Privacy Policy

Last updated: July 2, 2025

Introduction

Welcome to Poker Skill, a product line of Funco, Inc. (“we” or “us”). This Privacy Policy explains how we collect, use, and protect your personal information when you use our services. Poker Skill is a poker learning platform - think of it like a “Duolingo for poker,” focused on education and skill-building, not gambling. We want to be very clear: Poker Skill is not a real-money gambling app. There are no cash wagers or prizes, and any poker gameplay elements are purely for learning purposes. We emphasize this distinction in line with app-store guidelines that require developers to clearly disclose the nature of their games. By using Poker Skill, you agree to the collection and use of information in accordance with this Privacy Policy and our Terms of Service.

Information We Collect

We only collect the information necessary to provide and improve our educational service. Here’s what we gather and why:

Account Information: If you create a Poker Skill account, we collect basic details like your username, email address, and a password. This lets you log in, save progress, and sync across devices. We do not require sensitive personal details like your physical address or government ID for using our app.
Profile Data (Optional): You may have the option to add a profile picture or display name. This is completely optional and only used to personalize your experience (for example, showing your name on a leaderboard if you participate in friendly challenges).
Age Confirmation: We may ask for your age or date of birth solely to ensure you meet our minimum age requirements (Poker Skill is intended for users 13 and older). We do not use this information for any other purpose, except to apply appropriate account restrictions for minors if necessary.
Learning and Usage Data: As you use Poker Skill, we collect information about your activity in the app. This includes quiz answers, lesson progress, scores, and other metrics related to your poker learning. We use this data to provide feedback (like telling you which topics you excel at or need to practice) and to improve the content (for instance, refining questions that many users get wrong).
Technical and Device Information: Like most apps, we automatically receive certain technical data when you use Poker Skill. This includes device type (e.g., iPhone, Android phone), operating-system version, unique device identifiers or installation ID, and IP address. We collect this to ensure compatibility with your device, maintain service quality, and for analytics (e.g., to see how many people use our app and on what devices). This data is collected in a way that does not directly identify you (it’s tied to an anonymous ID).
Cookies and Web Data: If you visit our website (for example, to read this policy or learn about Poker Skill), we may use cookies or similar technologies. Cookies help operate and secure the site (like keeping you logged in) and understand how visitors use our site. We do not use cookies for advertising. You can adjust your browser settings to refuse cookies, but some site features might not work properly without them.
Support Communications: If you contact us for help or feedback (via email or in-app support), we will receive whatever information you choose to provide. This might include your email address, details about your question, and any other context you give. We only use this information to assist you and improve our customer support.
No Financial or Gambling Data: Importantly, we do not collect any credit-card numbers, bank info, or gambling-related data. Poker Skill involves no real-money transactions or bets within the app, so we will never ask for payment details except when you choose to subscribe to premium educational content (and those payments are processed by the App Store or Google Play, not by us directly). Because our platform has no wagering, we also do not collect information like betting history or gambling losses/wins - there’s simply none of that in our service.

How We Use Your Information

We use the collected information to operate and enhance Poker Skill’s educational experience. Specifically:

Providing and Personalizing the Service: Your data allows us to run the core functionality of Poker Skill. For example, we use your account info to log you in and show your saved progress. We use your quiz and lesson performance to personalize your learning path - for instance, suggesting practice on topics where you got more questions wrong. All of this helps make your poker training more effective and fun.
App Improvement and Analytics: Usage and technical data help us understand how Poker Skill is used. We analyze this data (in aggregate form) to debug issues, improve app stability, and decide which new features or content to develop. For example, if many users struggle with a certain quiz question, we might clarify the explanation. If a lot of users use a particular feature, we know to invest in it further. We may use trusted third-party analytics tools (like Google Analytics or similar) to assist with these insights, but these tools only receive de-identified information (such as device IDs or usage events, not your name or contact info).
Communication with You: We may use your email address or in-app notifications to communicate important information, such as: account verification, password resets, updates to our terms or privacy policy, and announcements about new Poker Skill features or lessons. We might also send motivational reminders or tips (for example, a push notification to practice if you haven’t logged in for a while). You can opt out of non-essential communications: every marketing or newsletter email will have an “unsubscribe” link, and you can manage push-notification preferences in your device settings. We will not spam you - our goal is to send only useful and relevant updates about the Poker Skill learning experience.
Enforcing Terms and Lawful Use: We use data as needed to enforce our Terms of Service and to prevent misuse of Poker Skill. For instance, we might monitor for bots or cheating if it violates the rules of the platform. Also, if required by law or necessary to protect rights and safety, we may use or disclose information appropriately (for example, addressing fraud or security issues).
No Advertising Profiles: Poker Skill does not serve third-party ads based on your data. We are not in the business of selling or renting your information. We do not use your data to build advertising profiles, and you will not see targeted third-party advertisements on Poker Skill. The focus is purely on learning. In the future, we may promote our own new features or courses, but those would be directed to all users generally or based on your course progress, not based on invasive tracking. And rest assured, we won’t share your personal data with advertisers or other companies for their independent marketing use.

Protecting your privacy is important to us. We limit the sharing of your personal information and do so only in the following circumstances:

Service Providers: We employ trusted third-party companies to help us operate Poker Skill or provide services on our behalf. Examples include cloud-hosting providers (to store data securely), analytics services (to understand app performance), or email service providers (to send out verification or newsletter emails). These service providers only receive the information necessary for them to perform their functions, and they are contractually obligated to keep your data confidential and use it only for our specified purposes.
Legal Compliance and Safety: We may disclose information if required to do so by law or in a good-faith belief that such action is necessary to comply with applicable laws, regulations, or legal processes. For instance, if a valid subpoena or court order is issued, we might need to provide relevant data. Similarly, if we believe disclosure is necessary to investigate or protect against illegal activities, suspected fraud, or to enforce our Terms of Service or user agreements, we may share information with law enforcement or relevant authorities.
Business Transfers: If Poker Skill (or the company that operates it) is involved in a merger, acquisition, financing, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will ensure the new owner continues to honor the commitments we’ve made in this Privacy Policy. We will notify you (for example, via email or a prominent notice in the app) of any such change in ownership or control of your personal information.
With Your Consent: Aside from the cases above, we will not share your personal data without your consent. If in the future there is ever a reason to share information in a way that’s not covered by this Privacy Policy, we would first get your explicit consent. For example, if we introduce a feature to link your Poker Skill account with another service or platform, we would only share data if you opt-in to that integration.
No Selling of Personal Data: To reiterate, we do not sell your personal information to third parties. We also do not share data with any gambling companies or casinos. Poker Skill is an independent educational platform, and your data is used only to support your learning experience and our internal operations, as described above.

Data Storage and Security

We take security seriously and adopt industry-standard practices to protect your information. Personal data collected by Poker Skill is stored securely on servers managed by our hosting providers. We implement technical and organizational measures to safeguard against unauthorized access, alteration, disclosure, or destruction of your data. These measures include encryption of data in transit (e.g., using HTTPS for our app and website to prevent eavesdropping) and encryption of sensitive data at rest where appropriate. For example, passwords are never stored in plain text - they are hashed and salted for security.

Our team also restricts internal access to personal data: only authorized personnel who need to process your data (for example, support staff assisting you with an account issue) have access, and they are bound by confidentiality obligations. We regularly update our software and infrastructure to address security vulnerabilities and continuously monitor for potential threats.However, it’s important to note that no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You can help by keeping your account credentials confidential and notifying us immediately if you suspect any unauthorized access to your account.

Data Retention

We retain your personal information for as long as needed to provide you with the Poker Skill service and fulfill the purposes described in this policy. In practice, this means we will keep your account data and learning history while your account is active. Keeping this data allows you to return to Poker Skill and see your progress, past results, and continue learning seamlessly.

If you choose to delete your account or if your account remains inactive for an extended period, we will initiate deletion of your personal data. Specifically:

Account Deletion: You can request to delete your Poker Skill account at any time (through an in-app setting or by contacting support). Upon confirmation of such a request, we will delete or anonymize personal information associated with your account, including your profile details and learning history. Some data (like aggregated analytics that do not identify you personally) may be retained for our internal purposes, but this data will not be linked back to you.
Inactivity: If our systems detect that an account has been completely inactive for a very long period (e.g., a few years) and we have been unable to reach you, we may deactivate and eventually delete the account to free up space and in line with data-minimization principles. We will provide notice (e.g., an email warning) before deleting an inactive account, giving you the opportunity to keep it active if you wish.
Legal Obligations: In certain cases, we might need to retain information even after an account-deletion request, if required for legal reasons. For instance, if there’s an unresolved issue like a dispute or a legal claim, or if we are obligated by law to keep certain records for a specified time (such as payment-transaction logs for tax or accounting purposes), we will retain the necessary data for the required period. We only keep what is absolutely necessary and only for the duration required under the law.

After the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you.

Your Rights and Choices

We believe you should have control over your personal information. Depending on where you live, you may have certain legal rights regarding your data, and in all cases we provide ways for you to manage your information:

Access and Correction: You can access and update the personal information you provided to Poker Skill. For example, you can edit your profile details (like your email if it changes) in the app settings or website profile page. If any information we have is inaccurate, please update it or let us know and we’ll help correct it.
Data Portability: Where applicable laws provide, you may request a copy of your data in a common format. For instance, we can provide a summary of your learning progress or account information if you need it.
Deletion of Data: As mentioned in the Data Retention section, you have the right to delete your account and personal data. This can be done by request, and we will promptly honor such requests (after verifying that you are the account owner). Once deleted, your personal information will be removed or anonymized from our systems, except for data we may legally need to keep.
Objection to Processing: In certain jurisdictions (such as the EU), you have the right to object to or restrict our processing of your data. In practice, since we do not use your data for marketing without consent and only process data for providing the service, this would typically apply if you have concerns about any analytics or personalization. We will consider and respect such requests as required by law. For example, you might ask us to stop using some of your data for analytics - if so, we can opt you out of non-essential data collection.
Opt-Out of Communications: You can choose not to receive promotional communications from us. As noted earlier, every promotional email will have an unsubscribe option. Push notifications can be turned off at the device level. Service-related messages (like critical account or policy updates) are infrequent and may be necessary for us to send, but we try to keep those to a minimum.
California Privacy Rights (CCPA/CPRA): If you are a California resident, state law provides you with specific rights. These include the right to know what personal information we collect, the right to request deletion of your personal information, and the right not to be discriminated against for exercising your privacy rights. Poker Skill does not sell personal information (as “sell” is defined under California law), so the opt-out of sale is not applicable. If you have any questions or requests related to your California privacy rights, you can contact us and we will respond in accordance with applicable law.
International Users (GDPR and others): If you are in the European Economic Area, United Kingdom, or other regions with privacy laws (like GDPR), you are entitled to certain rights as described above (access, rectification, deletion, etc.), and also the right to lodge a complaint with your local data-protection authority if you believe we have infringed your privacy rights. We will always do our best to resolve any concerns directly and comply with applicable data-protection laws.

To exercise any of your rights or make inquiries about your data, please reach out to us via the contact information provided at the end of this policy. We may need to verify your identity before fulfilling certain requests (for example, to ensure that someone else isn’t trying to delete your account). We will respond to your request within a reasonable timeframe and in accordance with the law.

Children’s Privacy

Poker Skill is not intended for children under 13 years of age, and we do not knowingly collect personal information from anyone under 13. Our services and content are designed for a general audience interested in learning poker strategy, and we expect users to be at least 13 (and in many regions, users between 13 and 18 should have a parent or guardian’s consent to use the app, per our Terms of Service). If you are under 13, please do not use Poker Skill or submit any information about yourself to us.

In compliance with the U.S. Children’s Online Privacy Protection Act (COPPA) and similar laws, if we become aware that we have inadvertently collected personal data from a child under 13, we will take immediate steps to delete that information from our servers. If you are a parent or guardian and discover that your child under 13 has created an account on Poker Skill or provided us with personal information, please contact us right away so we can remove the data and terminate the child’s account.

For users who are minors (e.g., under 18) but older than 13: We encourage parents and guardians to be involved in their teenagers’ online learning. While we do not collect any sensitive information about age beyond ensuring users are 13 or older, if a parent wishes to review or delete a minor’s account data, we will facilitate that in accordance with applicable laws. Our platform’s content is educational and contains no gambling or real betting, so it is generally suitable for teens, but parental guidance is always welcome to ensure the experience aligns with the family’s values and the teen’s maturity level.

International Data Transfers

Poker Skill is accessible to users around the world. We primarily operate our servers and business from the United States, which means the information we collect from you will likely be transferred to and processed in that country. While data-protection laws vary by country, we take steps to ensure that your privacy is protected consistent with this policy wherever your data is processed.

If you are located outside of the country where we process data (for example, outside the U.S.), be aware that we may transfer your information to a jurisdiction that may not have the same data-protection laws as your home country. In such cases, we rely on legal mechanisms to ensure the transfer is lawful, such as standard contractual clauses or your consent where required. We handle all data in accordance with this Privacy Policy, which provides a high level of privacy protection. By using Poker Skill, you acknowledge the transfer of your personal data to our facilities and to the servers of our service providers (which may be located in the U.S. or other countries).

If required by your local law, we will ask for your consent to the international transfer of your data, or implement other measures to legitimize the transfer. We are committed to protecting the privacy and integrity of personal information no matter where it is stored.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will notify you by updating the “Last Updated” date at the top of this policy. For significant changes, we may provide a more prominent notice (such as a notice on our website or an in-app alert, and/or email notification). We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Your continued use of Poker Skill after any update to this Privacy Policy will signify your acceptance of the changes. If you do not agree to the revised policy, you should stop using the app and may delete your account at any time.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact us. We are here to help and value your privacy. You can reach us at:

Poker Skill Support Team Email: support@pokerskill.com

Mailing Address: Funco, Inc. 504 W 7th St, Suite 200 Austin, TX 78701 USA

We will do our best to respond promptly to your inquiry and address any issues. Thank you for trusting Poker Skill with your poker learning journey. We are committed to keeping your information safe and your experience enjoyable. Remember, Poker Skill is about having fun and improving your skills - never about gambling. Enjoy learning, and play responsibly in real life!