Privacy Policy

Latest updates: 24 June 2025

Introduction

This Privacy Policy should be read in conjunction with our Terms and Conditions and Player Wellness Statement to understand our complete compliance framework.

We respect your privacy and protect your personal information. This policy explains how we collect, use, and safeguard your data when you use FlopHero.

Flophero US LLC ("we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website at https://flophero.com and our analysis software platform (the "Service").

By using our Service, you consent to the data practices described in this Privacy Policy.

Information We Collect

We collect information you provide (like your email), usage data (how you use our platform), and technical information (like your IP address).

We may collect the following types of personal information:

  • Name and email address
  • Username and password
  • Payment information (processed by third-party providers)
  • Communication preferences
  • Hand histories and data you upload
  • Analysis results and study sessions
  • Feature usage and interaction patterns
  • Time spent on different sections of our Service
  • IP address and device information
  • Browser type and version
  • Operating system and device identifiers
  • Cookies and similar tracking technologies

We may receive information from:

  • Payment processors (Stripe, PayPal)
  • Analytics providers (Google Analytics)
  • Customer support platforms (Zoho)
  • Social media platforms (if you choose to connect)

How We Use Your Information

We use your information to provide our service, communicate with you, improve our platform, and comply with legal requirements.

We use your information for the following purposes:

Service Provision

  • Providing and maintaining our poker analysis platform
  • Processing your hand histories and generating analysis
  • Personalizing your learning experience
  • Managing your account and subscription

Communication

  • Sending service-related notifications
  • Responding to your inquiries and support requests
  • Providing updates about new features or changes
  • Marketing communications (with your consent)

Improvement and Analytics

  • Analyzing usage patterns to improve our Service
  • Developing new features and functionality
  • Conducting research and analytics
  • Ensuring security and preventing fraud

Flop Hero does not rely on solely automated decision-making that produces legal or similarly significant effects on users.

Legal Compliance

  • Complying with applicable laws and regulations
  • Protecting our rights and interests
  • Responding to legal requests and preventing harm

Information Sharing and Disclosure

We don't sell your information. We only share it with trusted service providers and when required by law.

We may share information with trusted third-party service providers who assist us in operating our Service.

We may disclose your information when required by law or to:

  • Comply with legal obligations
  • Protect our rights and property
  • Prevent fraud or security threats
  • Protect the safety of our users

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.

Data Retention

We keep your data only as long as necessary. You can request deletion at any time.

We retain your information for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy. You may request earlier deletion of your data by contacting us at privacy@flophero.com.

Your Rights and Choices

You can access, correct, delete, or export your data. You can also control marketing communications and cookies.

You have the right to:

  • Access your personal information
  • Correct inaccurate information
  • Delete your personal information
  • Export your data in a portable format
  • Restrict processing of your information
  • Object to certain uses of your information

Communication Preferences

You can:

  • Opt out of marketing emails using the unsubscribe link
  • Contact us to modify your preferences

Cookies and Tracking

You can:

  • Control cookies through your browser settings
  • Opt out of analytics tracking
  • Disable non-essential cookies through our cookie banner

International Data Transfers

Our servers are in Ireland. We use appropriate safeguards for international data transfers.

Our Service is hosted on Amazon Web Services in Ireland. If you are located outside Ireland, your information may be transferred to and processed in Ireland and other countries where our service providers operate.

We ensure appropriate safeguards are in place for international transfers:

  • EU Standard Contractual Clauses (SCCs) - We use the 2021 SCCs Modules 1 & 2 for transfers from the EU
  • UK International Data Transfer Agreement (IDTA) for transfers from the UK
  • Adequacy decisions where applicable
  • Other appropriate safeguards as required by law

Security Measures

We use industry-standard security measures to protect your information.

We implement appropriate technical and organizational measures to protect your information:

  • Encryption in transit and at rest
  • Secure authentication and access controls
  • Regular security assessments and updates
  • Intrusion detection and monitoring
  • Employee training on data protection
  • Access controls and need-to-know basis
  • Incident response procedures
  • Regular policy reviews and updates

Children's Privacy

Our service requires users to meet local age laws. We don't knowingly collect information from those who don't meet these requirements.

Age Declaration

You confirm that you are 18 years of age or older (21+ where required by local law) and represent that you meet local age laws in your jurisdiction for accessing educational poker content. We do not knowingly collect personal information from individuals who do not meet these requirements. If we become aware that we have collected information from someone who does not meet local age requirements, we will take steps to delete such information promptly.

Automated Decision-Making

We do not use automated decision-making with legal or similarly significant effects. Any automated systems are for basic functionality only.

We do not engage in automated decision-making with legal or similarly significant effects on users. Any automated processing we use is limited to:

  • Basic fraud detection and prevention
  • Personalized content recommendations
  • Account security measures
  • Technical functionality and user experience optimization

These automated processes do not have legal or similarly significant effects on users. You have the right to request human review of any automated decisions that may affect you.

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Your Rights

  • Right to Know: Request information about the personal information we collect, use, and disclose
  • Right to Delete: Request deletion of your personal information
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Opt-Out: Opt out of the sale or sharing of personal information (we do not sell information)
  • Right to Limit: Limit the use of sensitive personal information
  • Right to Non-Discrimination: Not be discriminated against for exercising your rights

How to Exercise Your Rights

To exercise your California privacy rights, contact us at:

We will verify your identity before processing your request and respond within 45 days.

Sensitive Personal Information

We may collect sensitive personal information such as payment information. We use this information only for providing our Service and as permitted by law.

European Privacy Rights (GDPR)

EU residents have comprehensive privacy rights under GDPR, including access, rectification, erasure, and data portability.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

Legal Basis for Processing

We process your information based on:

  • Contract: To provide our Service and fulfill our obligations
  • Legitimate Interest: To improve our Service and communicate with you
  • Consent: For marketing communications and optional features
  • Legal Obligation: To comply with applicable laws

Your Rights

  • Right of access to your personal data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Rights related to automated decision-making

Data Protection Contact

For GDPR-related inquiries, contact our Privacy Point-of-Contact:

  • Name: Noorul Ilahi
  • Email: privacy@flophero.com
  • Phone: Contact via email only
  • Response Time: Within 30 days

Data Protection Officer

We are presently below the GDPR thresholds that trigger a mandatory Data Protection Officer (Article 37). We maintain a Privacy Manager structure to ensure comprehensive data protection compliance. Any future DPO appointment will be announced in Q3 2025 if business growth requires it.

Changes to This Privacy Policy

We may update this policy and will notify you of material changes.

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

  • Posting the updated policy on our website
  • Sending an email notification to your registered email address
  • Providing notice through our Service

Your continued use of our Service after the effective date of the updated Privacy Policy constitutes acceptance of the changes.

Contact Information

Contact privacy@flophero.com for privacy questions, hello@flophero.com for general inquiries or legal@flophero.com for legal inquiries.

This Privacy Policy is effective and will be updated in due course.