Privacy Policy

Last updated: February 25, 2026

1. Data Controller

The data controller for this website and service is:

AI Vantage — SAS au capital de 1 000 EUR 5 Terrasse Des Reflets, 5e etg, 92400 Courbevoie, France RCS Nanterre 101 403 277 Email: contact@pokeradvisor.ai

2. What Data We Collect

We collect and process the following personal data:

2.1 Account Data

  • Name, email address, and profile picture (provided at registration or via third-party login such as Google or GitHub)
  • Authentication tokens and session data

2.2 Usage Data

  • Poker hand histories that you upload or create for analysis
  • AI analysis results generated from your hand histories
  • Usage counters (daily/monthly analysis counts)
  • User preferences and settings (e.g., analysis mode, engine configuration)

2.3 Technical Data

  • IP address (stored in activity logs for security purposes)
  • Browser type and version, device type
  • Pages visited, timestamps, and referring URLs

2.4 Payment Data

  • If you subscribe to a paid plan, payment processing is handled by our third-party payment processor. We do not store your credit card number or full payment details. We only retain your subscription status and plan type.

3. Legal Basis for Processing (Article 6 GDPR)

| Purpose | Legal basis | |---|---| | Providing the service (analysis, history, account) | Performance of a contract (Art. 6(1)(b)) | | Account creation and authentication | Performance of a contract (Art. 6(1)(b)) | | Security logging (IP, activity logs) | Legitimate interest (Art. 6(1)(f)) | | Service improvement and analytics | Legitimate interest (Art. 6(1)(f)) | | Email communications about your account | Performance of a contract (Art. 6(1)(b)) | | Marketing emails (if applicable) | Consent (Art. 6(1)(a)) |

4. How We Use Your Data

We use your personal data to:

  • Provide, operate, and maintain the Poker [AI]dvisor service
  • Process and analyze your poker hand histories using AI models
  • Save your analyses and hand history for your future reference
  • Manage your account, subscription, and usage quotas
  • Ensure the security and integrity of the service
  • Respond to your inquiries and support requests
  • Improve the service based on aggregated, anonymized usage patterns

5. Data Processors and Third Parties

We use the following third-party service providers (data processors) who may process your personal data on our behalf:

| Processor | Purpose | Location | Safeguards | |---|---|---|---| | Supabase | Database hosting (PostgreSQL) | EU (AWS eu-west-1) | Data Processing Agreement; EU-hosted | | Vercel | Web hosting and deployment | EU / US (edge network) | Data Processing Agreement; Standard Contractual Clauses |

All processors are bound by data processing agreements in accordance with Article 28 GDPR. Where data is transferred outside the EU/EEA, appropriate safeguards are in place (Standard Contractual Clauses or adequacy decisions).

6. International Data Transfers

Your primary data (account, hand histories, analyses) is stored in the EU (Supabase, AWS eu-west-1, Ireland).

When you request an AI analysis, the hand history data for that specific analysis may be sent to AI provider servers that could be located outside the EU. These transfers are protected by Standard Contractual Clauses (SCCs) and the providers' data processing agreements.

7. Data Retention

| Data type | Retention period | |---|---| | Account data | Until you delete your account | | Hand histories and analyses | Until you delete them, or until account deletion | | Usage logs (daily/monthly counters) | 12 months, then automatically deleted | | Activity logs (IP, actions) | 6 months, then automatically deleted | | Technical/server logs | 30 days |

When you delete your account, all associated personal data is permanently deleted within 30 days.

8. Your Rights (Articles 15-22 GDPR)

Under the GDPR, you have the following rights:

  • Right of access (Art. 15) — Obtain a copy of all personal data we hold about you
  • Right to rectification (Art. 16) — Correct inaccurate or incomplete data
  • Right to erasure (Art. 17) — Request deletion of your personal data ("right to be forgotten")
  • Right to restriction (Art. 18) — Restrict processing in certain circumstances
  • Right to data portability (Art. 20) — Receive your data in a structured, machine-readable format
  • Right to object (Art. 21) — Object to processing based on legitimate interests
  • Right to withdraw consent (Art. 7(3)) — Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, contact us at contact@pokeradvisor.ai. We will respond within 30 days.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

  • Encrypted data transmission (HTTPS/TLS)
  • Encrypted database connections
  • Authentication via secure session tokens
  • Role-based access controls
  • Regular security updates

10. Cookies

We use only essential cookies required for the service to function (authentication session, preferences). We do not use tracking cookies or third-party advertising cookies.

If we introduce non-essential cookies in the future, we will request your explicit consent before placing them.

11. Children

Poker [AI]dvisor is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a person under 18, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page with a revised "Last updated" date. For significant changes, we may also notify you by email.

13. Supervisory Authority

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority. In France, the competent authority is:

CNIL (Commission Nationale de l'Informatique et des Libertés) 3 Place de Fontenoy, TSA 80715 75334 Paris Cedex 07 Website: www.cnil.fr

14. Contact

For any questions or requests regarding this Privacy Policy or your personal data:

Email: contact@pokeradvisor.ai