Privacy Policy

1. Controller

The controller responsible for the processing of personal data in connection with Poker Mentor is:

Arno Kompatscher
Germany
Email: team@pokermentor.ai

Poker Mentor is currently operated by the individual named above. If the legal structure of the service changes in the future, this Privacy Policy will be updated accordingly.

2. Scope of this Privacy Policy

This Privacy Policy applies to the Poker Mentor website and application, including in particular:

• pokermentor.ai / www.pokermentor.ai
• app.pokermentor.ai
• the associated Poker Mentor backend services.

live.pokermentor.ai is a legacy address that redirects to the current Poker Mentor application; it is not a separate application.

This Privacy Policy explains what personal data we process, why we process it, how long it is retained, which categories of service providers may receive it, and which rights users have under the General Data Protection Regulation ("GDPR").

3. Data processed when visiting the website

When you visit our website, certain technical information may automatically be processed in order to provide the website securely and reliably.

This may include:

• IP address
• date and time of access
• browser type and version
• operating system and device information
• requested pages or resources
• technical connection information
• error and security information.

We use external hosting, frontend and technical infrastructure providers to operate and secure the website.

These infrastructure providers are not used as the primary database for Poker Mentor user accounts, conversations or coaching history. However, they may process technical connection and log data as necessary to deliver and secure the website.

The legal basis for this processing is Art. 6(1)(f) GDPR. Our legitimate interest is providing a secure, stable and technically functional website.

4. Creating and using a Poker Mentor account

When you create and use a Poker Mentor account, we may process information including:

• email address
• name
• poker experience level
• stakes and/or game type
• goals
• preferences
• preferred language
• other information voluntarily entered into your profile.

This information is used to create and maintain your account and to personalize the Poker Mentor experience.

The legal basis is Art. 6(1)(b) GDPR, as the processing is necessary to provide the service requested by the user.

Guest use before permanent account creation

Poker Mentor can be used initially through an anonymous guest account before an email/password account is created. During guest use, we may process:

• an anonymous technical account identifier,
• onboarding and profile answers,
• guest conversations and messages,
• usage state necessary to enforce guest limits,
• pseudonymized/scrambled network information used for rate limiting and abuse prevention.

When a guest chooses to create a permanent account, the same account, profile and conversation may be associated with the confirmed email account so that the conversation can continue.

The legal basis for processing necessary to provide the guest experience is Art. 6(1)(b) GDPR; rate limiting and abuse prevention are based on Art. 6(1)(f) GDPR.

5. Conversations and coaching data

When using Poker Mentor, we may process information that you provide during your interactions with the service.

This may include:

• chat messages
• poker hands or situations described by the user
• strategic questions
• personal reflections
• goals and performance-related information
• session summaries
• coaching-related tags
• contextual information and memory derived from previous sessions
• feedback provided by the user.

This information is processed in order to:

• provide personalized coaching,
• understand the context of a user's questions,
• maintain continuity between sessions,
• generate summaries,
• remember relevant goals and previous discussions,
• provide conversation history,
• improve the usefulness of future coaching interactions.

The legal basis for processing necessary to provide these features is Art. 6(1)(b) GDPR.

6. Live Sessions and voice processing

Poker Mentor offers Live Session functionality that allows users to interact with the service by voice during a poker session.

Depending on how the feature is used, the following information may be processed:

• spoken input,
• audio streams necessary for real-time processing,
• transcripts generated from spoken input,
• responses generated by the coaching system,
• session context,
• session summaries and derived coaching information.

Audio and/or transcripts may be transmitted to an external AI processing provider where this is technically necessary to provide speech recognition, real-time interaction or coaching responses.

The legal basis is Art. 6(1)(b) GDPR.

7. Application database and storage

Poker Mentor uses an external cloud application and database provider to store and process application data.

Depending on the features used, this may include:

• account information,
• profile information,
• conversations,
• messages,
• conversation summaries,
• coaching tags,
• user memory,
• Live Session transcripts,
• debrief information,
• technical session data.

The provider processes these data on our behalf for the purpose of operating the Poker Mentor application.

The legal basis is primarily Art. 6(1)(b) GDPR.

Where processing is necessary for system security, troubleshooting, fraud prevention or protection against misuse, the legal basis may also be Art. 6(1)(f) GDPR.

8. Artificial intelligence processing

Poker Mentor uses external artificial intelligence processing services to provide features.

Only information that is necessary for the respective functionality is transmitted for processing.

External AI service providers process such information on our behalf for the purpose of providing the requested functionality.

We do not sell conversation content to AI providers or other third parties, and we do not provide user conversations to advertisers.

Data submitted through the AI services currently used by Poker Mentor is not used by those providers to train their general-purpose AI models.

Depending on the technical configuration of the respective service, limited temporary processing or retention may occur for security, fraud prevention or abuse monitoring.

The legal basis for processing necessary to provide Poker Mentor's AI functionality is Art. 6(1)(b) GDPR.

9. Internal improvement of Poker Mentor

We may internally analyze information generated through the use of Poker Mentor in order to improve the service.

Where reasonably possible, data used for these purposes is analyzed in pseudonymized or aggregated form.

We do not sell personal data or use personal conversations for third-party advertising.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is improving, developing and securing Poker Mentor.

Where processing is based on legitimate interests, users have the right to object in accordance with Art. 21 GDPR.

This section refers to the internal improvement of Poker Mentor. If we materially change how user data is used — for example, by introducing a separate machine-learning training program using identifiable user content — we will reassess the legal basis and update this Privacy Policy before doing so.

10. Communications

If you contact us by email or through another communication channel, we process the information you provide in order to respond to your request.

This may include:

• email address,
• name,
• content of the communication,
• related account or technical information.

Where the communication concerns the use of Poker Mentor, the legal basis is Art. 6(1)(b) GDPR.

For general inquiries, security matters or other communications, the legal basis may be Art. 6(1)(f) GDPR.

We distinguish between account, authentication, security and service communications (which are necessary to operate Poker Mentor) and voluntary marketing/lifecycle communications (which are sent only with consent, as described in the following sections).

11. Optional Poker Mentor email package

Poker Mentor offers an optional email package. It includes:

• the 30-day Welcome Mindset Package,
• poker mindset tips and reminders,
• Monthly Report emails and report-related email reminders,
• occasional Poker Mentor product updates.

These optional communications are sent only on the basis of the user's email choice (consent). The legal basis is Art. 6(1)(a) GDPR — consent.

If a player does not choose the optional email package, they do not receive these optional email communications. Declining affects only the delivery of these emails and email reminders; it does not by itself remove access to features available inside the application, such as Monthly Reports where they are accessible in the app.

Consent is voluntary. Creating or using a Poker Mentor account does not require consent to the optional email package. Consent can be withdrawn at any time; every optional email provides an unsubscribe mechanism. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Necessary authentication, account, password and security emails are separate from the optional email package and are sent regardless of this choice where required to provide the service.

To deliver optional emails at appropriate local times, Poker Mentor may store the timezone reported by the user's browser, such as an IANA timezone identifier (for example "Europe/Berlin"). This timezone is obtained from the browser/device configuration. Poker Mentor does not collect GPS or precise physical location for this purpose.

12. Consent records

Poker Mentor may retain records necessary to demonstrate and respect the user's email choice, such as:

• consent/decline timestamp,
• consent version and source,
• confirmation timestamp,
• unsubscribe/suppression status.

Such records are used to demonstrate consent and to ensure that an unsubscribe is respected.

13. Email delivery provider

Poker Mentor uses Twilio SendGrid as an email delivery service provider for the optional email package and related email delivery.

Data processed by the email delivery provider may include:

• email address,
• name where used in the email,
• email content and template identifiers,
• delivery status,
• bounce, spam report and unsubscribe information.

Tracking of optional emails is limited to operational delivery information (delivery, bounce, spam report, unsubscribe). Open and click tracking is disabled; we do not track whether these emails are opened or which links are clicked.

14. Cookies, local storage and similar technologies

Poker Mentor may use cookies, browser storage and similar technologies where necessary to operate the website and application.

These technologies may be used for purposes including:

• authentication,
• maintaining a logged-in session,
• security,
• remembering technically necessary application state,
• maintaining functionality between page loads.

Under German law, consent is not required where accessing or storing information on a user's device is strictly necessary to provide a digital service expressly requested by the user.

Poker Mentor's backend remembers your analytics preference using an essential, secure cookie that is accessible only to the backend. The website and application check the same preference in the same browser, so an applicable acceptance or decline does not require a second prompt. The cookie lasts up to 210 days; a decision applies for 180 days. The preference record includes the decision, separate analytics permissions, version, revision and timestamps. Unknown orphan preferences older than one day and decisions expired for more than 30 days are eligible for bounded cleanup; removal may occur later because cleanup runs in batches.

Optional analytics (only with your consent)

On pokermentor.ai we use the following non-essential analytics only with the corresponding permission verified by our backend following your explicit choice. "Accept" grants both purposes; "Decline" rejects both. Existing applicable choices can be reused between the website and application. If verification fails, optional analytics remain off and you can still use the website and application. Without permission, no analytics script is loaded and no analytics identifier is created or stored. The legal basis is your consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG).

Google Analytics 4 (Google Ireland Limited; data may also be processed by Google LLC in the United States) measures page views and clicks on trial buttons, using Google Analytics cookies. Advertising storage and ad personalization signals are disabled.

First-party acquisition measurement helps us understand which partner links and campaigns lead to visits, trial starts and completed sign-ups. After consent, your browser generates a random visitor identifier and receives a random, opaque attribution token from Poker Mentor's own backend. The token expires 30 days after it is created. If you arrived through a partner link (for example pokermentor.ai/?ref=partner-name), the partner code is checked against our list of active links. We record when a page is entered and when a trial button is clicked. No email address, name, IP address, device fingerprint, page content or poker information is included in these events.

When you click a trial button after consenting, the attribution token is passed to app.pokermentor.ai in the link so that a later sign-up can be associated with the campaign. The token is not shared with Google Analytics or other third parties and is not included in emails. If you do not consent, trial buttons link to the app without any token. A public partner code may remain in the link while a choice is pending; this code is not proof of consent and does not itself authorize tracking.

Raw acquisition events are generally deleted after about 90 days; anonymous daily totals and the association needed to avoid double counting a registration may be kept for up to 24 months. Deletion runs in batches, so it may occur somewhat later.

You can withdraw your consent at any time via "Cookie settings" in the website footer. Withdrawal stops Google Analytics and acquisition measurement, deletes the locally stored identifier and token, and asks our backend to delete the attribution sessions linked to that shared preference and their raw events. The withdrawn choice is remembered and no new prompt is shown automatically. Already credited registrations and anonymous aggregate history are retained. Other open pages recheck the preference when they regain focus. If withdrawal cannot reach the backend, optional collection stops locally immediately, but server-side withdrawal takes effect only once the request succeeds.

15. Categories of recipients

We may disclose or make personal data accessible to the following categories of recipients where necessary:

• website hosting and frontend infrastructure providers,
• cloud application and database providers,
• artificial intelligence processing providers,
• email and communication service providers,
• IT and security service providers,
• professional advisers where necessary,
• public authorities where disclosure is legally required.

Service providers that process personal data on our behalf are used only where appropriate contractual and data protection safeguards are in place.

We do not sell users' personal data.

We do not disclose personal data to third parties for their independent advertising purposes.

The GDPR expressly permits privacy information to describe recipients by category rather than necessarily listing every service provider by name.

16. International data transfers

Some technical service providers used by Poker Mentor — including our email delivery provider and, with your consent, Google Analytics — may process personal data outside Germany or outside the European Economic Area ("EEA"), including in the United States.

Where personal data is transferred outside the EEA, such transfers are carried out in accordance with Chapter V of the GDPR.

Depending on the recipient, appropriate safeguards may include:

• an adequacy decision by the European Commission,
• participation in the EU-U.S. Data Privacy Framework where applicable,
• Standard Contractual Clauses approved by the European Commission,
• other safeguards permitted under the GDPR.

Information about the applicable safeguards may be requested using the contact details provided in this Privacy Policy.

17. Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected.

Account, profile, conversation and coaching information is generally stored while the user's Poker Mentor account remains active and while it is required to provide history, memory and personalized coaching functionality.

Where a user requests deletion of their account, the associated personal data will be deleted or anonymized unless continued retention is:

• required by law,
• necessary to establish, exercise or defend legal claims,
• required for security or fraud-prevention purposes.

Technical backup copies may temporarily continue to contain deleted information until they are overwritten as part of the regular backup cycle.

Technical logs are retained only for the period necessary for system operation, security and troubleshooting.

Marketing subscription data is retained while needed to send the requested emails. Consent evidence may be retained as needed to demonstrate compliance, and unsubscribe/suppression information may be retained as necessary to ensure the user is not contacted again.

18. Special categories of personal data

Poker Mentor is designed as a poker coaching and performance service.

It is not intended for the processing of medical records, health information or other special categories of personal data under Art. 9 GDPR.

Users are therefore asked not to provide unnecessary highly sensitive personal information.

If such information is voluntarily included in a user's conversation, it may technically become part of the conversation being processed. Users should therefore consider carefully which personal information they choose to provide.

19. Automated decision-making

Poker Mentor uses artificial intelligence to provide coaching, analysis, feedback and recommendations.

However, Poker Mentor does not make solely automated decisions that produce legal effects concerning users or similarly significantly affect them within the meaning of Art. 22 GDPR.

20. Data security

We take appropriate technical and organizational measures designed to protect personal data against:

• unauthorized access,
• loss,
• alteration,
• unauthorized disclosure,
• destruction.

Access to application data is restricted according to technical and operational requirements.

However, no internet-based service can guarantee absolute security.

21. Your rights

Under the GDPR, you may have the right to:

• obtain information about whether we process your personal data,
• access your personal data,
• request correction of inaccurate data,
• request deletion of your data,
• request restriction of processing,
• object to processing based on legitimate interests,
• receive certain personal data in a portable format,
• withdraw consent at any time where processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

You also have the right to lodge a complaint with a competent data protection supervisory authority.

Requests regarding personal data can be sent to: team@pokermentor.ai

22. Supervisory authority

For private-sector controllers established in Bavaria, the competent supervisory authority is generally:

Bavarian State Office for Data Protection Supervision
(Bayerisches Landesamt für Datenschutzaufsicht – BayLDA)
Promenade 18
91522 Ansbach
Germany

The BayLDA is responsible for supervising private companies, self-employed persons and other non-public entities in Bavaria.

23. Changes to this Privacy Policy

Poker Mentor is an evolving service.

We may update this Privacy Policy if:

• features are added or changed,
• the technical infrastructure changes,
• new categories of service providers are introduced,
• our legal structure changes,
• applicable legal requirements change.

The current version will always be available through the Poker Mentor website.

Last updated: 22.10.2026