Privacy Policy
ACEX Mind: Poker Mental Coach – Privacy Policy
Effective Date: 2026-02-10
This Privacy Policy explains how ChienHua Lin, operating as ACEX Mind (“ACEX Mind,” “we,” “us,” or “our”) collects, uses, discloses, and protects information when you use the ACEX Mind: Poker Mental Coach mobile application and related services (collectively, the “Service”).
If you do not agree with this Privacy Policy, do not use the Service.
1) Who We Are / Contact
Provider: ChienHua Lin, operating as ACEX Mind
Location: Tainan, Taiwan (R.O.C.)
Mailing Address: No. 45, Aly. 20, Ln. 170, QingAn Rd., Xigang Dist., Tainan City 723023, Taiwan (R.O.C.)
Support Email: jeremy@acexmind.com
Website: https://acexmind.com
2) Eligibility (18+)
The Service is intended for users aged 18 and over. We do not knowingly collect personal information from individuals under 18.
3) Information We Collect
We collect information in the following categories. Some information may be considered sensitive depending on your jurisdiction (for example, content describing your emotional or mental state).
A) Account and Identity Information
- Account identifiers (e.g., user ID)
- Email address (for email/password login)
- Sign-in provider information (Apple Sign In / Google Sign In identifiers as provided by those services)
Note: When you sign in with Apple or Google, we receive information from those providers as needed to authenticate you. The exact data may vary depending on your provider settings.
B) User Content You Provide
The Service is designed to help you log, reflect, and receive coaching. You may choose to provide:
- Session Review structured data (e.g., profit/loss, duration, sleep, focus, stress, mood, and other structured indicators)
- Session Review notes (free-text notes you write for your own future review)
- Guided coaching inputs (structured fields such as sliders/dropdowns, plus optional notes describing what happened)
- AMA (Ask-Me-Anything) chat messages and conversation content
Important: The content you submit may include information about your emotional state, mental performance, habits, and other personal details. Please do not include information you do not want stored or processed for the purposes described in this policy.
C) Subscription and Service State Information
To provide subscription access and in-app feature availability, we may process and store:
- Subscription status (e.g., active/inactive, product identifiers, expiration or renewal-related timestamps as available through Apple/Google/RevenueCat)
- Feature state needed to operate the Service (e.g., energy counters, refresh times, and similar in-app state variables)
We do not receive or store your full payment card number. Purchases are processed by Apple App Store or Google Play.
D) Device and Technical Information (Limited)
We may process basic technical information necessary to operate and secure the Service (e.g., timestamps, app version, and limited diagnostic information). We do not use third-party advertising trackers and do not knowingly collect precise location data.
4) How We Use Information
We use information for the following purposes:
A) Provide and Operate the Service
- Create and manage your account
- Provide coaching features (Guided and AMA)
- Save and display your records (Session Review, Guided records, and other logs)
- Enable subscription access and enforce feature availability (e.g., energy systems)
B) Personalization (Per-User Only)
We use your structured logs and certain Service interactions to personalize your experience and help the AI coach better understand you over time, on a per-user basis.
We do not use your content to train a general AI model for other users.
C) Analytics and Improvement (Without Ad Tracking)
We may use aggregated or de-identified insights to improve the Service (for example, improving UX, stability, and feature effectiveness). We do not sell personal information and do not use third-party advertising trackers.
D) Safety, Security, and Abuse Prevention
- Prevent fraud, misuse, and security incidents
- Enforce our Terms of Use and protect users and the Service
E) Support and Communication
- Respond to your requests and support inquiries (including bug reports and account deletion requests if needed)
5) AI Processing and “Memory”
A) AI Providers
We use third-party AI services (currently OpenAI API) to generate coaching responses. To produce outputs, we may send relevant inputs to the AI provider, such as:
- Your current message and relevant context needed to answer
- Structured indicators you provide (e.g., session metrics or Guided fields) when used for coaching
- AI “memory” content associated with your account (see below), when enabled
B) Per-User “Memory” (Personalization)
We may create and store a per-user “memory” to help the AI coach provide more relevant guidance over time. This memory is designed to be account-specific and is not used to train a general model for others.
C) Controls
We provide controls to delete your account and associated data. Where available, we may also provide controls to clear your AI memory.
D) Provider Training
We configure our AI provider settings so that, to the extent supported by the provider, content sent via the API is not used by the provider to train or improve its general models.
6) Sharing and Disclosure
We share information only as needed to operate the Service, comply with law, or protect rights and safety. Examples include:
A) Service Providers (Processors)
We may share information with vendors that provide infrastructure and functionality, such as:
- Cloud hosting and databases (e.g., Google Firebase services)
- In-app purchases and subscriptions (Apple App Store, Google Play, and RevenueCat)
- AI processing providers (currently OpenAI API)
These providers process data on our behalf and under appropriate contractual and technical safeguards.
B) Legal and Safety
We may disclose information if required by law, legal process, or governmental request, or when necessary to protect the rights, safety, and security of ACEX Mind, our users, or the public.
C) Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to appropriate safeguards.
No Sale of Personal Information:
We do not sell personal information. We also do not share personal information for cross-context behavioral advertising.
7) Data Retention
We retain data for as long as necessary to provide the Service and for legitimate and essential business purposes (such as compliance, dispute resolution, and security), unless a longer retention period is required or permitted by law.
A) Structured Records (Session Review / Guided Structured Fields)
We retain structured records you create (such as session indicators and Guided structured inputs) for as long as your account remains active, because these are core to long-term tracking, visualization, and coaching. You may delete records where the Service provides that capability, and you may delete your account at any time (see Section 9).
B) Free-Text Notes
- Session Review notes are retained to allow you to review your own past sessions.
- Guided notes may be retained to support coaching and long-term progress tracking.
You may delete content where the Service provides that capability, or delete your account.
C) AMA Chat History (Conversation Logs)
We retain AMA chat history for a limited period to provide conversation continuity and user access to recent chat history. We may delete older chat messages over time as part of operating the Service.
D) AI Memory
AI memory associated with your account may be retained while your account remains active to provide personalization. Clearing memory (where available) or deleting your account will remove associated memory, subject to limited retention described below.
E) Backups and Limited Retention
Even after deletion, some information may persist for a limited period in backups or logs that are routinely overwritten, or as necessary for legal compliance, security, and fraud prevention.
8) Security
We use reasonable administrative, technical, and organizational measures to protect information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
9) Your Choices and Rights
A) Account Deletion
You can delete your account in-app. When you delete your account, we will delete personal information and content associated with your account from our active systems, subject to limited retention for backups, security, and legal obligations.
B) Content Controls
Where available, you can delete certain records or clear AI memory. If a feature is not yet available, you may contact us for assistance.
C) Marketing
We do not use third-party advertising trackers. If we ever introduce optional marketing communications, you will have the ability to opt out.
10) International Users and Cross-Border Transfers
We operate from Taiwan and may use service providers that process data in other countries. By using the Service, you understand that your data may be transferred and processed outside your country of residence, where data protection laws may differ. We take steps to apply appropriate safeguards where required.
11) Privacy Rights (EEA/UK and California – Where Applicable)
A) EEA/UK (GDPR/UK GDPR)
If you are in the EEA/UK, you may have rights to:
- Access, correct, or delete your personal data
- Object to or restrict certain processing
- Data portability
- Withdraw consent where processing is based on consent
- Lodge a complaint with a supervisory authority
Our legal bases for processing may include:
- Providing the Service (performance of a contract)
- Legitimate interests (e.g., security, prevention of abuse, and improving the Service)
- Compliance with legal obligations
- Consent where required (and you may withdraw it)
B) California (CCPA/CPRA)
If you are a California resident, you may have rights to:
- Know what personal information we collect, use, and disclose
- Request deletion of personal information
- Correct inaccurate personal information
- Opt out of “sale” or “sharing” (we do not sell or share for cross-context behavioral advertising)
- Not be discriminated against for exercising your rights
To exercise rights, contact us at jeremy@acexmind.com. We may need to verify your request.
12) Website Contact Form
If you contact us through our website, we will receive the information you provide (such as your email and message) to respond to your request, provide support, and improve our Service.
13) Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If changes are material, we will provide reasonable notice (for example, within the app or on our website). The “Effective Date” above indicates when this policy was last updated.
14) Contact Us
If you have questions or requests regarding privacy, contact:
Mailing Address: No. 45, Aly. 20, Ln. 170, QingAn Rd., Xigang Dist., Tainan City 723023, Taiwan (R.O.C.)