Privacy Policy

This Privacy Policy explains how OllinLabs ("Ollin," "we," "us," or "our") collects, uses, and shares information about you when you use the Ollin mobile application and any related services (collectively, the "App").

Ollin is a free-to-play poker learning application. It is played with virtual, play-money chips only. It does not offer real-money gambling, and virtual chips have no monetary value and cannot be redeemed, withdrawn, or exchanged for cash or prizes.

By using the App, you agree to the practices described in this Policy. If you do not agree, please do not use the App.

1. You Must Be 18 or Older

The App is intended only for users who are 18 years of age or older (or the age of majority in your jurisdiction, if higher). We do not knowingly permit anyone under 18 to create an account or use the App.

If we learn that we have collected information from a person under 18, we will delete that information promptly. If you believe a minor has provided us with personal information, please contact us at privacy@ollinlabs.com.

See Section 11 (Children's Privacy) for more detail.

2. Information We Collect

2.1 Information you provide to us

Account information: when you register, we collect information such as your email address, username, and a password (stored in hashed form). If you sign in through a third-party service (e.g., Google or Apple), we receive basic profile information from that provider as permitted by your settings.

Profile and gameplay preferences: any display name, avatar, or settings you choose.

2.2 Information collected automatically

When you use the App, we and our service providers may automatically collect:

• Device and technical data: device model, operating system and version, unique device or installation identifiers, language, time zone, and mobile network information.
• Usage and gameplay data: hands played, decisions made, in-app actions, feature usage, session duration, screens viewed, and performance/crash data. This gameplay data is central to how the App gives you feedback on your play.
• Log data: IP address, access times, and error logs.
• Notification and installation identifiers: a device/installation identifier used by Firebase Cloud Messaging to deliver push notifications, and, depending on configuration, identifiers used to understand engagement and improve the product.

2.3 Information from third parties

We may receive information from analytics providers, authentication providers, and app stores, consistent with their policies and your settings.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the App, including your account and gameplay.
• Generate the real-time and post-session feedback that is the core of the product — analyzing your decisions so we can show you why a hand went the way it did.
• Personalise your experience and improve learning outcomes.
• Understand how users engage with the App so we can improve it, fix bugs, and develop new features.
• Send you push notifications about your activity and the App, which you can control through your device settings.
• Detect, prevent, and address fraud, abuse, security incidents, and violations of our terms.
• Comply with legal obligations and enforce our agreements.

4. Legal Bases for Processing (EEA/UK Users)

If you are in the European Economic Area or the United Kingdom, we rely on the following legal bases under the GDPR:

• Performance of a contract — to provide the App and features you request.
• Legitimate interests — to improve and secure the App, understand usage, and develop features, provided these interests are not overridden by your rights.
• Consent — for certain analytics, marketing communications, or optional features, where required. You may withdraw consent at any time.
• Legal obligation — where we must process information to comply with the law.

5. How We Share Your Information

We do not sell your personal information. We share it only as described below:

Service providers/processors: companies that provide infrastructure and features on our behalf, acting on our instructions. We currently use:

• Google / Firebase (Google LLC) — to deliver push notifications (Firebase Cloud Messaging). This involves a device/installation identifier used to route notifications to your device and, depending on configuration, basic analytics. We do not store your account or gameplay data on Firebase.
• Google Sign-In (Google LLC) — to let you authenticate with your Google account. When you sign in, we receive basic profile information (such as your name, email address, and Google account identifier) as permitted by your Google settings.
• Microsoft Azure, with primary infrastructure in the United States — hosts our backend API and related cloud services, where your account information and gameplay data are stored and processed. Our marketing website is also hosted on Microsoft Azure Static Web Apps.

App stores: Apple and Google, in connection with the distribution of the App.

Legal and safety: where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Ollin, our users, or others.

Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy.

With your direction or consent, when you ask us to share information or otherwise agree.

6. Third-Party Services

The App uses third-party services (such as analytics and authentication providers) that may collect information as described in their own privacy policies. We encourage you to review the policies of any third-party service you connect to the App. We are not responsible for the practices of third parties.

7. Data Retention

We retain personal information for as long as your account is active or as needed to provide the App, and thereafter as necessary to comply with legal obligations, resolve disputes, prevent abuse, and enforce our agreements. When information is no longer needed, we delete or anonymize it. You may request deletion of your account and associated data as described in Section 9 and on our Delete your account page.

8. International Data Transfers

Ollin is operated from India, and your account and gameplay data are stored and processed on our backend hosted on Microsoft Azure in the United States (and other Microsoft regions as required for resilience). Information may also be processed in other countries where our service providers (such as Google/Firebase) operate. These countries may have data-protection laws different from those in your country.

Where we transfer personal information of EEA/UK users outside those regions, we rely on appropriate safeguards such as Standard Contractual Clauses or an equivalent lawful transfer mechanism. You may contact us for more information about these safeguards.

9. Your Rights and Choices

Depending on where you live, you may have some or all of the following rights:

• Access — request a copy of the personal information we hold about you.
• Correction — request that we correct inaccurate information.
• Deletion — request that we delete your personal information.
• Portability — request a copy in a portable format.
• Objection / restriction — object to or restrict certain processing.
• Withdraw consent — where processing is based on consent.

To exercise any of these rights, contact us at privacy@ollinlabs.com. We will respond within the timeframe required by applicable law. We will not discriminate against you for exercising your rights.

EEA/UK users also have the right to lodge a complaint with a supervisory authority.

California users (CCPA/CPRA): you have the right to know what personal information we collect, to request deletion, to correct it, and to opt out of "sale" or "sharing" of personal information. We do not sell your personal information. You may exercise these rights using the contact details above, and you may designate an authorized agent to act on your behalf.

India users (DPDP Act 2023): you may access, correct, and erase your personal data, nominate another individual to exercise rights in the event of death or incapacity, and address grievances through our contact channel below.

10. Data Security

We use reasonable technical and organizational measures designed to protect your information, including encryption in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your account credentials confidential.

11. Children's Privacy

The App is not directed to children under 18, and we do not knowingly collect personal information from anyone under 18. If you are under 18, do not use the App or provide any information to us. If we become aware that we have collected personal information from a person under 18, we will delete it promptly. Parents or guardians who believe their child has used the App may contact us at privacy@ollinlabs.com.

12. Cookies and Similar Technologies

The App and any associated web pages may use cookies, SDKs, and similar technologies to operate the service, remember your preferences, and understand usage. Where required by law, we will request your consent before using non-essential technologies. You can manage certain choices through your device settings.

13. Third-Party Links

The App may contain links to third-party websites or services (for example, our community channels). We are not responsible for the privacy practices of those third parties, and this Policy does not apply to them.

14. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you through the App or by other reasonable means and update the "Last updated" date above. Your continued use of the App after the changes take effect means you accept the revised Policy.

15. Contact Us

If you have questions about this Policy or our data practices, contact us at:

OllinLabs
Email: privacy@ollinlabs.com

To request account deletion, see Delete your account.