Privacy Policy

Welcome to PokerInk. This Privacy Policy outlines how we collect, use, and protect your information when you use our Service, accessible through our website or related services. Your privacy is a top priority, and we are committed to maintaining your trust.

Accelra Technologies Inc. is the legal entity that operates PokerInk. References to "PokerInk", "we", "us", or "our" in this policy refer to Accelra Technologies Inc..

1. Personal Data

While using our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. This may include:

• Email address, phone number, display name, username, and profile image
• Authentication information from third-party providers (for example, Google or Apple)
• Poker sessions, hands, notes, uploaded hand/profile images, comments, messages, feedback, and training progress you choose to create
• Purchase, subscription, and entitlement status when you buy paid features
• Push notification tokens if you enable notifications
• Usage data, app preferences, diagnostics, and approximate device/network information

2. Usage Data

We may also collect information about how the Service is accessed and used. This Usage Data may include:

• Device Information: IP address, device type, operating system, app version, browser type/version where applicable, and crash or diagnostic data
• Interaction Data: Screens and features used, training activity, AI coach requests, feedback interactions, and timing information
• Unique Identifiers: Account/session identifiers, device push tokens, and service-generated identifiers used for authentication, security, analytics, and app functionality

We retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

Your Right to Delete Your Data: You have the right to request the deletion of your personal information from our systems. You can request permanent deletion by:

• Sending an email to support@pokerink.com with the subject line "Data Deletion Request"
• Using the account deletion option in your profile settings

Timeframe for Deletion: We delete your account data from our active systems within 30 days of your request, and purge it from encrypted backups within a further 90 days. We will send you a confirmation email once the deletion is complete.

Data Retention Exception: Some information may be retained beyond deletion for legal or administrative purposes:

• Records required for tax or financial reporting - retained for the period required by law (in Canada, generally 6–7 years per Canada Revenue Agency requirements).
• Information needed to detect and prevent fraud or abuse - retained only as long as necessary for that purpose.
• Moderation and child-safety (CSAE) records - retained as described in the "Moderation & Safety Data" section, which may extend beyond account deletion where required by law.
• Information we are otherwise legally required to retain.

California Residents (CCPA): If you are a California resident, you have specific rights under the California Consumer Privacy Act including the right to know, delete, opt-out of sale, and non-discrimination. Contact us at support@pokerink.com to exercise these rights.

Legal bases for processing

Where data-protection law requires a legal basis, we rely on: (a) performance of a contract to provide your account, subscriptions, and the features you use; (b) legitimate interests to secure the Service, prevent abuse and fraud, and improve our product; (c) consent for optional marketing and push notifications, which you can withdraw at any time; and (d) legal obligation for tax records and child-safety (CSAE) reporting.

Canadian residents (PIPEDA / BC PIPA)

You may request access to or correction of your personal information, and withdraw consent to optional processing. If you have a concern, you may contact us or file a complaint with the Office of the Privacy Commissioner of Canada or the Office of the Information and Privacy Commissioner for British Columbia.

EEA / UK residents (GDPR)

You have the right to access, rectify, erase, restrict, or object to the processing of your personal data, to data portability, and to withdraw consent. You may also lodge a complaint with your local data protection supervisory authority.

California residents (CCPA/CPRA)

You have the right to know, delete, correct, and opt out of the sale or sharing of your personal information, and not to be discriminated against for exercising these rights. We do not sell or share your personal information for cross-context behavioral advertising.

To exercise any of these rights, contact us at support@pokerink.com. We will respond within the timeframe required by applicable law and may need to verify your identity first.

PokerInk uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features such as comments, messaging, shared hands, feedback, and notifications
• To provide AI coaching, trainer progress, analytics, subscriptions, and customer support
• To process payments and manage subscription entitlements
• To gather product analytics to improve our Service
• To monitor usage, detect abuse, moderate user-generated content, prevent fraud, and address technical issues

When users report content or accounts, or when PokerInk takes moderation action, we collect and retain the following data for safety, trust, and legal-compliance purposes:

Content reports

• Reporter identity: The user ID of the account that submitted the report (kept confidential from the reported user).
• Report category and reason: The violation type selected and any free-text description provided.
• Content reference: A pointer to the reported content (hand ID, comment ID, message ID, or profile ID) and, where applicable, a snapshot of the content at the time of report.

Moderation actions and audit log

• Records of moderation decisions (content removal, warnings, suspensions, permanent bans) and the staff or automated system that made them.
• Timestamps of each action to maintain an auditable history.

Block lists

• When you block another user, we store a record of that relationship to enforce the block across the platform.

Retention of moderation data

Moderation and safety data is retained for the period necessary to fulfil safety and legal obligations - which may extend beyond account deletion. In cases involving child safety (CSAE), records may be retained indefinitely and shared with law-enforcement authorities as required by law.

We may share your personal information in the following situations:

• Service Providers: Third-party providers who perform tasks on our behalf (cloud hosting, authentication, SMS/OTP delivery, payments and subscriptions, analytics, email delivery, push notifications, image storage, and AI infrastructure) are only authorized to process information for those services.
• Legal Requirements: We may disclose your information where required by law or in response to valid requests by public authorities.

PokerInk offers AI-powered coaching and analysis. When you use these features, the relevant content - such as hand histories, notes, and the prompts you submit - is transmitted to and processed by third-party AI providers acting as our service providers, solely to generate the coaching or analysis you requested.

This content is not used to train third-party AI models, is not sold, and is not used for advertising. AI-generated output is provided for informational and educational purposes only and may be inaccurate or incomplete; you remain responsible for your own decisions.

Accelra Technologies Inc. is based in British Columbia, Canada, and our service providers may operate in the United States and other countries. As a result, your personal information may be transferred to, stored in, and processed in countries other than the one in which you live, whose data-protection laws may differ from those of your jurisdiction.

Where required, transfers of personal information from the European Economic Area or the United Kingdom rely on appropriate safeguards such as Standard Contractual Clauses or an applicable adequacy decision. By using the Service, you understand that your information may be processed outside your home jurisdiction as described in this Policy.

The Service uses cookies, secure local storage, and similar technologies for:

• Session Management: To keep you logged in
• Preferences: To store theme and layout settings
• Authentication: To remember your login status

You can manage cookies via your browser settings. Note that disabling cookies may affect your experience.

We implement industry-standard measures to protect your information, including:

• Secure transmission of data (HTTPS)
• Restricted access to sensitive information
• Regular security assessments and updates
• Encryption of sensitive data in transit and secure storage for mobile authentication tokens

If a security breach affecting your personal information occurs, we will notify you and the relevant supervisory authorities (such as the Office of the Privacy Commissioner of Canada) where required by applicable law and without undue delay, consistent with our legal obligations.

PokerInk is intended for adults (18+) and is not directed to children. We do not knowingly collect personal information from anyone under 18. If you believe a child has provided us with personal information, contact us at support@pokerink.com and we will delete it and terminate any associated account.

We may update our Privacy Policy from time to time. We will notify you by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date at the top
• Sending you an email notification for material changes

If Accelra Technologies Inc. is involved in a merger, acquisition, or sale of assets, your personal information may be transferred. We will notify you before your information is transferred and provide options to download or delete your data.

Accelra Technologies Inc. is the controller responsible for your personal information. Our Privacy Officer can be reached at support@pokerink.com for any privacy questions or to exercise your rights.