Privacy Policy

Effective Date: May 15, 2026 · Last updated: October 14, 2026

Fair Play Studio Limited (a company registered in Hong Kong, hereinafter "we") values your privacy and data security. This Policy explains what information we collect, why we collect it, who we share it with, where it is stored, and what rights you have. By using the Product you accept this Policy.

1. Information We Collect

1.1 Registration information: phone number and SMS verification code, to create your account, verify your identity and protect access.

1.2 Device information: device model, OS version, network type and app language, for security, anti-cheat, compatibility and optimisation. We do not collect advertising identifiers (IDFA) and we do not track your activity across other apps or websites.

1.3 Activity logs: sign-in records, in-app actions, game records and crash logs, for troubleshooting, security and service improvement.

1.4 Optional information: nickname and avatar, which you provide voluntarily for your public profile.

1.5 Voice data (Guardian feature): when you turn on voice messages, the app requests microphone and speech-recognition permission in order to convert your speech into text so the Guardian can reply. You can turn voice input off in the app settings and revoke the permissions in your system settings; if you do not grant them, the rest of the game still works normally. Audio is used only to transcribe your message and is not used for advertising.

1.6 Location: when you enter tables with a geographic restriction, we request your approximate location to check that you meet the entry requirement. You may decline; in that case you cannot enter those tables, but the rest of the game remains available.

1.7 Photos: if you choose a profile picture, we access only the photo you select. We read only the selected image: we do not access the rest of your gallery and we do not write anything to it.

We request each permission only when you turn on the corresponding feature. We do not access your contacts or any other sensitive permission unrelated to the service.

2. How We Use Information

• Provide, maintain and optimise the game and account services;
• Security, risk control, fraud and anti-cheat prevention;
• Handle enquiries, feedback and support requests;
• Send product announcements and updates (you can opt out);
• Comply with the legal and regulatory obligations applicable to us.

3. AI Assistant (Guardian)

The Guardian is a conversational assistant generated by artificial intelligence. When you interact with it, we process the text of your message, the game context (the cards visible to you, the stage of the hand and the amounts you put in) and a summary of your recent hands, for the sole purpose of generating its reply and maintaining the continuity of the conversation.

For this we use external language-model and voice-synthesis providers, which process this data on our behalf, following our instructions and under confidentiality obligations. We do not use the content of your conversations for advertising, and we do not sell it to third parties.

The Guardian may generate a profile and preference summary in order to remember the conversation. You can disable the Guardian and clear its conversational memory in the app settings. The Guardian does not take part in dealing cards, does not influence the outcome of any hand and does not act on your behalf.

4. Sharing and Disclosure

We do not sell, rent or trade your personal data. We share it only in the following cases:

• With service providers acting as processors under our instructions: hosting and servers, artificial-intelligence models, voice synthesis, identity verification and sign-in, and payment processing. They are contractually required to protect your data and to use it only to provide the service;
• With your explicit consent;
• Where required by law or by a competent judicial or regulatory authority;
• In the event of a merger, acquisition or transfer of assets, the transferee must continue to comply with this Policy.

5. Storage and Security

5.1 Our game and account servers are located in Mexico.

5.2 We apply technical and organisational measures to protect your data: encryption in transit (TLS) for communications between the app and our servers, role-based access control, audit logging of sensitive operations, and periodic permission reviews. No system is completely secure, so we scale these measures to the risk and the type of data.

5.3 We keep information only for as long as necessary for the purposes described:

• Account data: while the account is active; after deletion it is erased or anonymised;
• Guardian conversations and profile summary: while the account is active; you can clear them in the settings and they are deleted when you delete your account;
• Voice audio: used to transcribe your message; we do not retain the recording once the transcript has been produced;
• Technical and security logs: up to 6 months;
• Transaction records and game audit data: for the period required by applicable tax and accounting rules.

6. Your Privacy Rights

You may access and correct your data, disable non-essential permissions and features, object to certain processing, request a copy of your data, and delete your account and data. To exercise these rights, email Support@fairplaystudio.net or use the in-app account deletion feature.

7. Protection of Minors

The Product is for users aged 18 and over only. Minors may not register or use it. We do not knowingly collect data from minors and will delete it immediately if it is obtained by mistake.

8. Updates to This Policy

We may update this Policy. We will publish the current version in the app and state the date of the last update. Continued use after it takes effect constitutes acceptance.

9. Contact

Data controller: Fair Play Studio Limited (a company registered in Hong Kong).
Privacy and support email: Support@fairplaystudio.net

10. Account Deletion

You can delete your account inside the app at: Profile > Delete Account.

Once you confirm, your account is signed out and disabled and can no longer be used to sign in or access the app. We will delete or anonymise your personal information within a reasonable period after your request — including the Guardian's conversational memory — except for data we must retain to comply with legal or tax obligations, resolve disputes, or prevent fraud and protect security.