AppThemis Technologies Inc. (“Company,” “we,” “us,” or “our”) operates the AceSolver mobile applications and the AceSolver web app at acesolver.com (together, 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. Where we rely on your consent (for example, for optional cookies on our website or optional emails), we ask for it separately, and you can withdraw it at any time.
Please read this Privacy Policy carefully. 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 with Sign in with Apple or Sign in with Google, we receive personal identifiers such as your name and email address (with Apple, possibly an anonymized relay email, depending on your Apple settings) and, with Google, your profile picture if you have one. We store this to identify you and manage your account. You can also start using the App before signing in; in that case we create a guest account identified only by a random identifier, which is attached to your account if you later sign in.
Authentication Identifiers: Apple and Google provide a unique user identifier that we use to recognize your account across sessions and devices. We do not receive or store your Apple ID or Google account 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.
Analysis Results: To analyze your submissions, we send them to external service providers for automated processing (see Section 3), which return the results used to produce your analysis and coaching responses (“Analysis Results”). We save Analysis Results alongside your inputs to provide 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. This includes the optional email address you may add to a feedback form, and the messages you exchange with our team in the App’s Messages screen, which are stored with your account (or guest account) so the conversation stays available to you and to us.
Push Notification Tokens: If you allow notifications, your device gives the App a push token (from Apple on iOS, or Google Firebase Cloud Messaging on Android). We store it with your account and platform only to send you notifications such as replies from our team and App announcements. It is removed when you sign out or delete your account, and you can turn notifications off at any time in your device settings.
Subscription and Transaction Data: We receive information necessary to confirm purchase status and entitlements (e.g., product identifier, price, currency, purchase and expiration dates) from the store or payment service you used and from our subscription management provider (RevenueCat). Purchases in the iOS app are processed by Apple, purchases in the Android app by Google Play, and purchases on acesolver.com by RevenueCat and its payment processor Stripe. We do not receive or store your full card number.
Install Attribution (iOS and Android apps): We use AppsFlyer to measure which campaigns lead to installs, sign-ups, and purchases of the iOS and Android apps. We use AppsFlyer in a way that does not collect Apple’s advertising identifier (IDFA) or Google’s advertising ID, and we do not track you across other companies’ apps or websites. Attribution relies on Apple’s privacy-preserving, aggregated install reporting, on Apple’s attribution token for Apple Search Ads, on the Google Play install referrer (which tells us which link led to an Android install), and on an AppsFlyer identifier for your installation. We link these, and the campaign that brought the install, to your subscription records (through RevenueCat) to measure revenue by campaign.
Cookies and Similar Technologies (website and web app): On acesolver.com we use:
Necessary cookies and storage to keep you signed in, remember your preferences, and remember your cookie choice. These are always on.
Aggregate visit counts: when you arrive on our home page, we add one to a daily count kept by page, campaign tags in the link (source, medium, campaign) and country. This uses no cookie, stores nothing in your browser, and keeps no IP address or other identifier, so it cannot be linked to you. It runs for every visitor, whatever your cookie choice.
Optional analytics and advertising technologies. Outside the United States, they are used only if you click “Accept” in our cookie banner; if you decline or ignore the banner, none of them is used. In the United States, they are on when you arrive, with a notice and an “Opt out” button; if you opt out, none of them is used again (see “California ‘Do Not Sell or Share’ Notice” below). We determine which rule applies from the country of your connection, without storing your IP address:
Google Analytics, the Reddit Pixel and the TikTok Pixel, which set their own cookies and receive information about your visit (see Section 3).
Campaign attribution: a first-party cookie and browser storage that record how you arrived when your visit came from a tagged link or another website (campaign tags, the referring website’s address, the page you landed on, and the date and time). The cookie lasts up to 30 days; the browser storage lasts until you decline, change your choice, or clear your browser data. If you create an account, the campaign source is saved to your account so we know which channels bring new players. The campaign source and name may also accompany the events sent to Google Analytics.
You can change your choice at any time with the “Cookie settings” link at the bottom of the site. If you decline after accepting, we stop sending events, delete these cookies and the attribution record from your browser, and do not save attribution to an account created afterwards; information already sent to Google, Reddit or TikTok is kept under their own retention rules.
Mobile Apps: The iOS app does not use web cookies; it uses local device storage for preferences and caching, which remains on your device. The Android app is built on our web app and uses only the necessary cookies described above, plus a device identifier stored for one year that we link to your account to prevent abuse of free trials and free usage limits. The Android app does not use Google Analytics, the Reddit Pixel, the TikTok Pixel, or campaign attribution cookies; it uses AppsFlyer as described above.
Required and optional information: Account information and the data needed to run the service (your submissions, usage, and subscription status) are required to provide the App; without them we cannot create your account or provide analysis. Optional website cookies, campaign attribution, and marketing emails are not required, and declining them does not limit your use of the App.
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 poker 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 refine the instructions we use to generate analyses and improve App 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), including push notifications when we reply to you or post an announcement, if you have allowed notifications. Legal basis: legitimate interests; legal obligations where applicable.
Measure Our Marketing: Understand which campaigns and websites bring visitors and new players, and measure sign-ups and purchases. Legal basis: consent for analytics, advertising, and campaign attribution on our website; legitimate interests for install attribution in the iOS and Android apps, which does not use an advertising identifier (see Section 1).
Optional Product Updates: If you opt in, we may send occasional product updates or tips; you can unsubscribe anytime. Promotional emails may include a small pixel that tells us whether the email was opened, and every email includes an unsubscribe link. 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. We share information only as needed to operate and promote AceSolver:
External Analysis Providers (Processors): To deliver analysis, we send your inputs and the relevant context to third-party service providers that process them automatically, including automated text-generation services, and return Analysis Results. When the App reads coaching responses aloud, their text is also sent to a voice-synthesis provider. These providers may retain limited request logs for a short period for abuse prevention, troubleshooting, and legal compliance. We instruct them not to use your inputs or Analysis Results to develop or improve their own general-purpose services offered to the public.
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 Operators (Apple and Google): If you sign in with Apple or Google, that company shares your name and email (or relay email) with us. Apple (App Store) and Google (Google Play) process in-app purchases made through their stores and maintain their own records under their own terms and privacy policies.
Payments and Subscriptions (Processors): RevenueCat manages subscription status across platforms; Stripe processes card payments made on acesolver.com.
Notifications and Support Alerts (Processors): Apple (Apple Push Notification service) and Google (Firebase Cloud Messaging) deliver push notifications to your device. When you send a support message or feedback, a copy of the message, any contact email you provided, your account email, and your platform are sent to our team through a private Telegram channel so we can respond quickly.
Install Attribution (iOS and Android): AppsFlyer processes install and in-app event data from the iOS and Android apps on our behalf to measure our campaigns, as described in Section 1.
Analytics and Advertising Partners (with your consent, or in the United States until you opt out): When optional cookies are on for you on acesolver.com (see Section 1), Google (Google Analytics) receives page views, sign-ups, checkout starts, and purchases, Reddit (Reddit Pixel) receives page visits, sign-ups, and purchases, and TikTok (TikTok Pixel) receives page views, sign-ups, checkout starts, and purchases. With these events they receive browser and device information, your IP address (from which approximate location is derived), their cookie identifiers, and, for checkout starts and purchases, the plan’s price and currency (the plan price is sent even when the purchase starts a free trial). We use this to measure our campaigns. Google, Reddit and TikTok process this information under their own privacy policies. We have disabled Google Signals and sharing of our Analytics data for Google’s own product improvement.
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. The Reddit Pixel and the TikTok Pixel on acesolver.com may be considered “sharing” for cross-context behavioral advertising under California law. For visitors in the United States they are on when you arrive, and you can opt out at any time with the “Opt out” button in the notice or the “Cookie settings” link at the bottom of the site. We honor Global Privacy Control: if your browser sends it, the Reddit Pixel and the TikTok Pixel are never loaded. Outside the United States these technologies are off unless you accept them.
International Transfers
We are based in Canada, and our service providers may process your information in Canada, the United States, and other countries. For information from the European Economic Area, the United Kingdom, or Switzerland, transfers to Canada rely on the adequacy decision recognizing Canadian privacy law, and transfers to the United States rely on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where the recipient is certified, or on the European Commission’s Standard Contractual Clauses. You can request more information about these safeguards, or a copy of them, using the contact details below.
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 & Analysis Results: 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.
Website Analytics and Attribution: We set Google Analytics to keep event-level data linked to cookie or user identifiers for 14 months; for a visitor who keeps returning, Google’s retention period restarts with each visit. Aggregated reports are not affected by these settings. In your browser, the attribution cookie expires after 30 days and the attribution record remains until you decline, change your choice, or clear your browser data. A campaign source saved to your account is kept as part of your account data.
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. Support conversations in the App are kept while your account exists and are deleted with your account. Push notification tokens are kept until you sign out, delete your account, or the token stops working.
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 or Google account and your 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.
Canada (including Quebec)
Access and Correction: Request access to the personal information we hold about you and ask us to correct it.
Withdraw Consent: Withdraw your consent at any time, subject to legal or contractual restrictions; for website cookies, use the “Cookie settings” link at the bottom of acesolver.com.
Deletion: Request deletion of your personal information where the law allows it.
Portability: Request a copy of the personal information you provided to us in a structured, commonly used technological format.
Complaint: Contact our Privacy Officer first (details below). You may also contact the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.
Deleting Your Account
You can delete your account at any time from the account settings in the iOS app, the Android app, or acesolver.com. This removes your account and associated data as described in Section 4. Deleting your account does not cancel a subscription purchased through Apple or Google; manage or cancel those in your App Store or Google Play settings.
California (CCPA/CPRA)
Right to Know: Request categories and specific pieces of personal information we collected, sources, purposes, and recipients.
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: We do not sell personal information. For visitors in the United States, the advertising technologies described in Section 1 are on when you arrive; you can opt out at any time with the “Opt out” button in the notice or the “Cookie settings” link at the bottom of acesolver.com, and we honor Global Privacy Control (see “California ‘Do Not Sell or Share’ Notice” in Section 3).
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). Where a change requires your consent, we will ask for it before applying the change to you.
9. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: