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pokercalc.app

Privacy Policy

Last updated: March 2026

This Privacy Policy explains how Poker Calc ("we", "us", "our"), operated by FUNKARNU SL (NIF: B75540567), a company registered in Spain, collects, uses, and protects your personal data when you use our website at pokercalc.app (the "Service"). We are committed to protecting your privacy and complying with the EU General Data Protection Regulation (GDPR).

1. Data Controller

The data controller responsible for your personal data is FUNKARNU SL (NIF: B75540567), a company registered in Spain. For any privacy-related inquiries, you can reach us at hello@pokercalc.app.

2. What Data We Collect

We collect the following categories of personal data:

  • Account information: When you sign in via Google OAuth, we receive your name, email address, and profile picture URL from Google. We do not receive or store your password.
  • Subscription and payment data: If you subscribe to the Pro tier, payment processing is handled by Stripe. We store your Stripe customer ID, subscription status, and plan details. We do not store your credit card number or full payment details.
  • Game and usage data: We store data you create within the Service, including quiz progress, hand history, saved ranges, strategy settings, and AI Coach conversation context. This data is tied to your account or anonymous identifier.
  • Usage metrics: We track feature usage counts (e.g., how many times you use the AI Coach or image scan per day) to enforce free-tier limits and improve the Service.
  • Technical data: We collect standard web server logs including IP addresses, browser type, operating system, referring URLs, and timestamps. PostHog collects anonymized page view and interaction data.
  • Cookies and identifiers: We use cookies as described in the Cookies section below.

3. Legal Basis for Processing

We process your personal data under the following legal bases:

  • Contract: Processing your account information, subscription data, and game data is necessary to provide you with the Service and fulfill our contractual obligations to you.
  • Consent: We use analytics cookies and third-party tracking (PostHog) only with your explicit consent, which you can provide or withdraw via our cookie consent banner.
  • Legitimate interest: We process aggregated and anonymized usage data to improve the Service, fix bugs, and understand usage patterns. We have assessed that this processing does not override your rights and freedoms.

4. How We Use Your Data

We use the collected data to:

  • Provide, maintain, and improve the Service
  • Authenticate your identity and manage your account
  • Process payments and manage subscriptions via Stripe
  • Enforce free-tier usage limits
  • Power AI Coach responses using Cloudflare Workers AI
  • Track quiz progress, achievements, and leaderboard standings
  • Analyze uploaded poker screenshots using AI image recognition (Cloudflare Workers AI) to extract game state
  • Analyze aggregated usage patterns to improve the product
  • Send transactional emails related to your account (e.g., subscription confirmations)

We do not sell, rent, or trade your personal data to third parties. We do not use your data for advertising or profiling purposes.

5. Data Storage and Security

Your data is stored on Cloudflare infrastructure, including Cloudflare D1 (database) and Cloudflare Workers (serverless compute). Cloudflare operates data centers globally, including within the European Economic Area. We rely on Cloudflare's data processing addendum and standard contractual clauses where applicable to ensure appropriate safeguards for any data transferred outside the EEA.

We implement appropriate technical and organizational measures to protect your data, including encrypted connections (HTTPS), HttpOnly session cookies, and secure authentication flows.

6. Data Retention

  • Account data: Retained for as long as your account is active. When you delete your account, your personal data is permanently removed within 30 days.
  • Anonymous usage data: Data associated with anonymous identifiers (pre-sign-in usage tracking) is retained for up to 30 days, after which it is automatically purged.
  • Session data: Session records expire after 30 days and are cleaned up periodically.
  • Payment records: Stripe retains payment-related data according to their own retention policies and legal obligations.

7. Your Rights Under GDPR

As a data subject, you have the following rights under the GDPR. You can exercise these rights at any time:

  • Right of access: You can request a copy of the personal data we hold about you.
  • Right to rectification: You can request correction of inaccurate personal data.
  • Right to erasure: You can request deletion of your personal data. You can delete your account directly from the Account page in the app, which permanently removes all associated data.
  • Right to data portability: You can request an export of your data in a machine-readable format. An export feature is available on the Account page.
  • Right to restrict processing: You can request that we limit how we process your data in certain circumstances.
  • Right to object: You can object to processing based on legitimate interest.
  • Right to withdraw consent: Where processing is based on consent (e.g., analytics cookies), you can withdraw consent at any time via the cookie settings on the site.

To exercise your rights, use the Account page in the app for data export and account deletion, or contact us at hello@pokercalc.app for other requests. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority. In Spain, this is the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD).

8. Cookies

We use the following cookies:

  • Session cookie (sid): An HttpOnly, secure cookie that identifies your authenticated session. It expires after 30 days and is essential for the Service to function when you are signed in. Legal basis: contract.
  • Anonymous ID cookie (anon_id): A cookie used to track feature usage for free-tier limits before you sign in. It expires after 30 days. This cookie is essential for enforcing usage limits for unauthenticated users. When you sign in, anonymous usage data is merged with your account and the cookie is replaced by the session cookie. Legal basis: legitimate interest.
  • Analytics (PostHog): PostHog collects anonymized data about how you interact with the Service, including page views, feature usage, and session duration. Analytics data is stored in localStorage and only collected with your explicit consent via the cookie consent banner. Legal basis: consent.
  • Language preference cookie (lng): Stores your preferred language for the Service. It persists for 1 year. Legal basis: contract.
  • Cookie consent preference: A local storage entry that records whether you have accepted or declined analytics cookies.

9. Third-Party Services

We share data with the following third-party services, each acting as a data processor or independent controller as indicated:

  • Google OAuth (Google LLC): Provides authentication. When you sign in with Google, Google shares your name, email, and profile picture with us. Google's privacy policy applies: policies.google.com/privacy.
  • Stripe (Stripe, Inc.): Processes payments for Pro subscriptions. Stripe receives your payment details directly. Stripe's privacy policy applies: stripe.com/privacy.
  • Cloudflare (Cloudflare, Inc.): Provides hosting, database (D1), serverless compute (Workers), and AI inference (Workers AI) for the Service. AI features include the AI Coach (text-based) and image scan (poker screenshots are sent to Cloudflare Workers AI for analysis). Cloudflare acts as a data processor. Cloudflare's privacy policy applies: cloudflare.com/privacypolicy.
  • PostHog (PostHog, Inc.): Collects anonymized usage analytics and error reports, only when you have consented via the cookie banner. PostHog's privacy policy applies: posthog.com/privacy.

10. Children's Privacy

The Service is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without verifiable parental consent, we will take steps to delete that data promptly. If you believe a child under 16 has provided us with personal data, please contact us at hello@pokercalc.app.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you by posting the updated policy on the Service with a revised "Last updated" date. Your continued use of the Service after such changes constitutes your acknowledgment of the updated policy. We encourage you to review this page periodically.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at hello@pokercalc.app.