1. Introduction and Who We Are

This Privacy Policy explains how Precision Play Ltd (“we”, “us”, “our”) collects, uses, stores, and shares your personal data when you use the Preflop Dojo website at app.preflopdojo.com, our marketing website at preflopdojo.com, our iOS and Android mobile applications, and all related services (collectively, the “Service”).

We are the data controller for the personal data described in this Privacy Policy. Our details are:

Company: Precision Play Ltd

Company Number: 15868293 (England and Wales)

Registered Address: Crown House, 27 Old Gloucester Street, London, WC1N 3AX, England

Email: info@precision-play.co.uk

It is important that you read this Privacy Policy together with our Terms of Service and Cookie Policy so that you are fully aware of how and why we are using your data. This Privacy Policy supplements those documents and is not intended to override them.

The Service is not intended for children under 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a person under 18 without appropriate consent, we will take steps to delete that data promptly.

2. What Data We Collect

We collect and process different categories of personal data depending on how you interact with the Service. We have grouped these into the following categories:

2.1. Account Information

When you register for an account, we collect the email address you provide and the password you create. Your account is assigned a unique user identifier which is used internally to associate your data across the Service.

2.2. Payment and Subscription Information

When you subscribe to a paid plan, we process information relating to your subscription status, billing period, and payment provider (Stripe or Apple). We do not directly collect or store your full payment card details. These are held and processed by our third-party payment processors (Stripe and Apple). We receive and store:

• Your Stripe customer identifier and subscription identifier (for web and Android purchases)
• Your Apple original transaction identifier and product identifier (for iOS purchases)
• Subscription status, plan details, and billing dates

2.3. Usage and Training Activity

When you use the Service, we collect data about your training activity and how you interact with the platform. This includes:

• Training session results: the hands you were dealt, the actions you chose, whether your answers were correct, and session timestamps
• Session history and performance statistics
• Your preferences and settings, such as keybindings, colour schemes, selected training sets, and accuracy tolerance

2.4. Technical and Device Information

We automatically collect certain technical information when you access the Service. This includes:

• IP address
• Browser type and version
• Operating system and platform
• Device type (web, iOS, or Android)
• Page load performance, JavaScript errors, and session flow data (collected via AWS Real User Monitoring)

2.5. Marketing Attribution Data

When you register for an account, we may capture information about how you found the Service. This includes UTM parameters (source, medium, and campaign identifiers) and your signup source. This data helps us understand which marketing channels are effective.

2.6. Communications

If you contact us for support, provide feedback, or communicate with us through email or our Discord community, we may retain the content of those communications along with your email address for the purpose of responding to your enquiry and improving the Service.

2.7. Information We Do Not Collect

We do not collect special categories of personal data as defined under UK GDPR (such as data concerning racial or ethnic origin, political opinions, religious beliefs, health, sexual orientation, or biometric data). We do not collect financial information such as bank account or payment card numbers directly. We ask you not to provide any such information to us.

3. How We Collect Your Data

3.1. Information You Provide Directly

We collect personal data that you provide to us when you:

• Complete the registration form and create an account
• Subscribe to a paid plan
• Update your account settings or preferences
• Contact us for support or provide feedback
• Communicate with us via email or Discord

3.2. Information Collected Automatically

When you access and use the Service, certain data is collected automatically through your browser or device. This includes the technical and device information described in Section 2.4, performance monitoring data collected via AWS Real User Monitoring, and analytics data collected via Google Analytics and Google Tag Manager.

We use cookies and similar technologies to collect some of this information. Please refer to our Cookie Policy for full details of the cookies we use, their purposes, and your choices regarding them.

3.3. Information from Third Parties

We may receive limited information from third-party services that you use to interact with us:

• Payment processors (Stripe, Apple): confirmation of payment events, subscription lifecycle updates, and transaction identifiers
• App store platforms (Apple App Store, Google Play): app installation data and in-app purchase confirmations

4. How and Why We Use Your Data

We only use your personal data where we have a lawful basis for doing so under applicable data protection law. The table below sets out the purposes for which we process your data, the categories of data involved, and the lawful basis we rely on.

5. Who We Share Your Data With

We do not sell your personal data. We share your data only with the following categories of recipients and only to the extent necessary for the stated purposes:

5.1. Service Providers and Processors

We use the following third-party service providers who process personal data on our behalf:

We require all service providers to process your data only in accordance with our instructions and applicable data protection law. They are not permitted to use your data for their own purposes.

5.2. Poker Platform Operators and Industry Bodies

As described in Section 9 of our Terms of Service, we may share non-personally-identifiable, anonymised usage data with poker platform operators and industry bodies for the purpose of monitoring compliance with our prohibition on real-time assistance. This may include confirming whether a particular poker situation was searched for within the Service at a particular time. We will not share your name, email address, or other directly identifying information in this context without your consent or a legal obligation to do so.

5.3. Professional Advisers

We may share your data with our legal, accounting, and insurance advisers where necessary for the conduct of our business, the exercise of our legal rights, or compliance with legal obligations.

5.4. Legal and Regulatory Disclosure

We may disclose your personal data where required to do so by law, regulation, court order, or other legal process, or where we believe disclosure is necessary to protect our rights, your safety, the safety of others, or to investigate fraud.

5.5. Business Transfers

If Precision Play Ltd is involved in a merger, acquisition, sale of assets, or other business restructuring, your personal data may be transferred as part of that transaction. We will notify you of any such transfer and any choices you may have regarding your data.

6. International Data Transfers

Your personal data is primarily stored on AWS servers located in the European Union (Ireland, eu-west-1). However, some of our service providers are based outside the UK and the EEA, particularly in the United States.

Whenever we transfer your personal data outside the UK or EEA, we ensure that appropriate safeguards are in place to protect your data, including:

• Transfers to countries that the UK government or European Commission has determined provide an adequate level of data protection
• Use of the UK International Data Transfer Agreement (IDTA) or EU Standard Contractual Clauses (SCCs) approved by the relevant authorities
• Transfers to US-based providers who participate in the EU-US Data Privacy Framework, where applicable

If you would like further information about the specific safeguards applied to any particular transfer, please contact us at info@precision-play.co.uk.

7. How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The specific retention periods depend on the category of data:

We may retain data for longer than the periods stated above where necessary for the establishment, exercise, or defence of legal claims, or where required by law.

Where we no longer need your personal data, we will securely delete or anonymise it. Anonymised data (which cannot be used to identify you) may be retained indefinitely for statistical and analytical purposes.

8. Data Security

We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it from unauthorised access, loss, alteration, or disclosure. These measures include:

• All data in transit is encrypted using HTTPS/TLS via AWS CloudFront and AWS Certificate Manager
• Sensitive credentials (such as payment processor API keys) are stored in AWS Secrets Manager, not in application code or environment variables
• Authentication is managed through AWS Cognito with industry-standard JWT token-based security
• Access to backend systems is restricted using least-privilege IAM policies
• DynamoDB tables have point-in-time recovery enabled for data resilience
• We monitor for security events using CloudWatch alarms and real-time alerting

While we take reasonable precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, and you acknowledge that you provide your data at your own risk.

9. Your Rights

Under applicable data protection law (including UK GDPR and, where applicable, EU GDPR), you have the following rights in relation to your personal data:

• Right of access: You have the right to request a copy of the personal data we hold about you.
• Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
• Right to erasure: You have the right to request that we delete your personal data, subject to certain legal exceptions (such as where we are required to retain it for tax purposes).
• Right to restrict processing: You have the right to request that we limit how we use your data in certain circumstances.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that we transfer it to another controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data where we rely on legitimate interest as the lawful basis. This includes the right to object to processing for direct marketing purposes.
• Right to withdraw consent: Where we process your data on the basis of your consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at info@precision-play.co.uk. We will respond to your request within one month. In exceptional circumstances (for example, where your request is complex or we have received a large number of requests), we may extend this period by up to two further months, and we will inform you if this is the case.

There is no fee for exercising your rights. However, if your request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on the request.

You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email we send you, or by contacting us at info@precision-play.co.uk.

10. Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making that produces legal effects or similarly significant effects on you.

The Service does involve profiling in a limited sense: we calculate training performance statistics (such as accuracy scores) and display leaderboard rankings based on your training activity. These are features of the Service that you choose to engage with and do not have legal or similarly significant effects.

11. Cookies and Tracking Technologies

We use cookies and similar technologies (such as web beacons and pixels) on our Service. These are used for essential functionality (such as authentication), performance monitoring, and analytics.

For comprehensive information about the cookies we use, why we use them, and how you can manage your preferences, please refer to our Cookie Policy at https://preflopdojo.com/cookie-policy.

You can control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Service.

12. Third-Party Links

The Service may contain links to third-party websites, platforms, and services (such as our Discord community, poker-related content, and payment processor pages). These third-party services have their own privacy policies, and we are not responsible for their data practices. We encourage you to review their privacy policies before providing any personal data to them.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Service. When we make changes, we will update the “Last Updated” date at the top of this policy.

Where changes are material, we will notify you by email or through a notice within the Service at least 30 days before the changes take effect. Your continued use of the Service after the revised policy takes effect constitutes your acceptance of the changes.

For changes required by law or regulation, the revised policy may take effect immediately.

14. Complaints

If you have any concerns about how we handle your personal data, we encourage you to contact us first at info@precision-play.co.uk so that we can address your concern.

You also have the right to lodge a complaint with the relevant supervisory authority. In the United Kingdom, this is:

Information Commissioner’s Office (ICO)

Website: www.ico.org.uk

Telephone: 0303 123 1113

If you are located in the European Union or European Economic Area, you may also lodge a complaint with the supervisory authority in your country of residence.

15. Contact Us

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your data protection rights, please contact us:

Email: info@precision-play.co.uk

Post: Precision Play Ltd, Crown House, 27 Old Gloucester Street, London, WC1N 3AX, England

We will endeavour to respond to all enquiries within 5 business days, and to all formal data protection requests within one month as required by law.