Privacy Policy

1. Who We Are and What This Policy Covers

1.1 Responsible organization. Pokerpoker.ai is provided by UNLEASHFUN SG PTE. LTD., incorporated in Singapore, with its address at 10 Anson Road, 079903 Singapore ("Pokerpoker.ai", "we", "us" or "our"). We are responsible for the collection, use and disclosure described in this Privacy Policy and act as the data controller or responsible organization where those terms apply.

1.2 Scope. This Policy covers the Pokerpoker.ai applications, related account and sharing webpages, post-game reviews, AI conversations, purchases and customer support (together, the "Service"). It also explains our handling of personal information about other people visible in submitted gameplay. It does not replace the policies of independent game platforms, app stores, login providers or payment services for their own activities.

1.3 Reading this Policy. The information processed depends on the features you use and the permissions you grant. Listing a category does not mean we collect it from every user. Uploading gameplay is not, by itself, permission to publish it, send marketing or train general-purpose models. Where specific processing requires a separate notice or permission, we provide that notice and obtain the permission before that processing.

2. Information We Collect and Why

2.1 Account and sign-in information. When you register or sign in, we process a Pokerpoker.ai account identifier, your selected login method and the identity information that method authorizes and returns. This may include a provider-specific user identifier, authentication tokens, name or nickname, email address and profile image. Apple may provide a private relay email address. We use this information to authenticate you, maintain account access, associate records and protect account security. We do not receive your Apple, Google or Facebook password.

2.2 Profile, preferences and eligibility. We process profile details you choose to provide, language and notification preferences, and account settings needed to personalize the Service. Where an age or eligibility check is necessary, we process the minimum declaration or verification result required for that check. We do not require identity documents for ordinary game review. Additional verification is requested only when reasonably necessary and with an explanation.

2.3 Recordings and uploaded material. When you record and submit gameplay or select files for upload, we process the submitted video, screenshots or other supported content, associated thumbnails or extracted frames, and file details such as format, size, duration, submission time and task status. A file may contain embedded audio and metadata even where the review focuses on visual gameplay. We use this material to receive and process your task, identify game events, generate the requested review and investigate associated failures.

2.4 Gameplay facts and reports. We extract information such as hand cards, shared cards, player positions, visible actions, bet sizes, chip amounts, pots, outcomes, player labels and video time points. We use these facts to produce replays, metrics, scores, strategy explanations, performance summaries, position analysis and historical comparisons. Information in a report remains personal information where it can be linked to an account, a recording or an identifiable person.

2.5 Other players' information. Submitted gameplay may contain another player's nickname, avatar, in-game identifier, visible messages and game actions. We process relevant observations to explain that gameplay and identify tendencies within the submitted sample. We do not obtain their private game account, personal communications outside the submitted material or unrelated records simply because they appear in a recording. Further safeguards are described in Section 3.

2.6 AI conversations and feedback. When you use an available chat feature, we process your messages, attachments, relevant conversation or review context, AI responses, timestamps and feedback you submit. This supports the response you request, conversational continuity and resolution of issues you report. Playing-style, learning or mindset observations may be generated from the submitted material. These are fallible inferences, not clinical assessments.

2.7 Orders, memberships and Credits. We process product identifiers, order or transaction references, purchase receipts or tokens, payment status, amount, currency, purchase and renewal times, subscription status, entitlement periods, allowance issuance and consumption, and refund information. This is used to verify purchases, deliver or restore benefits, prevent duplicate claims, manage refunds and meet accounting obligations. Standard app-store purchases do not provide us with your full payment-card number, security code or payment password.

2.8 Sharing, invitations and messages. When you use sharing or invitation features, we process the selected content, link or invitation identifiers, referral associations, reward status and necessary access records. Notification delivery may use a device push token and your notification settings. This allows us to deliver task and account messages, operate chosen sharing and verify invitation rewards. An inviter does not receive your private reviews, chats or full payment details through the invitation relationship.

2.9 Technical, usage and security information. We process information such as IP address, device model, operating-system and app version, app-scoped installation identifiers, language, time zone, access timestamps, requested functions, network information and error or crash records. We use it to operate the Service, maintain compatibility, understand feature performance, troubleshoot faults and detect misuse. IP addresses may indicate an approximate region; this is different from accessing your device's precise location. Optional analytics and tracking are subject to Section 5.

2.10 Support and rights requests. When you contact us, we process the reply details you provide, your question or complaint, relevant task or order references, supporting attachments and the correspondence needed to resolve it. We may request proportionate verification information to prevent unauthorized disclosure or deletion. Support does not require your password, payment verification code or full card-security information.

2.11 Sources and necessity. Information comes from you, your device while you use the Service, providers you authorize, transaction confirmations, and outputs generated from submitted content. Other players' information may come indirectly from a user's recording. You may choose not to supply optional information. Information needed to authenticate an account, analyze a submission or fulfill a purchase cannot be withheld without affecting that particular function; it does not authorize unrelated collection.

3. Recordings, Opponents and Sensitive Material

3.1 User-controlled capture. Screen capture is initiated through your action and the applicable system permission. You can stop it using the available app or system control. Capture permission is not permission for unrelated monitoring, public sharing or general-purpose model training. We process recordings submitted for post-game review, not for providing live decision guidance during an ongoing hand or game.

3.2 What a recording can contain. A recording may include notifications, another application shown on screen, in-game chats, avatars, audio or other unintended details. Review the material before submitting it and remove unrelated personal information where possible. We do not represent that every identifying detail is automatically removed or that audio is always stripped before upload.

3.3 Relevant opponent analysis. Opponent observations are used in the context of the gameplay being reviewed. A nickname or avatar is not reliable proof of real identity, and similar labels do not by themselves establish that two records concern the same person. Where a seat label or other non-identifying parameter is sufficient, we limit that processing step to the necessary parameters. Replacing a name with a code does not make information anonymous if it can still be linked back to a person.

3.4 Privacy of analysis. Submitting a recording does not by itself authorize a public profile of its players or unrestricted sharing of private analysis across users. Access and any sharing remain limited to the relevant account, authorized service processing and the scope expressly selected for a share. We may restrict or remove content where the submission lacks a proper basis or creates an unlawful privacy risk.

3.5 Sensitive information and non-users. Do not submit unrelated identity documents, passwords, precise location, health records, financial credentials or information about children. We limit processing of incidentally included sensitive material to what is lawfully necessary to handle the submission or a complaint. A person shown or described in gameplay may contact us about their information even without a Pokerpoker.ai account. Any request is assessed independently of the uploader's account rights, with protection for everyone concerned.

4. AI Processing, Context and Model Training

4.1 Processing sequence. A review may involve receiving content, extracting visual information, reconstructing gameplay, obtaining strategy or GTO references, generating an explanation and storing the result for your access. Some steps may run in our systems and others may use contracted image-recognition, AI or strategy services. Use of Pokerpoker.ai does not mean that all processing takes place on your device.

4.2 Third-party AI permission. Before personal information is sent to an external AI provider, we identify the provider, explain the material to be sent and the purpose, and obtain your explicit permission. The feature-specific notice also explains relevant processing and retention conditions. These notices form part of the information provided under this Policy. Accepting the general Terms, authorizing screen capture or making a payment does not substitute for that permission.

4.3 What may be sent. Depending on the task, AI processing may involve selected gameplay frames or images, extracted hand and action data, a question, relevant conversation history and associated review context. We limit disclosure to what is needed for that step. Strategy calculation that only needs cards, actions and stack sizes does not require your login credentials, email or payment record. When identifiable images are needed, the disclosure describes them as images rather than anonymous statistics.

4.4 Declining or withdrawing permission. You may decline external AI processing or withdraw permission for future processing through the relevant privacy control or by contacting us under Section 14. A function that depends on that processing may then be unavailable, but you may still exercise privacy rights and manage your account or purchases. Withdrawal cannot undo a completed response, but you may request deletion of personal information that remains stored. Lawful processing before withdrawal is not made unlawful retrospectively.

4.5 Context and memory. Conversation and review context is used to answer your request and support the history you choose to keep. It is not a general authorization to send every historical item to every provider. An additional optional cross-conversation memory or preference feature is subject to its own explanation of scope, controls and deletion. Deleting a conversation can also require removal of identifiable summaries or related retrieval records; deletion requests are not limited to the visible message.

4.6 Separate training purposes. The permission to provide a review or answer does not authorize use of identifiable recordings, private conversations or associated personal data for unrelated general-purpose model training. We will seek a separate opt-in before using that content for such optional training or fine-tuning. Service providers acting for us are not authorized to reuse the content for their own independent training. Declining optional training does not remove access to the core paid service.

4.7 Quality, safety and human access. Authorized personnel may access relevant material where necessary to resolve your reported issue, investigate a technical fault, protect the Service or comply with law. Access is limited by role and purpose and subject to confidentiality requirements. An optional use of identifiable content for broader research or evaluation beyond these purposes requires a separate explanation and the applicable permission. Anonymous operational statistics are distinct from personal content.

4.8 Provider records and retention. Generating a response, retaining a request for security or troubleshooting, and training a model are different activities. A restriction on model training does not mean that no provider log or temporary copy exists. We apply purpose, access and retention restrictions to processing on our behalf and require providers to support applicable deletion obligations.

5. Permissions, Local Storage, Analytics and Communications

5.1 Device permissions. Screen-recording permission is requested when you initiate recording. Photo or file access is used for material you select for submission, and notification permission is used for permitted notifications. Ordinary text chat and file upload do not require microphone, camera, contacts or precise-location access. Any function that does need an additional permission must explain why before requesting it. Refusing an optional permission affects the dependent feature rather than unrelated account rights.

5.2 Managing permissions. You can manage recording, photo access and notifications through your device settings and the relevant controls. You can manage Apple, Google or Facebook authorizations through those providers. Removing a device permission or disconnecting a login prevents the relevant future access but is not the same as deleting information already submitted to Pokerpoker.ai.

5.3 Cookies and similar storage. Our webpages and embedded web functions may use cookies or equivalent local storage for sign-in sessions, security, language settings and remembering your choices. Necessary session storage lasts for the session or the relevant login period; saved preferences remain until replaced, cleared or no longer needed. Blocking necessary storage may prevent a function from working. Non-essential analytics or advertising storage is used only with the notice, choice and consent required by the law applicable to you.

5.4 Measurement and advertising-related uses. Feature and error events may be used to assess reliability and product use. Invitation identifiers or campaign parameters attached to a link may be used to understand the source of a visit or registration. This is not permission to disclose private video or conversation content for another party's advertising. Cross-app tracking, advertising identifiers or other optional advertising measurement require a separate, specific disclosure and the applicable consent or opt-out controls; this Policy alone does not authorize them.

5.5 Marketing and notifications. We distinguish service notices, such as task completion, security alerts and purchase updates, from promotional communications. Marketing requires the applicable legal basis and includes a way to stop receiving it. Opting out does not stop necessary service or legal notices. Private gameplay, conversations and inferred emotional distress must not be used to target gambling offers or encourage you to chase losses.

6. When Information Is Shared

6.1 Login providers. When you choose an offered Apple, Google or Facebook login, that provider processes the authentication request and supplies the authorized identity information described in Section 2. We exchange information necessary for authentication and account security, not your complete review history merely because you sign in. The provider's own authentication activities are governed by its privacy policy.

6.2 App stores and payment services. Apple, Google and another payment provider you select process purchases under their own applicable terms and policies. We exchange the transaction and account-association information needed to verify orders, deliver entitlements, restore supported purchases and handle refunds. Private gameplay recordings and chat contents are not needed to validate a normal purchase.

6.3 Service providers. We may use providers for hosting, storage, databases, content delivery, video or image recognition, AI generation, strategy calculation, notifications, technical diagnostics and customer support. A provider receives only the categories necessary for its function: hosting may store submitted content and account records; recognition or AI may process the task material described in Section 4; diagnostics may receive technical and error records; support may receive the relevant inquiry. External AI recipients are identified before the sharing requiring your permission.

6.4 Restrictions on providers. For processing on our behalf, we require appropriate confidentiality, security, purpose limits, retention limits and assistance with data-rights requests. Such providers must protect personal information to a standard consistent with this Policy and applicable law, and must not use it for unrelated independent purposes under our service instructions.

6.5 People you choose to share with. A person who receives a link or shared item can access the content included in that share, subject to the sharing settings and function. They may forward or save it. Sharing one hand does not give them access to your entire account. Removing content we control cannot guarantee deletion of an independent recipient's copy.

6.6 Legal protection and business transactions. We may disclose necessary information to competent authorities or professional advisers to comply with a valid legal requirement, protect people or the Service, or establish, exercise or defend legal rights. In a merger, acquisition, restructuring or business transfer, relevant information may be disclosed under appropriate confidentiality and protection measures. A successor must honor the applicable obligations or provide a lawful new notice and choice before changing purposes.

6.7 Limits on sharing. The disclosures described here are purpose-specific, not permission to make private content available for any commercial use. We do not authorize service providers to sell personal information received on our behalf, use private gameplay or conversations for their own advertising, or build unrelated personal profiles from them. A materially different use or sharing arrangement requires a new disclosure and any permission or other legal basis required before it begins.

7. Legal Grounds and International Processing

7.1 Singapore and other applicable laws. We collect, use and disclose personal information with consent where required under Singapore's Personal Data Protection Act and rely on applicable legal exceptions only when their conditions are met. We apply the other mandatory privacy laws that govern the particular processing. We do not rely on a broad product-improvement purpose to justify collecting unrelated personal information.

7.2 Where European or UK data-protection law applies. Necessary account, review, chat and purchase processing is based on performing our contract with you or taking requested steps before a contract. Tax and other legally required records are processed to comply with legal obligations. Proportionate security, fraud prevention, troubleshooting and service administration may rely on legitimate interests after considering the effect on your rights. Optional marketing, tracking, additional training and other consent-based uses rely on the required consent. Where opponent information is assessed under legitimate interests, we consider that person's expectations and rights; the uploader's contract alone does not authorize every use of another person's data.

7.3 International processing. We are based in Singapore. Information may be processed in Singapore and in other countries where relevant providers or authorized support operations are located. Our company address does not mean all information is stored only in Singapore. The external AI notice explains the recipient and relevant processing conditions before the transfer requiring permission. You may contact us for information about destinations and safeguards relevant to your data.

7.4 Transfer protection. Before a transfer that requires protection under applicable law, we put in place the appropriate legal mechanism and safeguards, such as enforceable contractual protections, an applicable adequacy decision or approved standard contractual clauses. Transfers from Singapore must receive protection comparable to that required by its data-protection law. European and UK transfers are subject to the relevant additional requirements. You may request information about applicable safeguards, with confidential material redacted where appropriate. A general acceptance of this Policy does not replace a separately required transfer consent.

8. How Long We Keep Information

8.1 Retention principle. We keep personal information only for as long as reasonably necessary for the purposes described in this Policy or a valid legal requirement. The period depends on the information, whether you continue to request storage or access, outstanding tasks or support issues, the sensitivity of the content and any applicable recordkeeping or claim period. Once retention is no longer justified, we delete it or anonymize it so that a person cannot reasonably be identified.

8.2 Account and saved history. Account details are retained while needed to maintain your account and resolve associated issues. Saved gameplay facts, reports, replays and conversations are retained to provide the history you keep, unless you delete them, close the account or they are no longer needed for the relevant purpose. This is not a promise of permanent archival storage. Invalidated authentication credentials are removed or disabled when no longer needed.

8.3 Original files and temporary processing data. Original recordings, uploaded files, extracted frames and temporary copies are kept for the requested processing, any storage or replay function you use, and necessary resolution of a related failure. Where the requested result can be retained without the original source and no other valid purpose remains, the original is deleted. Failed, cancelled and abandoned-task material is not kept indefinitely merely because no report was delivered.

8.4 Transaction records. Order, payment, entitlement and refund records are retained for the applicable accounting, tax, fraud-prevention and dispute periods. Singapore corporate tax records are generally required to be kept for at least five years from the relevant Year of Assessment. An applicable longer legal requirement or active claim may require longer retention of the relevant record. This does not justify retaining all associated video or chat content.

8.5 Operational and support records. Technical logs, crash records, support correspondence and rights-request records are retained only while reasonably needed to diagnose the issue, protect the Service, demonstrate lawful handling or address a related claim. Invitation and reward records are retained for administration and necessary fraud checks. Identifiable sharing records are retained while the share is active and for any limited security or legal need after removal.

8.6 Deletion, backups and providers. A valid deletion request covers relevant identifiable source content and derived data under our control, including related frames, summaries, indexes and profiles, not just the visible account screen. Information that must temporarily remain in protected backups is isolated from normal use and removed through the applicable backup replacement process; deletion instructions are reapplied before any recovery into active use. We require processors to implement applicable deletion instructions. We complete requests without undue delay and within legal time limits, and explain any necessary lawful retention or permitted extension.

8.7 What deletion does not reach. Deleting a local file does not itself delete a cloud copy, and deleting an original recording may not delete a separately retained report unless your request covers both. Account deletion addresses the associated personal data subject to the limited exceptions above. Truly anonymous statistics may remain. Independently retained copies held by a person you shared with or by a platform acting for its own purposes are governed by that recipient's obligations, not by our ability to remove a Pokerpoker.ai copy.

9. Your Privacy Choices and Rights

9.1 Access, correction and deletion. You may ask for access to personal information we hold about you, correction of inaccurate information, a copy where applicable, or deletion of an account, recording, report, conversation or related identifiable analysis. Use the relevant in-app controls, email support@pokerpoker.ai with the subject "Pokerpoker.ai Privacy Request", or use the other contact channels in Section 14. For a request to delete specific data without closing your account, identify the relevant material and explain the scope of your request. We may protect other people's rights by providing an appropriate extract rather than an entire shared recording.

9.2 Withdrawal and additional rights. You may withdraw consent for future consent-based processing. Where the applicable law provides them, you may also request portability or restriction, object to processing based on legitimate interests, object to direct marketing, and opt out of applicable sales, advertising-related sharing, targeted advertising or certain profiling. These rights depend on the law and processing involved; a description of a right does not mean that Pokerpoker.ai performs every activity to which it may apply.

9.3 Verification and handling. Provide only enough information to identify the account or material and explain the request. We may verify identity or an authorized agent's authority to prevent misuse, using a proportionate method. We respond within the period required by applicable law and explain a lawful refusal, partial response or permitted extension. We do not charge for ordinary requests unless a charge is expressly permitted by law and explained in advance.

9.4 No unnecessary barriers. You do not need a paid membership to exercise privacy rights. We do not discriminate against you for exercising a right. A feature can become unavailable where its necessary processing has been refused or withdrawn, but unrelated rights and valid refund claims remain. The rights of a person shown in uploaded gameplay do not depend on that person having a Pokerpoker.ai account.

9.5 Review and complaints. You may ask us to reconsider a rights-request decision or account restriction by explaining the issue through the contact channels below. You may also complain to Singapore's Personal Data Protection Commission or the competent data-protection authority in your location. You do not have to complete an internal complaint process before using a statutory remedy.

10. How to Delete a Pokerpoker.ai Account

10.1 In the application. Open Account Settings from the settings area of your profile, choose the account-deletion option and follow the confirmation process. Deletion is a request to remove the account and associated personal information, subject to the limited legal retention described in Section 8; it is not merely a request to sign out or freeze the account.

10.2 By email or without access to the application. Email support@pokerpoker.ai with the subject "Pokerpoker.ai Account Deletion" to request deletion of your account and associated personal information. Include your Pokerpoker.ai account ID or login email, where available, your sign-in method (such as Apple, Google or Facebook), and a clear deletion request. For deletion of specific data without closing your account, use "Pokerpoker.ai Privacy Request" and identify the material. You do not need to reinstall the application, sign in or make a purchase to submit an email request. If you cannot access the original login email, explain this so we can arrange proportionate verification. Do not send passwords or authentication codes. You may also write to the Data Protection Officer at the address in Section 14.

10.3 Subscriptions and other providers. Deleting a Pokerpoker.ai account does not itself cancel an app-store subscription or delete an Apple, Google or Facebook account. Manage ongoing subscription renewal separately with the relevant payment provider. You may submit a deletion request while a subscription is still active. Revoking Facebook or another login permission stops the relevant future authorization but does not automatically delete the Pokerpoker.ai data already received; use the deletion process to request that removal.

10.4 Results of deletion. We remove relevant account data and revoke or disable linked credentials under our control, subject to lawful retention. Your saved reviews, conversations, related identifiable inferences and our controlled sharing links are addressed by the request. We may retain the minimum transaction or complaint information needed to finish a refund, meet a recordkeeping duty or handle an existing claim. Completed deletion may be irreversible.

10.5 Handling your request. We acknowledge your request, explain any necessary verification and the expected completion time, and confirm the outcome using the contact details you provide. We complete deletion without undue delay and within applicable legal time limits. If limited information must be retained, we explain the relevant categories, reasons and retention period or criteria.

11. Security and Automated Analysis

11.1 Safeguards. We apply reasonable technical and organizational measures appropriate to the information and risks, including protections for data transmission, controlled access, confidentiality requirements, appropriate storage protections and service-provider oversight. Access to private content is limited to authorized purposes. No internet service or storage system can be guaranteed completely secure.

11.2 Security incidents. Where an incident may affect personal information, we investigate, take appropriate containment and remediation measures, and notify affected people and relevant authorities when required by applicable law. Such notices explain the information and action required by law. You can report a suspected security incident through the contact channels below.

11.3 Automated observations. Pokerpoker.ai uses automated analysis to explain gameplay and personalize learning. A playing-style label, score or mindset observation is not a determination about your legal rights, creditworthiness, employment or medical condition. Where an account or other significant decision affects you, you may request an explanation or review in accordance with applicable law. Do not treat generated observations as established facts about another person.

12. Children and Age Restrictions

Pokerpoker.ai is intended for people aged 18 or older who are legally eligible to use it. It is not directed to children, and parental permission does not remove the minimum-age restriction. An app-store content rating does not replace our eligibility requirements.

If we learn that an ineligible child has registered or that we hold unnecessary personal information about a child, we will take appropriate steps to restrict access and delete the information, subject to necessary legal retention. A parent, guardian or affected person may contact us without creating an account. Incidental information about a child in a recording is subject to the same necessity and protection requirements.

13. Changes to This Policy

We update the effective and last-updated dates when this Policy changes. We provide a prominent notice of material changes through the Service or an appropriate available contact channel, including changes to purposes, relevant recipients, important retention rules or the handling of your rights. Where required, we obtain additional permission before the changed processing begins.

A change to this Policy does not retrospectively authorize an unlawful use of information. Silence, continued browsing or accepting a general update does not substitute for separate permission required for third-party AI sharing, optional training, tracking or another specific purpose. You may decline optional new processing and use the rights described above.

14. Contact the Data Protection Officer

For privacy questions, consent withdrawal, access or deletion requests, complaints, or concerns about a person shown in gameplay, email support@pokerpoker.ai, use Contact Support in Pokerpoker.ai and identify the request as a privacy matter, or write to:

For an account-deletion request, use the subject "Pokerpoker.ai Account Deletion". For another privacy request, including deletion of specific data, use "Pokerpoker.ai Privacy Request". Include a reply contact and only the information reasonably needed to locate and assess the request. Do not include passwords, authentication codes or unnecessary identity or payment documents. Email and postal requests are available to users and non-users alike and do not require installing the application or signing in.