Poker Trainer: privacy and terms of use

Poker Trainer has no account and no server of its own. The lessons ship inside the app, and your progress stays on your phone. What leaves it is a set of usage statistics, a crash report when something breaks, your total XP for the ranking only if you sign in to Google Play Games, the questions the app asks Google Play about the unlimited lives purchase, and what Google AdMob needs when you choose to watch a video for a life.

I, Tiago Danin, am the developer and the controller of this data under the LGPD (Lei 13.709/2018). If you are in the EU, the GDPR gives you the same rights and I answer them the same way. Write to TiagoDanin@outlook.com about any of it.

What stays on your phone

The app saves your progress: which lessons you finished, your best accuracy and number of attempts on each, your XP, chips, lives and streak, the days you played, the lesson you left halfway, whether you bought unlimited lives, and counters of answers and of the kinds of mistakes you make, which feed the tips at the end of a lesson. That is what lets you pick up where you stopped. The app also counts how many times you have opened it, up to the 11th time, for the rating request described below. That number stays on the phone.

Uninstalling the app, or clearing its data in Android settings, erases all of it.

What the app sends

Google Analytics for Firebase records how the app is used: lessons started, finished or left halfway (with the lesson, its phase and a rough accuracy), each answer (the lesson, the kind of exercise and whether it was right), running out of lives, opening an exercise's extra notes, the tips shown at the end of a lesson, finishing a phase, streak milestones, chips earned and spent, free practice, opening the ranking or sending a score to it, seeing the unlimited lives offer, the outcome of a purchase (bought, cancelled, pending or failed) and of a "Restore purchase", and starting a video for a life and whether it ended with the life. It also records the intro card of a lesson, resuming a lesson you left halfway, runs of 5, 10 or 20 right answers, the out of lives screen and what you chose there (with a rough range of the chips you were missing), the streak at risk banner and a streak that went back to zero, phases opened or closed on the path, taps on locked lessons and on the hand rankings, the end of a practice session, when the store could not return the purchase offer, your answer to the ad consent form, and when a rating card was requested. When you come back to the app, it records the time since your last lesson in ranges of days, your streak and the phase you are in. Each statistic is tagged with your current phase, ranges of your streak and of the lessons you finished, whether you own unlimited lives, the language and version of the lessons and whether the consent form allows ads. Like any app using the SDK, it also records automatic events such as the first open, each session and the screens you visit, together with an ID for this installation, the device model, operating system, app version and approximate location. On Android the SDK may read the install referrer (how you got to the app on Google Play). Because the app now has ads, the SDK may also read the device's advertising ID. The app does not send a user ID, because it has none, and does not use these statistics for advertising.

When the app crashes or hits an error, Firebase Crashlytics sends a crash report: the technical trace of the error, the device model, operating system, app version and an ID that Crashlytics creates for this installation. The report carries no user ID and nothing about your answers. Development builds of the app send none.

Lessons work offline. The statistics and reports wait and go out when there is a connection.

Google Play Games ranking

On Android the app can show a ranking of players. It uses Google Play Games, which signs you in with the Play Games profile already on the phone. When you are signed in, your total XP goes to a Play Games leaderboard, where other players see it next to your Play Games name and avatar. Google runs that profile and that leaderboard under its own terms, and you can hide or delete your Play Games activity in the Play Games app. If you never sign in, nothing goes there and the app works the same.

Unlimited lives purchase

Unlimited lives is a one-time purchase made through Google Play. Google Play handles the payment: I never see your card or your payment details. The app asks Google Play for the price, and whether your Google account has bought unlimited lives when you buy, when you tap "Restore purchase" and quietly when the app starts, so a purchase made on another phone is picked up. Google shares with me, through the Play Console, the order information it gives every developer, such as the order number, date, country and amount. If you never buy, nothing about a purchase is recorded.

Ads

When you run out of lives, the app can offer a short video that gives you one life back. It only plays if you tap it, it is never shown to someone who bought unlimited lives, and there are no banners and no ads that appear on their own. Google AdMob serves the video. To pick and measure ads, AdMob uses the advertising ID, your IP address, the device model and how you interact with the ad, and it may show ads based on your interests.

Where the law asks for consent, such as in the EU and the UK, the app shows Google's consent form before any ad loads, and you can change your answer later through "Ad privacy" on the out of lives screen. You can also reset or delete the advertising ID in Android settings, under Privacy, Ads (on some phones, Google, Ads). Deleting it stops personalised ads on the whole device.

Rating request

On the 3rd, 5th and 10th time you open the app, it may ask Google Play to show its rating card. Google Play decides whether the card appears. Your stars and any review go to Google Play under its own terms, and the app never learns whether you rated it or what you wrote.

Who else receives it

Google, which runs Firebase and processes this data on my behalf, on servers that may be outside Brazil, including in the United States. Google Play also processes the unlimited lives payment and tells the app whether you own it, and Google AdMob receives what it needs to show the videos you ask for and to record your consent choice. Their terms: Firebase privacy, Google Play terms and Google Privacy Policy.

I do not sell this data or hand it to a data broker, and the statistics are not shared with advertisers. The statistics and crash reports are used to find bugs and to see which lessons are too hard or too easy, on the basis of my legitimate interest in keeping the app working and improving it. The videos rely on your consent where the law requires it, and otherwise on my legitimate interest and on the choices you make in Android's ad settings. Purchase data is used to deliver the unlimited lives you paid for, which is the performance of that contract, and order records are kept as tax law requires. The statistics and crash reports are kept for the retention period configured in Firebase, after which Google deletes them. AdMob and Google Play keep their data under Google's own policies.

Your rights

Since the statistics and crash reports carry no name or account, I usually cannot tell which ones are yours. Resetting the advertising ID and uninstalling the app cut the link between new data and your device. You can still ask me what exists, ask me to delete it, or object to it, at TiagoDanin@outlook.com. You may also complain to the ANPD, Brazil's data protection authority.

Children

The app teaches a card game and is meant for adults. I do not knowingly collect data from children under 13. If you believe a child's data reached me, write to me and I delete what I can find.

Changes

If this policy changes, the date at the top changes with it. A change in what is collected is described here before the version that makes it is published.

Contact

Tiago Danin, TiagoDanin@outlook.com.

These terms apply to anyone who installs or uses Poker Trainer on Android or iOS. Using the app means you accept them. If you do not, uninstall it.

Who provides the app

Tiago Danin, a private individual in Brazil, who develops and publishes Poker Trainer. "I" and "me" below mean him.

What it is

A trainer for No Limit Hold'em poker: short lessons grouped in phases, each one a series of practice hands and questions with an explanation after every answer.

There is no real money in the game. You cannot bet, deposit, win or withdraw anything. Chips, XP, lives and streaks are game scores with no value outside the app. Chips and XP cannot be bought, and nothing in the app can be exchanged for money.

The lessons teach common strategy. They are not financial advice and do not promise that you will win at a real table, where luck plays a large part in every hand. If you play for money, follow the law where you live, only play what you can afford to lose and stop when it stops being fun.

Price

Poker Trainer is free to download and use. Every lesson is free. When you run out of lives you may choose to watch a short video ad to get one life back; it never plays on its own and is never offered with unlimited lives. The ads are served by Google AdMob, as the privacy policy describes.

Unlimited lives is an optional one-time purchase sold through Google Play, with the price shown by Google Play before you pay. With it, a wrong answer in a lesson no longer costs a life; lessons, chips, XP and streaks work the same. It is tied to the Google account that bought it: on another phone with the same account, "Restore purchase" in the app turns it back on. Payment, receipts and refunds follow Google Play's terms and refund policy, without prejudice to your rights under the Código de Defesa do Consumidor.

What you may do with it

I give you a personal, free, non-exclusive and revocable licence to use Poker Trainer on your devices. You may not resell or redistribute it, or copy its lessons to publish elsewhere. The name, the icon, the design and the lesson content are mine.

Liability

The app is provided as it is. Your progress lives only on your phone, so uninstalling the app, clearing its data or losing the phone loses it too. To the extent Brazilian law allows, I am not liable for lost progress, for a mistake in a lesson, or for losses at a real poker game. Nothing here removes a right that the law gives you and that a contract cannot take away, such as those in the Código de Defesa do Consumidor.

Changes

I may update these terms. The date at the top changes when I do.

Law

Brazilian law governs these terms. Anything an email cannot settle goes to the courts of Belém, Pará, without prejudice to your right as a consumer to sue where you live.

Contact

Tiago Danin, TiagoDanin@outlook.com.