Privacy Policy

1. Introduction

This privacy policy explains how we collect, use, store and disclose personal information when you use our live poker hand recorder mobile application (the App). HandRecorder is designed as a privacy-first poker tracking app for Texas Hold'em players and tournament poker enthusiasts. The App offers three subscription tiers—Free, Plus, and Premium—each providing different features. By using the App or accessing any service we provide, you acknowledge that your personal information will be handled as described in this policy. If you do not agree with the terms of this policy, please do not use the App.

We are based in Örebro, Sweden and act as the data controller for information collected through the App. Our processing of personal data complies with the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws. If you have any questions about this policy or your personal data rights, please contact us using the details in the Contact information section.

2. Information We Collect

We collect different types of information depending on which tier you use and which features you enable. HandRecorder is designed to minimize data collection - we only collect the minimum information necessary to provide our live poker tracking services. Unlike other poker apps, we don't require user accounts or collect personal identifiers.

2.1. Information you provide

2.2. Information we collect automatically

When you use the poker tracking app, we automatically collect certain information about your device and usage. This information helps us to operate and secure the App, understand how live poker players interact with it and improve performance. We limit the data we collect to what is necessary for legitimate purposes.

2.3. Information collected from third parties

• Advertising networks – For Free tier poker app users, we display ads using AdMob. AdMob collects certain device and usage data (IP address, device ID, crash logs, performance metrics and advertising interactions) for ad targeting and analytics.
• Payment processors – If you subscribe to Plus or Premium poker tracking features, Apple Pay or Google Pay may send us a payment confirmation and your transaction ID. We do not receive your full credit‑card number or other sensitive payment data.

3. How We Use Your Information

We use the information we collect for legitimate interests, contractual obligations and, where required by law, on the basis of your consent. Specifically, we use your information to provide the best poker tracking app experience:

1. Provide and maintain the poker app – To deliver core functionality such as recording Texas Hold'em hands, storing offline poker venue data, performing tournament searches, synchronizing poker data across devices and generating poker statistics.
2. Facilitate poker app subscriptions and transactions – To process subscription payments and manage billing for advanced poker tracking features (Plus and Premium tiers).
3. Provide multi‑device synchronization – If you enable iCloud synchronization, your poker hand histories and preferences are stored in your personal iCloud account using Apple's CloudKit. This allows you to access the same poker data across your own devices. We do not access your Apple ID or email and cannot read your iCloud contents.
4. Improve and personalize the poker app – To analyse usage patterns among live poker players, fix bugs, develop new features, and customize the content (e.g., recommending poker venues or tournaments).
5. Provide advanced poker statistics and exports – In the Premium tier, we generate advanced poker statistics and offer advanced export formats (CSV, JSON, PokerStars). These features require processing of your recorded Texas Hold'em hands.
6. Send poker notifications – If you enable notifications, we will send alerts about upcoming poker tournaments, stop‑loss thresholds, or poker app updates. You can control notifications through your device settings.
7. Display advertising – In the Free tier, we display personalized or contextual ads via AdMob. AdMob uses device and usage data to deliver relevant ads to poker app users. You can opt out of personalized ads through your device settings.
8. Provide customer support – To respond to your inquiries about poker app features, troubleshoot issues and communicate about your subscription or use of the App.
9. Comply with legal obligations – To comply with applicable laws, regulatory requirements and enforce our legal rights.

4. Legal Basis for Processing

Under the GDPR, we rely on the following legal bases to process personal data for our poker tracking app:

• Contractual necessity – We process subscription information and relevant transaction records to provide the poker app's paid features and fulfil our contract with you. As we do not require a separate user account, we do not process account identifiers such as email addresses.
• Legitimate interests – We process device and usage information to improve the poker app, prevent fraud and secure our services for live poker players, provided that such processing does not outweigh your rights and freedoms.
• Consent – We collect location data and send marketing communications or personalized ads related to poker venues and tournaments only when you have given us consent. You can withdraw your consent at any time.
• Compliance with legal obligations – We process data when required to comply with laws or respond to lawful requests by public authorities.

5. Advertising and Analytics

For Free tier poker app users, the App uses the Google Mobile Ads SDK (AdMob) to display advertisements relevant to poker players. The SDK may collect the following data to improve ad performance and measure engagement: IP address (used to estimate location), crash logs, user‑associated performance data (such as app launch time and energy usage), device ID, advertising data (e.g., ads viewed) and user interactions. AdMob may share this data with its advertising partners.

You can opt out of personalized advertising by changing the advertising settings on your device (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android). Opting out will not remove ads entirely but will limit AdMob's use of your data for targeting purposes.

We use our own analytics to evaluate usage patterns among live poker players. This data is aggregated and pseudonymized. We do not use third‑party analytics services that track you across different apps or websites.

6. Data Sharing and Disclosure

We do not sell or rent your personal data or poker information. We share your information only in the circumstances described below:

• Service providers – We use third parties to host servers, provide cloud storage, process payments and deliver advertisements for poker app users. These service providers access your information only to perform tasks on our behalf and are bound by contractual obligations to protect your data.
• Analytics and advertising partners – AdMob receives device and usage data to serve ads to poker players.
• Legal compliance – We may disclose your information if required by law or to respond to valid requests by public authorities (e.g., a court or government agency).
• Business transfers – If we are involved in a merger, acquisition or asset sale, your information may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

7. Data Retention

We retain your personal data only as long as necessary for the purposes described in this policy or as required by law. Generally:

• Poker hand histories and session notes are stored until you delete them. Deleting a session will remove the associated poker data from your device and our servers. Because we do not maintain user accounts, there is no account to delete.
• Subscription and purchase records for poker app features are retained for the duration of your subscription and for a reasonable period thereafter (for example, to comply with legal or tax obligations). Because we do not maintain separate user accounts, there is no persistent account profile to delete.
• Usage and device information is retained for analytics purposes for up to 24 months, after which it is either deleted or aggregated.

8. International Data Transfers

Our servers may be located in jurisdictions outside your country of residence. If we transfer personal data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or other lawful transfer mechanisms. By using the poker tracking app, you consent to the transfer of your data to countries that may have different data protection laws than your country, but which provide an adequate level of protection.

9. Your Rights

If you are located in the EEA, UK or other jurisdictions that provide privacy rights, you have the following rights regarding your personal data related to your poker app usage:

1. Right to be informed – You have the right to know what poker data we collect, why, how we use it, and who we share it with.
2. Right of access – You can request a copy of your personal data and information about our processing activities related to your poker tracking.
3. Right to rectification – You may request that inaccurate or incomplete poker data be corrected.
4. Right to erasure – You may ask us to delete your personal data when it is no longer necessary, you withdraw consent, or the data has been unlawfully processed. We will also inform third‑party recipients of the erasure when feasible.
5. Right to restrict processing – You can request that we limit the way we use your poker data in certain circumstances, such as when you contest its accuracy.
6. Right to data portability – You can request that we provide your poker data in a structured, commonly used and machine‑readable format, or transfer it to another provider.
7. Right to object – You can object to the processing of your data based on legitimate interests or direct marketing related to poker services. We will comply unless we have compelling legitimate grounds.
8. Rights related to automated decision‑making – We do not perform automated decision‑making or profiling that produces legal or significant effects for poker app users.
9. Right to withdraw consent – If processing is based on your consent, you may withdraw it at any time. This will not affect the lawfulness of processing before withdrawal.

To exercise your rights, please contact us using the details in the Contact information section. We may ask for verification of your identity. You have the right to lodge a complaint with your local data protection authority if you believe our processing violates applicable law.

10. Security

We implement administrative, technical and physical safeguards to protect personal data and poker information against unauthorized access, disclosure, alteration and destruction. These measures include encryption, secure data centers, access controls and regular security assessments. While we strive to protect your poker data, no method of transmission or storage is completely secure; therefore, we cannot guarantee absolute security.

11. Children's Privacy

The poker tracking app is intended for adult users and is not directed to individuals under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that a child has provided us with personal information without parental consent, we will delete that information and terminate the child's access to the App. If you believe that a minor has provided us with personal data, please contact us.

12. Changes to This Policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements for poker app operations. We will post the updated version in the App and indicate the date of revision. If we make material changes, we will provide a prominent notice (such as via email or in‑App notification) prior to the change becoming effective. Your continued use of the poker tracking app after the effective date of the revised policy constitutes acceptance of the updated terms.

13. Contact Information

If you have questions, concerns or requests regarding this privacy policy or your personal data related to poker app usage, please contact us:

• Email: handrecorder-support@nikielhard.se
• Address: Myggvägen 19, 702 30 Örebro, Sweden

We will respond to your requests without undue delay and within the timeframes required by applicable law. If we are unable to resolve your concerns, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten) or your local supervisory authority.