AppThemis Technologies Inc. (“Company,” “we,” “us,” or “our”) operates the AceSolver mobile application (the “App”). This Privacy Policy explains what information we collect from users of AceSolver (“you” or “user”), how we use and share that information, and your rights in relation to that information. We are committed to protecting your privacy and handling your personal data in a transparent and compliant manner. This Policy is incorporated into our Terms of Use, and by using AceSolver, you agree to the collection and use of information as described in this Privacy Policy.
Please read this Privacy Policy carefully. If you do not agree with our practices, please do not use the App. If you have any questions, you can contact us using the information provided at the end of this Policy.
1. Information We Collect
When you use AceSolver, we collect or receive several types of information. This includes information you provide directly, information collected automatically about your use of the App, and information from third-party services that you connect to AceSolver.
Account Information: When you create an AceSolver account via Sign in with Apple, we receive personal identifiers such as your **name** and **email address** from Apple:contentReference[oaicite:13]{index=13}. We store this information in our database (hosted on Supabase) to identify you and manage your account. If you choose to hide your email address through Apple’s private email relay service, we will receive an alternative proxy email address from Apple instead of your real email:contentReference[oaicite:14]{index=14}. We treat this proxy email as your contact email for the purposes of your account.
Authentication Identifiers: In addition to your name and email, Sign in with Apple provides us with a unique **user identifier** (a string of characters unique to our App) that we use to recognize your account across sessions and devices. We do not receive or store your Apple ID password or any of your personal credentials from Apple’s systems.
User-Submitted Data (Poker Game Inputs): The core function of AceSolver is to analyze poker hands and game scenarios that you submit. When you input text describing a poker hand history, scenario, or any query to the App, the exact **contents of your submission** are collected and stored on our servers. This may include any details you choose to provide about the game (such as card details, bets, outcomes, or your own analysis). We **store all user inputs and the corresponding AI-generated outputs** securely in our database. None of this data is treated as transitory or ephemeral; it is retained as part of your usage history (see “Data Retention” below for duration).
AI Analysis Output: When our system processes your input via OpenAI’s API, it generates an **analysis/output** which is returned to you in the App. We save these AI-generated responses alongside your inputs in order to provide you with chat history, allow you to review past analyses, and for our internal service improvement (for example, to help refine our AI prompts or address errors). The output might occasionally contain information or content that could be sensitive depending on the input; treat it with the same care as your input.
Usage Data: We automatically collect information about how you interact with the App. This includes **log data** such as the date and time you access the App, the features or screens you use, the actions you take (e.g., number of analyses requested, clicks on certain buttons), and your in-app preferences. It may also include **device information** such as your device model, operating system version, unique device identifiers, and App version. We use Supabase as our backend, which logs certain events for debugging and analytics (e.g., counts of how often a particular analysis type is used). We do *not* collect precise geolocation or GPS data from your device; AceSolver does not request or access your location. However, for security and analytics, we may collect or infer approximate location information from your IP address (such as city or country), but we do not store or use this for anything beyond aggregate statistics and regulatory compliance (e.g., to assess where our user base is generally located).
Feedback and Support Messages: If you provide feedback within the App (for example, by filling out a feedback form or sending an error report) or if you contact us via email or support channels, we will collect the information you provide. This may include your contact details (like email address) and the content of your communications. We store this to address your inquiries and improve our services.
Subscription and Transaction Data: When you make a purchase in AceSolver (such as subscribing to a premium plan), we receive information from Apple and our subscription management partner RevenueCat to record your subscription status. This includes confirmation that a purchase was made, the type of subscription or product, the price and currency, and the dates of purchase and expiration. We do **not** receive your credit card number or other billing information; that information is handled by Apple. We assign you an internal user identifier for purchases (either the Apple-provided user ID or a RevenueCat anonymous ID) to track your entitlements:contentReference[oaicite:15]{index=15}. We also store records of your subscription **status** (active, expired, canceled) and any transaction IDs or receipts associated with your purchases. This data is used for license verification and customer support (e.g., troubleshooting subscription issues).
Cookies and Similar Technologies: As a mobile app, AceSolver itself does not use traditional web cookies. However, if we have a web portal or if you visit our website (for example, to read these terms or for support), cookies might be used there. This Policy primarily covers the App, but if a website is used, we will provide a separate notice of any cookie usage on that site. Within the App, we may use local storage or device storage to keep certain preferences or cached data for better performance (for instance, storing your last-used settings or locally caching AI responses for quick retrieval), but this data stays on your device and is not used to track you outside the App.
2. How We Use Your Information
We use the collected information for the following purposes, and we rely on certain legal bases under relevant data protection laws (such as the GDPR) to process your information as described:
To Provide and Maintain the Service: First and foremost, we use your information to operate AceSolver and deliver its core functionality to you. This includes using your Apple Sign-In information to authenticate you each session, processing the poker data you submit to generate AI analysis, and ensuring you receive the correct outputs. We send your game input data to OpenAI’s API in order to obtain the analysis results:contentReference[oaicite:16]{index=16}, and we use your account data to fetch your usage history or manage your session. Legal basis: This processing is necessary to perform our contract with you (the Terms of Use), i.e., to provide the services you request.
To Manage Your Account and Subscription: We use your email (or Apple relay email) and name to personalize your experience (for example, greeting you by name in the interface) and to communicate with you about your account. We use your unique IDs and subscription purchase data to determine your access rights (e.g., whether you are a free or premium user). RevenueCat helps us unlock premium features for you based on your subscription status:contentReference[oaicite:17]{index=17}. We may also send you administrative emails about account status, subscription renewal reminders, receipts, or important service changes. Legal basis: Contractual necessity for providing the services, and our legitimate interest in ensuring you receive information about your account.
To Analyze and Improve the App: Internally, we review usage data and user feedback to understand how AceSolver is used and how we can improve it. For example, we might analyze which features are most popular or which types of poker scenarios are most often analyzed, so we can focus our development accordingly. We also monitor the performance of the AI (like response times or error rates) and may review stored inputs/outputs when investigating a bug or improving our AI prompts. Whenever feasible, we use aggregated or anonymized data for analytics to avoid using personal data. Legal basis: Our legitimate interests in analyzing and improving our product, ensuring the stability and quality of our AI features, and enhancing user experience. Where required by law, we will obtain your consent for certain analytics (though at this time, our analytics are first-party and minimal).
Customer Support and Communications: If you reach out to us for support, we will use your submitted information (like your email and the issue description) to assist you. We may also use your contact information to send you important service-related notices, such as changes to terms or privacy policy, security alerts, or service outages. These are not marketing communications but are necessary notices. Legal basis: Legitimate interests in maintaining customer relationships and legal obligation (in some cases, to notify you of certain rights or changes).
Marketing Communications: We will not spam you or sell your data for advertising. We might send you occasional product updates, offers, or tips by email *if* you have given us consent to do so (for example, if you opted in to a newsletter). If so, you can opt out at any time by clicking “unsubscribe” in such emails or contacting us. We do not engage in third-party advertising within the App, and we do not use your personal data for any targeted advertising profiles.
Enforcing Terms and Policies / Preventing Misuse: We use information (including usage logs and possibly analyzing content of queries) to monitor for fraudulent, illegal, or abusive activity. For example, we keep logs that might help us detect if someone is attempting to overload the system or use the AI in prohibited ways (such as generating disallowed content or automating requests). This is necessary to protect the integrity of our service, comply with our obligations to partners (like OpenAI’s content guidelines), and ensure a fair experience for all users. Legal basis: Legitimate interests in preventing misuse and enforcing our Terms; legal compliance in some cases (if we have to provide info to law enforcement or handle legal claims).
Compliance with Legal Obligations: We may process and retain your information as needed to comply with applicable laws (for instance, tax laws requiring us to keep transaction records) or to respond to lawful requests by public authorities (e.g., a court order to disclose certain data) or to exercise our legal rights or defend against legal claims.
We will not use your personal information for purposes that are incompatible with the above, unless we obtain your consent or as required/allowed by law. If we plan to process your data for a new purpose, we will update this Privacy Policy or otherwise communicate the changes to you.
3. How We Share Your Information
We value your privacy and do not sell your personal information to third parties for money or share it for their independent marketing purposes. However, we do share certain information with third parties in the following contexts, to operate the AceSolver service and as otherwise described here:
OpenAI (Service Provider): As described, when you use the App’s core feature, the content you input (and context from prior messages, if any) is sent to OpenAI, LLC (based in the United States) which provides the AI analysis service. OpenAI acts as our processor for this data. They will process the data to generate the AI response and may store it for a limited time (up to 30 days) for abuse monitoring:contentReference[oaicite:18]{index=18}. OpenAI has committed that API data is not used to train their models without permission:contentReference[oaicite:19]{index=19}, and we have not given such permission. We have a data processing agreement in place with OpenAI to protect your data. Despite these measures, by using AceSolver you acknowledge that your query content will be handled by OpenAI’s servers, which are subject to OpenAI’s security and privacy practices. Please refer to OpenAI’s privacy policy for more information on their handling of personal data:contentReference[oaicite:20]{index=20}. If you prefer that your poker data not be shared with an external AI provider, do not input it into AceSolver, as the analysis cannot be provided otherwise.
Supabase (Hosting and Database Provider): We use Supabase (Supabase, Inc.) as our backend infrastructure for storing and managing data (this includes user accounts, content, and usage logs). Supabase is a cloud platform that acts as a data processor on our behalf. Personal information like your email, name, and stored content (inputs/outputs) reside on Supabase’s databases:contentReference[oaicite:21]{index=21}. Supabase may incidentally have access to data for maintenance or technical support, but they will not use your data for any purpose except to provide services to us. We have ensured Supabase is compliant with relevant security standards (they offer encryption at rest and in transit) and have agreed to data protection terms. Depending on configuration, your data in Supabase may be stored on servers located in the United States or another jurisdiction; however, we ensure that any international transfers of personal data from users in the EU or other regions are done under legal mechanisms (see “International Data Transfers” below).
RevenueCat (Subscription Management): We integrate with RevenueCat (RevenueCat, Inc.) to handle in-app subscription logic. What is shared: When you install and use the App, RevenueCat assigns an anonymous user ID and collects purchase receipts from your device to inform us of your subscription status:contentReference[oaicite:22]{index=22}. RevenueCat may receive device identifiers (such as a Device ID and the Apple App Store receipt) and information about the purchases (e.g., product identifiers, price, currency, subscription expiration date). RevenueCat does not receive personally identifying info like your name or email:contentReference[oaicite:23]{index=23}; we do not provide them with that data. They act as our processor to validate subscriptions and do not use the data for other purposes. See RevenueCat’s privacy policy for more details on their data handling. In short, we share the minimum necessary info with RevenueCat to ensure your subscriptions work across your devices and to prevent fraud.
Apple Inc. (Sign-in and App Store): Your use of AceSolver involves certain interactions with Apple. When you use Sign in with Apple, Apple will inform us of your name and email (or relay email). Apple also knows that you are using our App and may collect information on its usage under their own privacy policy (for example, Apple may collect usage stats or crash reports for our App on your device). Similarly, all purchases are processed by Apple through your App Store account, and Apple will have records of those transactions (which may include personal data like your Apple ID, payment info, and device info) governed by Apple’s terms. We do not control Apple’s data practices. We encourage you to review Apple’s privacy policy:contentReference[oaicite:24]{index=24} to understand how they handle your information. We do not share your personal data with Apple beyond what is necessary for these processes (they already have your info as part of your Apple ID account). We may send Apple certain technical data when needed for things like push notifications or if you enable iCloud backup for our App, but AceSolver currently does not use iCloud sync for user data.
Service Providers and Partners: In addition to the above, we may employ other trusted third-party companies and individuals to help us support or improve AceSolver. These service providers might include: cloud hosting providers, data analytics services (if we engaged any external analytics, though currently we rely on Supabase’s in-house analytics), email service providers (to send newsletters or support emails), or content moderation services (to help filter prohibited content). For example, we utilize OpenAI’s content moderation API to screen user inputs for disallowed content:contentReference[oaicite:25]{index=25}; this means user input may also be sent to OpenAI’s moderation endpoint, which similarly might retain data for a short period but not use it to train models. All service providers are bound by contractual obligations to keep personal information confidential and to use it solely for the purposes of providing their services to us.
Business Transfers: If the Company is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed or transferred as part of such a transaction, as permitted by law and/or contract. We would seek to ensure the new entity will honor the commitments we have made in this Privacy Policy regarding your personal data.
Legal Requirements and Safety: We may disclose your information when we believe in good faith that such disclosure is necessary to: (a) comply with a legal obligation, government request, or applicable law (e.g., responding to a subpoena or court order); (b) protect and defend our rights or property, or the rights, property, and safety of our users or the public; (c) prevent or investigate possible wrongdoing in connection with the App (such as fraud, security incidents, or misuse of our AI); or (d) protect against legal liability. This includes sharing information with law enforcement or regulatory authorities if required and with our legal advisors.
California “Do Not Sell or Share” Notice
We do not sell personal information as defined under the California Consumer Privacy Act (CCPA) and its amendment, the California Privacy Rights Act (CPRA), nor do we share it for cross-context behavioral advertising. In the past 12 months, we have not sold or shared personal information of our users:contentReference[oaicite:26]{index=26}. As such, the “Do Not Sell or Share My Personal Information” request is not applicable in the context of AceSolver. If this changes in the future, we will update this Privacy Policy and provide appropriate opt-out mechanisms.
4. Data Retention
We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Here are some key retention practices for different categories of data:
Account Data: We keep your basic account information (name, email, Apple ID identifier, subscription status) for as long as your account is active. If you delete your account or if we terminate it, we will remove or anonymize this information within a reasonable timeframe, except to the extent it is necessary for us to retain it (for example, records of transactions for financial reporting or legal compliance). If you have only temporarily stopped using the App (dormant account), we will generally retain your data in case you return, unless you request deletion.
User Inputs and AI Outputs: By default, we store all your session data, including the queries you submit and the AI’s responses, indefinitely or until you delete your account. This enables features like reviewing past hands or analyses. However, you have control: if you wish to delete specific content, you may contact us to request its removal (we will treat it similar to a personal data deletion request). Upon account deletion, we will delete or anonymize all associated inputs/outputs in our database, except that we may retain aggregated data (which no longer identifies you) or any data we are required to keep by law. Note that data shared with OpenAI is subject to OpenAI’s retention policy (they delete API data after 30 days):contentReference[oaicite:27]{index=27}, independent of our retention. We do not send OpenAI any request to erase earlier than their schedule, but they automatically handle that.
Usage Logs: Our application logs and Supabase logs may be kept for a shorter period, often 30-90 days, unless needed longer for security analysis. These logs are typically used for troubleshooting and are then either deleted or anonymized. Some aggregated analytics with no personal identifiers might be retained longer to understand trends (e.g., monthly active user counts).
Subscription and Transaction Records: We retain purchase and subscription records for as long as you are a subscriber and for a certain period thereafter (at least a year, often longer as required by financial regulations or tax laws). Even if you delete your account, we may need to keep a record of purchases for accounting and compliance purposes for the legally required duration (e.g., in Canada and many jurisdictions, financial records are kept ~7 years). However, we will dissociate these records from your personal identity where possible once your account is deleted (for instance, keeping a receipt ID with no active user account attached).
Communications: Any communications you send us (support emails, feedback) may be retained for as long as necessary to address your request and for us to have an audit trail of our correspondence. If it contains personal data and you request deletion, we will delete the communication from our systems unless we are required to retain it (e.g., for legal reasons).
When determining retention periods, we consider the volume, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and if we can achieve those purposes through other means, and the applicable legal requirements (such as statutes of limitations, regulatory obligations, etc.).
Once the retention period expires or the purpose of processing has been achieved, we will securely dispose of or anonymize your personal data. For example, we may aggregate or pseudonymize data so that it can no longer be associated with you and may retain that aggregated information indefinitely for statistical analysis and business insights without further notice.
5. Data Security
We are committed to protecting your personal information. We implement a combination of technical, administrative, and physical security measures designed to safeguard your data against unauthorized access, alteration, disclosure, or destruction. These measures include:
Encryption: All communications between the AceSolver App and our servers (and to OpenAI’s API) are encrypted in transit using HTTPS/TLS protocols. Additionally, our database (Supabase) encrypts data at rest:contentReference[oaicite:28]{index=28}, so your personal data and conversation logs are stored in encrypted form on the disk. OpenAI likewise states that they encrypt data in transit and at rest on their systems:contentReference[oaicite:29]{index=29}.
Access Controls: We restrict access to personal data to authorized personnel who need to know that information to operate, develop, or improve the App. Our team members and contractors who have access to personal data are bound by strict confidentiality obligations and are subject to disciplinary action (including termination and legal consequences) if they fail to meet these obligations. We also use authentication measures and, where appropriate, multi-factor authentication for our internal administrator accounts to reduce the risk of unauthorized access.
Secure Development Practices: We follow industry best practices for software development, including regular updating of dependencies, penetration testing when possible, and code reviews to catch security issues. We segment our production environment and apply the principle of least privilege for database and API keys (for example, our connection to OpenAI’s API is restricted and the API key is stored securely).
Monitoring and Logging: We monitor our systems for potential vulnerabilities and attacks. Supabase provides logging of access to the database, and we use these logs to detect anomalies. We also employ basic rate-limiting and input validation to prevent abuse of the AI endpoint which could compromise security.
Third-Party Security: We choose reputable third-party service providers that have demonstrated strong security practices. For example, OpenAI and Supabase both maintain robust security programs and have compliance certifications (OpenAI’s API platform is SOC 2 Type 2 compliant:contentReference[oaicite:30]{index=30}; Supabase also offers GDPR compliance and security features). We review their documentation and updates to ensure they meet our standards. However, no service can be guaranteed 100% secure, and we rely in part on their measures to protect your data when it’s in their care.
Important: While we strive to protect your information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security. You also play a role in protecting your information by keeping your Apple ID secure (since that’s your login method). Please maintain the confidentiality of your Apple account credentials. Notify us immediately if you suspect any unauthorized access to your account or any security breaches.
In the event of a data breach that affects your personal information, we will act promptly to mitigate the impact and comply with any notification obligations. This may involve emailing you and/or posting a notice in the App if feasible, as well as informing relevant regulatory authorities when required by law.
6. Your Privacy Rights
Depending on your jurisdiction, you may have certain rights regarding your personal information. Below, we outline rights that may apply to you, especially if you are in the European Economic Area (EEA), United Kingdom, or California. We will honor all applicable rights requests in accordance with law.
Your Rights Under GDPR (EEA/UK residents)
If you are in the EEA, UK, or a comparable jurisdiction, you have the following rights under the General Data Protection Regulation (GDPR) or equivalent laws:
Right to Access: You have the right to request confirmation whether we are processing your personal data, and if so, to request a copy of the personal data we hold about you:contentReference[oaicite:31]{index=31}:contentReference[oaicite:32]{index=32}. We will provide this in a structured, commonly used electronic format.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data about you. You can also update basic account info (like your name or email) by contacting Apple or us if it was provided incorrectly.
Right to Erasure: You have the right to request deletion of your personal data, also known as the “right to be forgotten,” subject to certain exceptions:contentReference[oaicite:33]{index=33}. This includes the ability to delete your AceSolver account (which will remove your stored inputs, outputs, and other personal info). We will comply unless we have a lawful reason to retain some data (e.g., compliance with a legal obligation, or if the data is in active dispute). See Data Retention above for details on how deletion requests are handled.
Right to Restrict Processing: You can ask us to restrict or suppress the processing of your personal data in certain circumstances, for example if you contest the accuracy of the data or have objected to processing (pending our review of whether we have legitimate grounds that override your interests).
Right to Object: You have the right to object to our processing of your personal data when we do so based on legitimate interests, including profiling. You also have the absolute right to object to your personal data being used for direct marketing (we currently do not use your data for third-party marketing). If you object, we will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, or such processing is needed for legal claims.
Right to Data Portability: You have the right to receive personal data that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller where technically feasible. This right applies when processing is based on consent or contract and is carried out by automated means. For instance, you can request an export of all your hand history inputs and analysis outputs that you provided or that were generated for you.
Right to Withdraw Consent: In the limited cases where we rely on your consent to process data (e.g., if you opted into a marketing newsletter), you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of any processing done before you withdrew consent.
Right to Lodge a Complaint: If you believe our handling of your personal data violates the GDPR or applicable law, you have the right to lodge a complaint with your local supervisory authority. For example, in the EEA you might contact the Data Protection Authority in your country; in the UK, this is the Information Commissioner’s Office (ICO).
To exercise any of these rights, please contact us at our support or privacy email provided below. We may need to verify your identity before fulfilling your request (for example, by confirming that you are contacting us from the email associated with your account, or by other means). We will respond to your request within one month, or inform you of any extension if needed due to complexity.
Your Rights Under California Law (CPRA/CCPA)
If you are a California resident, you have specific rights under the California Consumer Privacy Act (as amended by the CPRA) regarding your personal information:
Right to Know: You can request that we disclose the following information covering the 12 months prior to your request:
The categories of personal information we collected about you:contentReference[oaicite:34]{index=34}, the categories of sources from which we collected it:contentReference[oaicite:35]{index=35}, the business or commercial purposes for collecting it:contentReference[oaicite:36]{index=36}:contentReference[oaicite:37]{index=37}, and the categories of third parties with whom we share that personal information:contentReference[oaicite:38]{index=38}.
The specific pieces of personal information we collected about you:contentReference[oaicite:39]{index=39}:contentReference[oaicite:40]{index=40} (often called a data portability request).
If we disclosed any personal information for a business purpose, the categories of personal information and the categories of recipients for each:contentReference[oaicite:41]{index=41}.
Whether we have sold or shared any of your personal information. *(As noted, we have not sold or shared personal information for cross-context ads in the preceding 12 months:contentReference[oaicite:42]{index=42}.)*
Right to Delete: You can request that we delete personal information we have collected from you, subject to certain exceptions (for example, we may retain information needed to complete a transaction, detect security incidents, comply with legal obligations, or other exceptions outlined in the CCPA/CPRA):contentReference[oaicite:43]{index=43}. If you request deletion, we will delete your personal information from our records (and direct our service providers to do the same) unless an exception applies.
Right to Correct: You can request that we correct inaccurate personal information that we maintain about you. Considering the nature of the personal information and purposes of processing, we will take appropriate steps to correct it as you direct, or we may delete it if correction is not feasible.
Right to Opt-Out of Sale or Sharing: As mentioned, we do not sell personal information or share it for targeted advertising, so this right is generally not applicable. However, if we ever were to engage in practices that fall under “selling” or “sharing” personal info, you would have the right to opt-out. We would provide a clear “Do Not Sell or Share My Personal Information” link or mechanism in that case. Since we don’t do this, there is no need for such an action now.
Right to Limit Use of Sensitive Personal Information: The CPRA allows California residents to limit a business’s use and disclosure of “sensitive personal information” if it is used for purposes beyond what is necessary to provide the services. AceSolver does not collect sensitive personal information such as government IDs, financial account info, precise geolocation, racial or ethnic origin, biometric data, etc., except for your account login identifier which could be considered “account credentials” (email plus authentication token). However, we only use such information to provide the App’s login functionality and not to infer characteristics about you. Therefore, the right to limit is not particularly applicable here, as we do not use sensitive info for secondary purposes.
No Retaliation/Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the above rights. We will not deny you our services, charge you different prices, or provide a different level of quality just because you exercised your privacy rights. If you are a paying subscriber and you delete your data, we will of course need to retain minimal info (like that you have a valid subscription) to continue providing the service you paid for, but that is not discriminatory – it’s simply operational.
To exercise your California rights, you (or an authorized agent acting on your behalf) can contact us as described in the Contact section. We will verify your request using information associated with your account, including email address and, if necessary, any information related to your use of the service. We aim to respond to verified requests within 45 days as required by the CCPA/CPRA, or inform you if we need more time.
For all users: if you want to exercise any privacy rights that apply to you, please reach out. We will explain what info we need to verify your identity and fulfill your request. Typically, for account-related data, contacting us from the email associated with your AceSolver account or providing proof of account ownership will suffice.
7. Children’s Privacy
AceSolver is not intended for children under the age of 13. We do not knowingly collect or solicit personal information from anyone under 13 years old. If you are under 13, please do not attempt to register for or use AceSolver, and do not send any information about yourself to us. If we learn that we have collected personal information from a child under 13, we will take steps to delete that information as soon as possible.
If you are a parent or guardian and you discover that your child under 13 has provided personal information to us, please contact us immediately so that we can delete the child’s information. Additionally, for minors above 13, we expect and assume that any use of AceSolver is with parental knowledge and consent where required by law. For example, in some jurisdictions (such as in parts of the EU), the age of data consent may be higher (like 16); if we become aware that we have unwittingly collected personal data from a minor below the applicable consent age without proper authorization, we will delete it.
We do not use the App to target or market to children. The content of the App (poker strategy) is generally intended for an adult or at least teen audience. By using AceSolver, you represent that you meet the required minimum age and, if you are between 13 and 18 (or the age of majority in your region), that you have your parent or guardian’s permission to use the App and to provide your personal information to us.
8. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. If we make material changes to how we handle your personal information, we will provide you with notice in accordance with law. This may include posting a notice within the App, updating the “Last Updated” date at the top of this Policy, and/or sending a notification (e.g., via email or in-app alert) to inform you of the changes.
Your continued use of AceSolver after any such update constitutes your acceptance of the changes. However, if the changes are significant or require your explicit consent (for example, if a new purpose for data processing arises), we will seek consent as appropriate. We encourage you to review this Privacy Policy periodically to stay informed about our data practices and the ways you can help protect your privacy.
If you do not agree with the revised policy, you should deactivate your AceSolver account and stop using the App. If you wish to see earlier versions of this Policy, you may contact us – we maintain archives of our privacy policies for regulatory compliance.
9. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach out to us. We are here to help and address any issues you may have about your privacy and AceSolver.
We will do our best to respond to your inquiry within a reasonable timeframe and provide you with the information or assistance you need. If you are contacting us to exercise a specific data right, please clearly describe your request (e.g., “Right to Access – GDPR request”) and provide enough information for us to verify your identity. We may ask for additional verification information as a security measure.
Thank you for reading our Privacy Policy. Your privacy is important to us, and we are committed to protecting and respecting your personal data as you use AceSolver.
This Privacy Policy and Terms of Use were last updated on August 18, 2025. :contentReference[oaicite:46]{index=46}:contentReference[oaicite:47]{index=47}