abandoned matches), friends and friend requests, club membership (club name, tag and join code), referral codes and referrals, and the predefined emotes you send at a table. Chat consists only of a fixed set of emotes; there is no free-text messaging. Matches may include computer-controlled players operated by us (section 7). Where the economy is enabled, this also includes your coin balance, stakes, pots, awards, deductions and transaction history, which we keep as an append-only ledger. A display name or account identifier can make gameplay records personal information even though they do not contain your legal name.

Purchases and billing information. We receive what is needed to deliver and support a purchase: the coin bundle, price, currency, a transaction or receipt identifier, the time of purchase, its status and any refund. Where purchase restrictions apply, the billing country and region reported by the payment provider or app store are checked after payment. The payment provider or app store handles your payment method and, for web purchases, collects your email address for its receipt; we do not receive or store full payment-card numbers, card security codes or your billing address. For website purchases we also record the time you ticked the immediate-delivery consent at checkout (section 12 of the Terms), as evidence of that consent; it is kept with the purchase record.

Device and technical information. Your IP address while you are connected, browser or app type and version, operating system, language, your device's time zone (sent by the app for the eligibility checks below), a session identifier, error and diagnostic messages (including short reports the app sends when an advertisement fails to load), and service performance information. We do not use a crash-reporting or third-party analytics kit. Advertising identifiers and advertising events are processed by the advertising network under the settings described in section 8; we do not store them.

Approximate location and eligibility information. We infer your country and, where available, your region from your IP address, using the location headers of our content-delivery provider or, failing that, an IP-location provider. Unless you switch country detection off, we store that country and region on your account the first time you sign in, to show a flag on your profile. For the regional restrictions described in the Terms we may also compare the current IP location, the account's first-seen location, your device's time zone and the billing country or region reported after a payment, and we check whether the connection appears to come from a VPN, proxy, Tor exit or data centre. These signals are approximate. When a purchase or economy action is blocked, we record the signals used for that decision, including the IP address, for the period stated in section 11. We never request precise (GPS) location.

Support and preferences. Correspondence you send to support, privacy requests you make, your advertising-consent choice, and your notification choices. Please avoid sending sensitive information about yourself or others.

4. Where information comes from

We receive information directly when you play, purchase, change settings or contact us; automatically when your device connects to the Service; and from the providers involved in sign-in, payments, app distribution, content delivery, advertising and location checks. Other players may include your display name in a friend request, invite or referral. We also create information such as statistics, ratings, reputation and eligibility results from your use of the Service.

Guest access is available without registering. A guest account still has an identifier, gameplay records and a device identifier, so guest access is not anonymous in the sense of preventing all collection.

5. Why we use information

We use information to provide accounts and requested features; run matches and matchmaking; maintain statistics, ratings and leaderboards; run the virtual-coin economy where it is offered; deliver purchases and handle refunds and support; display advertisements; remember your choices; diagnose faults; improve gameplay; detect cheating, collusion and abuse (for example the once-per-device welcome grant); protect accounts; apply regional and age rules; produce aggregate, first-party usage statistics; and comply with applicable legal requirements.

We also use relevant records to investigate disputes, correct technical errors and establish or defend legal claims. Where information is genuinely anonymised so that individuals cannot reasonably be identified, we may use it for statistical analysis and planning.

Not supplying information necessary for an account, purchase or eligibility check may prevent us from providing that function. Declining advertising consent does not stop you from playing.

6. Legal bases where European law applies

We use the following bases where the GDPR or a corresponding local framework requires a legal basis:

You may contact us about a legitimate-interest assessment or object to processing based on legitimate interests. A law outside the EU does not automatically supply an Article 6(1)(c) basis under the GDPR.

7. Computer-controlled players

Two kinds of computer-controlled players exist in Belote Pro.

Practice bots are marked "CPU" at the table. On your request ("Add bot"), practice bots fill empty seats at tables you create for practice. Practice bots ("CPU") are available only on free tables (no stake), and games with practice bots are not ranked.

Automated Players (AI players, sometimes called swarm players) are computer-controlled participants operated by us to fill open seats and reduce waiting times. They hold ordinary player accounts, may appear on leaderboards, may sit at free and, where the economy is offered, staked tables, and are marked with an "AI" badge. They sit only at tables where "Allow AI players" is on. It is on by default, and the host can switch it off. The first time you create a table, switch the setting on, or join a table where it is on, the app shows you a notice about this and asks you to agree; until you do, no Automated Player is seated at your table. Your acknowledgement is stored on your account. Automated Players communicate only through the app's predefined emotes; they do not send or read free-text or voice messages. Both kinds of computer-controlled player receive only the information a human player in that seat would receive: their own hand, the cards played and the auction. They are not given your cards.

Automated Players act in real time, using only the live game state. Matches that include them are recorded like any other match (moves, timing, scores, emotes and rating changes) and kept as ordinary gameplay records (section 11). We process this information only to run the game mechanics, for interoperability (keeping your account, match history, statistics and ratings consistent across the platforms you play on) and to protect players against fraud and cheating. We do not use it to analyse or profile your individual playing behaviour, and we do not use your gameplay data, correspondence, payment information or identity information to train machine-learning models.

8. Cookies, device storage and advertising

We use the following essential technologies:

• A session cookie (or, in the apps, a session token kept in the device's secure store) that signs you in. It is not readable by page scripts, lasts 180 days from your last visit, and is deleted when you sign out or delete your account.
• A device identifier cookie (or, in the apps, an equivalent device value) that lasts two years and is used to grant the one-time welcome coins once per device and to resume a guest on the same device. It is not used for advertising.
• Browser storage on the web for your preferences: your advertising-consent choice, language, sound and music settings, a "returning visitor" flag, any referral code you arrived with, and the sign-in provider's own session while you are signed in. These are not shared with third parties. The one-time 18+ confirmation is kept the same way (in the apps, in the device's secure store).
• Inside Facebook Instant Games, Facebook's platform provides sign-in; no cookie consent banner is shown there because the game sets no advertising cookies in that environment.

Advertising. The Service shows advertisements: rewarded video advertisements you choose to watch in exchange for coins (where the economy is offered) and one interstitial advertisement after a match. Inside Facebook Instant Games a banner advertisement is also shown along the bottom edge of the screen during play. No advertisements are shown on the marketing pages. Advertisements are served by Google (AdSense on the website, AdMob in the native apps) and, inside Facebook Instant Games, by Meta Audience Network. These networks may use cookies, advertising identifiers, your IP address and device information to serve and measure advertisements, and Google may use that data as described at https://policies.google.com/technologies/partner-sites. Advertising is non-personalised by default. On the website, personalised advertising requires your consent through the cookie banner or, in the EEA, the UK and Switzerland, the consent form provided by the advertising platform; in the native apps, the consent form and, on iOS, the system tracking permission are shown where required before the advertising software starts. You can change your choice at any time through the cookie settings, the in-app privacy options or your device settings. Withdrawal applies going forward. If you decline, you still see non-personalised advertisements, which may still use limited device information where the law allows.

We do not sell personal information for money. Advertising disclosures may nevertheless fall within broader local definitions of a sale, sharing or targeted advertising; where such laws apply to us, we provide the required notice and choices and honour legally applicable opt-out signals.

9. Who receives information

We disclose information only as appropriate for the purposes described in this policy, to the following categories of recipient:

• The sign-in provider you choose (a social sign-in service or an email sign-in service), which handles authentication and tells us your identifier, name and picture.
• Payment processors and app stores, which handle payment for coin purchases, issue receipts and, where restrictions apply, report the billing country or region.
• Our hosting, content-delivery and security providers, which operate the servers and network the Service runs on and add the approximate-location headers described in section 3.
• IP-location and connection-risk providers, which receive an IP address in order to return an approximate location and whether the connection looks like a VPN, proxy, Tor exit or data centre.
• The advertising networks named in section 8.
• Professional advisers, regulators, courts and law-enforcement bodies where a lawful disclosure is required or justified.

Some of these providers act as processors on our instructions; others (payment processors, app stores, sign-in and advertising providers) act as independent controllers for their own compliance and services under their own notices. You can ask us for further information about the providers relevant to your data and the safeguards in place.

What other players can see. Your display name, avatar, wins, losses, matches played, skill ratings and tiers, rank, Fair-Play reputation and whether you are a guest or a member are visible to other players on your profile card, at the table and, once you are a registered player with enough rated matches, on the public leaderboard. If your profile is set to public (the default), your country flag, "member since" date and recent match history are visible too; setting it to private hides those three. At a table, the other players see your seat, name and avatar; inside Facebook Instant Games, Facebook draws your Facebook name and picture at the table itself. Your friends see whether you are online or playing. Nothing about your payments or balance is shown to other players.

If the business is reorganised or transferred, relevant information may be disclosed under appropriate confidentiality and data-protection safeguards, and we will notify you of a controller change where required.

10. International processing

We operate from Australia. Our service providers process information in Australia, the EU/EEA, Switzerland and the United States, with specific locations depending on the provider and product.

Where information is transferred from the EEA, the UK or Switzerland to a destination requiring additional safeguards, we use an applicable lawful transfer mechanism such as an adequacy decision covering the recipient or standard contractual clauses with the required UK or Swiss adaptations, together with supplementary measures where necessary. Australia is not covered by a general EU adequacy decision. You may request information about the safeguards relevant to your data, subject to lawful redaction of confidential information. Where Australian cross-border privacy obligations apply, we take the steps those obligations require.

11. How long we retain information

• Your account and everything attached to it (profile, settings, gameplay records, statistics, friends, clubs, referrals, notification subscriptions, reputation) is kept for as long as your account exists. We do not currently delete inactive accounts automatically; you can delete your account at any time (section 12).
• Sessions expire 180 days after your last visit. The device identifier lasts two years.
• Purchase, ledger and tax records are kept for the period required by applicable accounting and tax law. When you delete your account they are de-identified: they remain in our records but are no longer linked to a person.
• Blocked-purchase and blocked-economy records, which include the IP address and the other signals used for that decision, are kept for 12 months and then deleted automatically. Allowed actions are not recorded this way.
• Rating history and daily-activity statistics are kept in de-identified form for statistical purposes after an account is deleted.
• Live tables that never start are removed within about two hours; finished tables are removed within minutes of the match ending.
• Backups are removed or overwritten through the normal backup cycle; deletion is reapplied if a backup is restored.

A legal hold or an active dispute may justify retaining limited records longer. Contact us for the retention period applicable to a particular record.

12. Account deletion and your choices

Delete your account yourself from Account & privacy on your profile (web and the native apps) or from the in-game menu inside Facebook Instant Games, or email support@belotepro.com. The website also documents the steps at belotepro.com/delete-account. Deletion takes effect immediately: your profile, display name, statistics, match history, friends, clubs, referrals, reputation and sign-in link are erased from our live systems and you are signed out. Purchase and ledger records are kept in de-identified form as described in section 11, and any remaining coin balance is forfeited (coins have no cash value). Deleting the app alone does not delete your account. A platform or payment provider may retain its own records under its own obligations.

You can also, from Account & privacy: set your profile to private; and switch country detection off, which stops us inferring your country and deletes the stored country and region. Switching it off does not stop the regional eligibility checks, which use the current connection. You can turn notifications on or off in your browser or device, and change your advertising choice through the cookie settings or in-app privacy options.

→ How to delete your account

13. Your privacy rights

Depending on applicable law, you may request access, correction, deletion, a copy of your information in a portable form, restriction of processing, or information about disclosures. You may object to processing based on legitimate interests. Where processing depends on consent, you may withdraw it at any time. Some US state laws may provide rights to opt out of specified advertising or profiling activities, to use an authorised agent or to appeal a refused request, where those laws apply to us.

These rights have legal exceptions, which we will explain if we rely on one. We normally respond to GDPR requests within one month and explain any lawful extension within that period; other requests are handled within the applicable local deadline. Requests are free unless the law permits a fee for excessive or manifestly unfounded requests. We do not penalise you for exercising a right. Deletion and the profile and country settings are self-service (section 12); other requests, including copies of your information, are handled by support at support@belotepro.com. Do not include a password, full card number or unnecessary identity documents. You can also complain to a competent privacy regulator without giving up other remedies.

14. Automated processing and review

Matchmaking, ratings, game responses, the behaviour of computer-controlled players and the connection and eligibility checks use automated rules. Approximate-location and connection checks can switch off purchases or the coin economy for your session; they use IP location, connection type, the account's first-seen location, device time zone and, after a payment, the billing country or region. These signals are not always accurate. If you believe a restriction is wrong, contact support@belotepro.com and we will review it. Where applicable law gives you rights concerning solely automated decisions with legal or similarly significant effects, we honour those rights, including the rights to human intervention, to express your view and to contest the decision.

15. Security and underage accounts

We use safeguards appropriate to the information and risks: encrypted connections, a sign-in session that page scripts cannot read, a coin ledger that can only be appended to, access controls including an administrator allow-list, rate limiting, signature verification of payment and advertising callbacks, and security monitoring. No service can guarantee absolute security. Protect your device and report suspected account compromise promptly. We assess security incidents and notify affected people and regulators where the law requires.

If we learn that an account is used by someone below the applicable minimum age, we will restrict access and delete information we have no lawful reason to retain. A parent or guardian who believes a child has supplied information should contact us.

16. Communications and policy changes

We do not currently send marketing email. Push notifications (for example a friend coming online or a table invite) are sent only if you turn them on in your browser or device, and you can turn them off there. Necessary account, transaction, security and legal notices may still be sent.

We may update this policy to reflect actual changes in processing, features or law. We will update the effective date and give additional notice of material changes where required. If a new activity requires consent, we will request it; continuing to use the Service does not by itself supply that consent.

17. Contact and complaints

Privacy contact: support@belotepro.com, addressed to Monti Games / Belote Pro. Please describe the issue and a safe way to contact you. We will acknowledge and investigate complaints and explain the outcome, aiming to respond substantively within 30 days or to explain any delay, without limiting a shorter statutory deadline.

Questions about privacy? Email support@belotepro.com or visit our contact page.

EU/EEA and Swiss users — our representative. Because we are established outside the EU, we have appointed Data Protection Representative Limited (trading as DataRep), registered in Ireland (company number 616588), as our representative under Article 27 GDPR in the EU/EEA and under the Swiss Federal Act on Data Protection in Switzerland. You may contact DataRep to raise a question or exercise any of your rights: by email at datarequest@datarep.com quoting “Monti Games / Belote Pro” in the subject line, through the web form at datarep.com/data-request, or by post to DataRep, 77 Camden Street Lower, Dublin, D02 XE80, Ireland or to the DataRep office in your own country (listed below). Letters must be addressed to “DataRep”, not to us, or they may not reach us. You may also contact your local supervisory authority at any time.

Australian users may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

See also our Terms & Conditions.