You play online poker and want to know what PokerImprove sees about you
Notice under Article 14 GDPR ยท last updated: 12/10/2026
PokerImprove is a program that some players use to study the hands they have played. Poker rooms give every player the history of the hands they took part in: that history shows the nicknames of the other players at the table and their actions. If you have played against a PokerImprove user, their program has seen your nickname just as they see it at the table.
What we keep on our servers
For each user, your nickname and some aggregate counters about the way you play (for example how many times you raised before the flop out of how many opportunities), plus any private notes that user has written — short text, at most 400 characters, which our Terms forbid using for data about health, opinions or private life, or to identify you beyond your nickname. Outside the cases described below we do not keep complete hands, your name or your email address.
Who sees them
Only the user who played against you. We do not combine the data collected by different users, we do not publish them and we do not sell them. The data are deleted together with that user's account. For technical management only, they are processed on our behalf by the provider that hosts our servers (Supabase, a Singapore company, which relies on infrastructure from Amazon Web Services; the data are stored in Germany. Access from Singapore is covered by the standard contractual clauses, access from the United States by Amazon Web Services' Data Privacy Framework certification). There are then two cases in which your nickname also passes through other providers, and they are explained below.
Artificial intelligence analysis
The first case. PokerImprove offers a feature that, at the user's request, has a single hand commented on by an artificial intelligence model. At that moment the text of that hand โ cards, actions, amounts and the nicknames of the players at the table, so yours too if you were in that hand โ is sent from our servers in Germany to a language model provider (currently OpenAI), which processes it in the United States.
Under its contract, the provider does not use these data to train its models and keeps them for at most 30 days for abuse monitoring only; the transfer outside the European Union takes place on the basis of the standard contractual clauses approved by the European Commission, a copy of which you can obtain by writing to the address given at the bottom of this page. It happens only for the hands that a user chooses to have analysed, not for all those they have played.
The second case: support
When a user asks us for help because the program cannot read a room's hands, they can send us by email the hand history files just as the room delivered them: those files contain the complete hands, and with them your nickname if you were at the table. We use them only to adapt the program to that room and delete them within 90 days; they do not enter the archive we use to test the program. Support messages travel through the Resend and Cloudflare email services (United States) and arrive in our mailbox.
The same applies, more rarely, to the technical logs that a user can attach to a report: they may contain a nickname inside a file name, they stay on our servers and are deleted after 30 days.
Why it is lawful
We process these data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in offering a tool for studying one's own game, with pseudonymous, aggregated and private data; we have weighed this interest against your rights and freedoms and concluded that they do not override it; the assessment is available on request. We cannot inform you personally because we only know your nickname: this page is how we do it (Art. 14(5)(b) GDPR).
In the language of the law, the counters are profiling of the way you play (Art. 4(4) GDPR): they describe tendencies, not people. No automated decision producing legal or similarly significant effects on you derives from them (Art. 22): their only use is in the playing choices of the user who played against you, which you would face at the table anyway.
What you can ask for
You can object (Art. 21) by writing to privacy@pokerimprove.com and stating the room and the nickname. We will ask you for proof that the nickname is yours (for example a screenshot of the room's client with your nickname visible). After the check we delete from our servers the lines with that nickname for all users and prevent them from being loaded again.
We cannot, however, act on the files that the room delivered to the players or on the data saved on their computers: those remain in their personal sphere, like the history that the room delivered to you.
At the same address and with the same proof of the nickname, you can also ask for access to the data concerning you, their rectification (for example a note that describes you inaccurately), their erasure or the restriction of processing. We reply within one month. You also have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it), or with the supervisory authority of the EU country where you live, work or where the infringement took place (Art. 77 GDPR).
Data controller: Antonio Tatarelli, Via Magalotti 112, 00042 Anzio (RM), Italy, privacy@pokerimprove.com. The full privacy policy is here.