Poker Club Admin, LLC

Privacy Policy

Version 1.1 Effective Date: August 25, 2026

Poker Club Admin, LLC (“Poker Club Admin,” “PCA,” “we,” “us,” or “our”) provides software that helps customers administer poker clubs, leagues, tournaments, cash games, players, and related activities.

This Privacy Policy explains how PCA collects, uses, discloses, retains, and protects personal information when individuals visit our website, create or use a PCA account, interact with our Service, communicate with us, or otherwise provide information to PCA.

1. Our Role

PCA processes personal information in two principal capacities.

PCA as Controller

PCA determines how and why certain information is processed when administering our own business and Service, including information relating to:

Account Owners and authorized users;
account registration;
authentication and security;
subscriptions and billing;
age eligibility;
customer support;
privacy requests;
analytics;
Service security and abuse prevention.

PCA as Processor

PCA customers may enter and manage information about players and other individuals through the Service.

For this Customer Data, the PCA customer generally determines why and how the information is used and acts as the Controller. PCA generally processes that information on the customer's behalf as a Processor or service provider.

Questions about information maintained by a particular poker club or organization may therefore need to be addressed to that organization.

2. Eligibility

PCA is intended only for persons 18 years of age or older.

PCA is established in the United States and currently offers customer accounts, free trials, and subscriptions only to Customers/Account Owners located in the 50 United States or the District of Columbia. U.S. territories are not currently eligible customer jurisdictions.

This customer eligibility rule does not require players, league members, tournament or cash-game participants, invitees, or authorized Administrators managed by an eligible customer to reside in the United States.

For geographic eligibility, PCA collects the Customer/Account Owner's selected state or District of Columbia and affirmative attestation. PCA does not use precise geolocation, government identification, or IP geolocation as proof of residence.

Individuals creating PCA customer accounts must affirmatively confirm that they are at least 18 years old.

PCA records the account, user, confirmation, and timestamp associated with that attestation.

We do not require a date of birth, government identification, biometric information, or identity document solely to establish this eligibility requirement.

Customers must not knowingly use PCA to maintain accounts for persons under 18.

3. Information We Collect

Depending upon how the Service is used, PCA may process:

Account and identity information, such as name, email address, account association, role, and account identifiers.

Authentication and security information, such as authentication state, password hashes where applicable, MFA configuration, sessions, login attempts, verification status, network information, and security events.

Customer-provided player information, which may include names, email addresses, telephone numbers, club/league membership, and other information entered by PCA customers.

Poker administration records, such as tournament participation, seating, attendance, results, standings, points, buy-ins, rebuys, re-entries, add-ons, bounties, payouts, cash-game participation, cash-outs, fees, notes, and related records.

Subscription and billing information, such as plan, billing interval, subscription status, Stripe customer/subscription references, invoices, and transaction information.

PCA does not receive or store complete payment-card numbers or CVV values entered through Stripe-hosted payment functionality.

Communications, including support requests, privacy inquiries, service communications, and Customer-directed communications.

Technical and analytics information, such as page paths, referrers, browser/device information, language, screen dimensions, approximate geographic information, and related technical data.

4. How We Use Information

PCA may use personal information to:

provide and operate the Service;
create and administer accounts;
authenticate users;
maintain account and tenant security;
provide tournaments, leagues, cash-game and player-management functionality;
process subscriptions and billing;
send transactional and service communications;
provide customer support;
operate the optional AI Assistant;
prevent fraud, bots, spam and automated abuse;
investigate security incidents;
maintain audit records;
understand and improve the Service;
respond to privacy requests;
enforce our agreements;
comply with applicable law;
establish, exercise, or defend legal claims.

PCA does not sell personal information for monetary consideration and does not use Customer Data for behavioral advertising.

5. Customer Data

Customers control the information they enter into PCA about their players, leagues, tournaments, cash games, and related activities.

Customers are responsible for ensuring they have an appropriate legal basis and authority to collect and use that information.

Customers should not use PCA to collect unnecessary sensitive information.

PCA processes Customer Data according to the customer's instructions, our Terms of Service, and where applicable our Data Processing Addendum.

6. Payments and Stripe

PCA uses Stripe for payment processing, subscription checkout, and subscription management.

Information provided directly through Stripe-hosted payment functionality is processed by Stripe according to its applicable terms and privacy practices.

PCA receives information necessary to administer the subscription, such as subscription status, plan, billing interval, transaction references, and Stripe customer/subscription identifiers.

PCA does not receive or store complete payment-card numbers or CVV values.

7. AI Assistant and OpenAI

PCA provides an optional AI Assistant for authorized Owners and Administrators.

When used, PCA may transmit to OpenAI:

the user's current message;
limited recent AI conversation context;
whether the user has the Owner or Administrator role;
relevant generic PCA Help Center content;
instructions necessary to generate the response.

PCA does not automatically transmit the customer's player directory, account database, tournaments, cash games, leagues, billing records, or payment information to OpenAI.

Users can nevertheless enter personal information themselves. Users should not submit unnecessary private, confidential, sensitive, financial, authentication, or payment information to the AI Assistant.

PCA uses OpenAI's API with application-state storage disabled through store:false. PCA does not intentionally persist AI conversation content in its own application after the active interaction.

OpenAI's applicable API abuse-monitoring practices may nevertheless involve retention of API content for up to approximately 30 days. PCA does not currently represent that its OpenAI processing operates under Zero Data Retention.

8. Analytics and Umami

PCA currently uses Umami Cloud for privacy-focused analytics.

Our current implementation:

does not use analytics cookies;
does not assign a persistent PCA analytics identifier;
excludes URL query strings;
removes page titles;
does not intentionally send names, email addresses, PCA account IDs, player IDs, tournament IDs, or similar Customer Data;
does not use custom PCA analytics events or user-identification calls.

Umami may process page paths, referrers, browser/device information, language, screen dimensions, approximate geographic information, and related technical information.

PCA does not use Umami for behavioral advertising or cross-site advertising tracking.

Additional information is provided in our Cookie & Analytics Notice.

9. Security and Cloudflare Turnstile

PCA uses security measures designed to prevent unauthorized access and automated abuse.

These measures include Cloudflare Turnstile.

PCA currently uses Turnstile:

as a required anti-bot control during account registration; and
on a risk-based basis after repeated failed login attempts.

Security processing may involve network/source information, request timing, rate-limit state, authentication failures, challenge results, and related security signals.

PCA's implementation uses bounded, expiring rate-limit state and does not intentionally retain Turnstile response tokens in its security audit records.

These technologies are used for security and abuse prevention, not behavioral advertising.

10. Cookies and Browser Technologies

PCA uses browser technologies necessary to operate and secure the Service, including authenticated-session functionality.

PCA's current Umami analytics implementation does not use analytics cookies.

We do not currently use third-party behavioral-advertising cookies or cross-site advertising trackers.

Additional information is available in our Cookie & Analytics Notice.

11. Service Providers and Disclosure

PCA may disclose information to service providers where reasonably necessary to operate the Service.

Current principal providers include:

hosting.com — hosting, infrastructure, databases, backups, and related services;
Stripe — payments and subscription management;
OpenAI — optional AI Assistant;
Umami Cloud — privacy-focused analytics;
Cloudflare — Turnstile security and automated-abuse prevention.

PCA may also disclose information where reasonably necessary:

to comply with applicable law or valid legal process;
to investigate fraud or security incidents;
to protect PCA, our customers, users, or others;
to enforce our agreements;
in connection with a merger, acquisition, financing, sale, restructuring, or similar business transaction.

Our current provider information is maintained in our Subprocessor List.

12. Data Retention

PCA retains personal information only as long as reasonably necessary for the applicable purpose, subject to legal, accounting, security, contractual, dispute, and regulatory requirements.

Our working retention practices include:

Customer operational data: generally during active service and for approximately 30 days after paid access ends;
subscription/accounting records: generally up to seven years where appropriate;
contractual and age-attestation evidence: generally account lifetime plus approximately six years;
ordinary security records: generally approximately 12 months;
ordinary application audit records: generally approximately 24 months;
privacy-request records: generally approximately three years after closure;
support records: generally approximately 24 months after resolution.

Deleted information may remain temporarily in protected backups until ordinary backup rotation removes it.

PCA may retain information longer when reasonably necessary for legal obligations, security incidents, fraud prevention, disputes, legal claims, or legal holds.

13. Account Cancellation and Customer Data

Canceling a PCA subscription does not necessarily cause immediate deletion of Customer Data.

Paid access ordinarily continues through the applicable paid subscription period.

Following the end of paid access, PCA generally maintains Customer operational data for approximately 30 days to support account recovery and administrative needs before deletion or anonymization, subject to applicable legal exceptions and backup rotation.

Certain legal, accounting, subscription, security, age-attestation, and contractual records may be retained longer.

14. Security

PCA uses technical and organizational safeguards appropriate to the nature of the Service, including measures such as:

encrypted HTTPS communications;
authentication and authorization controls;
role-based access;
tenant isolation;
MFA support;
secure session management;
CSRF protection;
rate limiting;
automated-abuse controls;
email verification;
audit/security logging;
data minimization;
controlled secrets/configuration;
backup and recovery infrastructure;
automated quality/security testing.

No system can guarantee absolute security.

Users are responsible for protecting their own account credentials and promptly notifying PCA of suspected unauthorized access.

15. Processing Locations

PCA is established in the United States.

PCA customer accounts and subscriptions are currently offered only in the eligible U.S. jurisdictions identified in our Terms. This does not mean every person whose information an eligible customer legitimately manages through PCA must reside in the United States.

PCA and its service providers may process information in locations reasonably necessary to provide, secure, support, and administer their services. PCA does not represent that every provider operation occurs only in the United States.

16. Privacy Rights

Depending upon where an individual resides and applicable law, individuals may have rights concerning their personal information, potentially including rights to:

access;
correction;
deletion;
restriction;
objection;
portability;
withdraw consent where processing relies on consent;
complain to an applicable privacy authority.

These rights are not absolute and may be subject to legal exceptions.

Requests may be submitted to:

privacy@pokerclubadmin.com

PCA may take reasonable steps to verify identity before fulfilling a request.

We do not require government identification by default and seek to avoid collecting unnecessary information merely to verify a request.

17. Player Privacy Requests

If PCA receives a request concerning information entered and controlled by one of our customers, PCA may refer or coordinate the request with that customer.

For example, a poker club may control its player directory and tournament history while PCA provides the software used to store that information.

PCA will assist customers with applicable requests as required by law and our DPA.

18. No Discrimination for Privacy Requests

Where prohibited by applicable law, PCA will not unlawfully discriminate against an individual for exercising applicable privacy rights.

19. Children's Privacy

PCA is not intended for children or minors.

The Service is restricted to individuals 18 years of age or older.

If PCA learns that an account was created in violation of this requirement, PCA may suspend or terminate the account and take appropriate steps concerning the associated information.

20. Changes to This Policy

PCA may update this Privacy Policy as the Service, law, providers, or processing practices evolve.

When appropriate, we will update the effective date and provide additional notice of material changes.

Material changes will apply prospectively as required by applicable law.

21. Contact Us

Poker Club Admin, LLC 3511 Tahoe Blvd Normal, IL 61761 United States

Privacy: privacy@pokerclubadmin.com Legal: legal@pokerclubadmin.com Security: security@pokerclubadmin.com