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 services 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 (or an anonymized relay email, depending on your Apple settings). We store this to identify you and manage your account.
Authentication Identifiers: Sign in with Apple provides a unique user identifier that we use to recognize your account across sessions and devices. We do not receive or store your Apple ID password.
User-Submitted Data (Poker Game Inputs): The core function of AceSolver is to analyze poker hands and scenarios you submit. The exact contents of your submissions are collected and stored to provide features like history and replays. We also store the corresponding analysis results.
AI Analysis Output: When our system processes your input via external AI processing services, it generates analysis that is returned to you. We save these outputs alongside your inputs to provide chat history, allow review of past analyses, and improve service quality.
Usage Data: We automatically collect information about how you interact with the App (e.g., features used, buttons tapped, number of analyses) and basic device info (device model, OS version, App version). We do not collect precise GPS location. We may infer approximate location from IP for security and aggregate analytics.
Feedback and Support: If you send feedback or contact support, we collect the information you provide (e.g., email and message content) to respond and improve our services.
Subscription and Transaction Data: For in-app purchases, we receive information necessary to confirm purchase status and entitlements (e.g., product identifier, price, currency, purchase and expiration dates) from Apple and our subscription/entitlement management services. We do not receive your credit card number; Apple processes payments.
Cookies and Similar Technologies: The App does not use web cookies. If you visit our website, cookies may be used there as described in that site’s notice. Within the App, we may use local/device storage for preferences and caching; this data remains on your device.
2. How We Use Your Information
We use collected information for the following purposes (and rely on the listed legal bases where applicable):
Provide and Maintain the Service: Authenticate you, process your inputs to generate AI analysis, display results, and maintain your account and history. Legal basis: performance of our contract with you.
Manage Account and Subscription: Determine access rights (free/premium), handle entitlement logic, and send administrative communications (e.g., subscription notices). Legal basis: contract; legitimate interests.
Analyze and Improve: Review usage patterns and feedback, monitor performance and error rates, and improve prompts/features. We prefer aggregated or de-identified datasets where feasible. Legal basis: legitimate interests.
Customer Support & Notices: Respond to support requests and send important service notifications (security, policy updates, outages). Legal basis: legitimate interests; legal obligations where applicable.
Optional Product Updates: If you opt in, we may send occasional product updates or tips; you can unsubscribe anytime. Legal basis: consent.
Enforce Terms & Prevent Misuse: Detect fraud/abuse, protect service integrity, and comply with platform and provider acceptable-use requirements. Legal basis: legitimate interests; legal obligations.
Legal Compliance: Retain and process data to comply with laws (e.g., tax records) and respond to lawful requests.
We will not use your personal information for incompatible purposes without your consent or as required/allowed by law.
3. How We Share Your Information
We value your privacy and do not sell your personal information or share it for cross-context behavioral advertising. We share information only as needed to operate AceSolver:
AI Processing Services (Processors): To deliver analysis, your inputs (and relevant context) are sent to external AI processing services that generate outputs and may retain limited logs for a short period for abuse prevention and troubleshooting. We instruct such providers not to use your data to train public models.
Infrastructure & Operations (Processors): We use third-party providers for cloud hosting, databases, authentication, analytics, email/support, and subscription/entitlement management. They process limited personal data on our behalf under contractual obligations and do not use it for their own purposes.
Platform Operator (Apple Inc.): Sign in with Apple shares your name and email (or relay email) with us. Apple processes your in-app purchases and maintains its own records governed by Apple’s terms and privacy policy.
Business Transfers: Your information may be disclosed in connection with mergers, acquisitions, financing, or sale of assets, subject to continuity of privacy commitments.
Legal & Safety: We may disclose information to comply with law, protect rights and safety, investigate misuse, or respond to lawful requests.
California “Do Not Sell or Share” Notice
We do not sell personal information as defined by the CCPA/CPRA, nor do we share it for cross-context behavioral advertising. If this changes, we will update this Policy and provide appropriate opt-out mechanisms.
4. Data Retention
We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.
Account Data: Retained while your account is active. Upon deletion or termination, removed or anonymized within a reasonable timeframe, subject to required retention (e.g., financial records).
User Inputs & AI Outputs: Stored to enable history/replay features and service quality. You may request deletion of specific items or your account; we will delete or anonymize associated data except where retention is legally required or for aggregated, non-identifying analytics.
Usage Logs: Typically retained for a limited period (e.g., weeks to a few months) for troubleshooting and security, then deleted or de-identified.
Subscription & Transaction Records: Retained for periods required by financial/regulatory obligations (often multiple years), with identifiers minimized where feasible if your account is deleted.
Communications: Retained as needed to address your request and for audit purposes; deletable on request unless legally required to retain.
5. Data Security
We implement technical, administrative, and physical safeguards to protect your data against unauthorized access, alteration, disclosure, or destruction, including:
Encryption: Data is encrypted in transit (HTTPS/TLS). Data at rest on our managed infrastructure is encrypted.
Access Controls: Role-based access, least-privilege principles, confidentiality obligations, and (where appropriate) multi-factor authentication for administrative accounts.
Monitoring & Logging: System monitoring and audit logs to detect anomalies and investigate issues.
Third-Party Oversight: We select reputable providers with appropriate security programs and enter into data-protection agreements. However, no method is 100% secure.
Important: We cannot guarantee absolute security. Protect your Apple ID and device. Notify us promptly of any suspected unauthorized access or security incident.
If a data breach affecting your personal information occurs, we will take prompt steps to mitigate and notify you and regulators as required by law.
6. Your Privacy Rights
Your rights depend on your jurisdiction. We honor applicable rights requests in accordance with law.
GDPR/EEA/UK
Access: Request a copy of your personal data we process.
Rectification: Request correction of inaccurate or incomplete data.
Erasure: Request deletion of your personal data, subject to legal exceptions.
Restriction: Request we limit processing in certain circumstances.
Object: Object to processing based on legitimate interests and to direct marketing.
Portability: Receive data you provided in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
Withdraw Consent: Withdraw consent at any time (does not affect prior processing).
Complaint: Lodge a complaint with your local supervisory authority.
To exercise these rights, contact us using the details below. We may need to verify your identity.
California (CCPA/CPRA)
Right to Know: Request categories and specific pieces of personal information we collected, sources, purposes, and recipients over the prior 12 months.
Right to Delete: Request deletion of personal information, subject to exceptions.
Right to Correct: Request correction of inaccurate personal information.
Right to Opt-Out of Sale/Sharing: Not applicable currently (we do not sell/share for targeted ads). If this changes, we will provide an opt-out.
Right to Limit Use of Sensitive Information: Not applicable as we do not use sensitive information beyond what is necessary to provide the service.
Non-Discrimination: We will not discriminate against you for exercising your rights.
Submit requests via the contact methods below. We will verify and respond within the timelines required by law.
7. Children’s Privacy
AceSolver is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn we have collected such information without appropriate consent, we will delete it. If you are a parent/guardian and believe your child provided us information, please contact us.
Note: The App’s content rating on the App Store is 4+ for content suitability; however, account features and data collection are intended for users who meet age and consent requirements in their jurisdiction (parental consent may be required for minors).
8. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in practices, technologies, or legal requirements. Material changes will be notified as required (e.g., in-app notice and updated “Last Updated” date). Continued use of the App after changes become effective constitutes acceptance.
9. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: