Privacy Policy

ACEX Mind: Poker Mental Game — Privacy Policy

Effective Date: 2026-03-22

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 Game 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. If we become aware that a user is under 18, we will take steps to delete their account and associated data.

3. Information We Collect

A) Account and Identity Information

- Account identifiers (e.g., user ID)

- Sign-in provider information (Apple Sign In / Google Sign In identifiers as provided by those services)

- Email address (as provided by your sign-in provider)

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) Session and Performance Data You Provide

The Service is designed to help you track, analyze, and improve your poker mental performance. You may choose to provide:

- Pre-session data: focus level, tilt carryover, blind level, session type, and other structured indicators

- In-session data: tilt events including type, severity, and optional trigger descriptions

- Post-session data: profit/loss, decision quality rating, hands played, end reason, and optional notes

- Deep Review inputs: structured fields describing triggers, feelings, appraisals, drift patterns, and other mental state indicators used for AI diagnosis

Important: The content you submit may include information about your emotional state, mental performance, and personal habits. Please do not include information you do not want stored or processed for the purposes described in this policy.

C) AI Diagnosis Data

When you use the AI Diagnosis (Deep Review) feature, we process your inputs through a third-party AI service to generate structured analysis and training task recommendations. The AI-generated diagnosis results and assigned training tasks are stored in your account.

D) Subscription and Service State Information

To provide subscription access and feature availability, we may process and store:

- Subscription status (e.g., active/inactive, tier, product identifiers, expiration or renewal-related timestamps as available through Apple/Google/RevenueCat)

- AI diagnosis usage counts (to enforce monthly quota limits per subscription tier)

We do not receive or store your full payment card number. Purchases are processed by Apple App Store or Google Play.

E) 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

A) Provide and Operate the Service

- Create and manage your account

- Record and display your session data, tilt events, and notes

- Provide AI diagnosis and training task recommendations

- Compute and display performance metrics (Focus Quality, Tilt Control, Recovery Speed, Training Discipline)

- Generate trend charts and progress visualizations

- Enable subscription access and enforce feature availability (e.g., AI diagnosis quotas)

B) Derived Analytics (Server-Side)

We compute derived metrics from your raw session data to provide performance insights. These computations happen on our servers, not on your device. Raw data you submit is preserved as-is; derived metrics can be recalculated if our formulas improve.

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

5. AI Processing

A) AI Providers

We use third-party AI services (currently OpenAI API) to generate diagnosis responses. To produce outputs, we send relevant inputs to the AI provider, including:

- Your Deep Review form inputs (structured fields such as triggers, feelings, appraisals, drift patterns)

- Related session context needed to produce a meaningful diagnosis

B) No Model Training

We configure our AI provider settings so that content sent via the API is not used by the provider to train or improve its general models, to the extent supported by the provider.

C) Data Storage

AI diagnosis results are stored in your account for your review. You can delete your account to remove all associated data (see Section 9).

6. Sharing and Disclosure

We share information only as needed to operate the Service, comply with law, or protect rights and safety.

A) Service Providers (Processors)

We may share information with vendors that provide infrastructure and functionality, such as:

- Cloud hosting and databases (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.

D) No Sale of Personal Information

We do not sell personal information. We 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, unless a longer retention period is required or permitted by law.

A) Session Records and Tilt Events

Retained for as long as your account remains active, as these are core to long-term tracking, metrics computation, and progress visualization.

B) AI Diagnosis Records and Training Tasks

Retained for as long as your account remains active, to allow you to review past diagnoses and track training progress.

C) Performance Metrics

Metric snapshots are retained to show historical trends. Raw session data is preserved separately and can be used to recalculate metrics if formulas change.

D) Account Deletion

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. Even after deletion, some information may persist for a limited period in backups or logs that are routinely overwritten.

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 the app (Settings > Delete Account). 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

You can delete individual session records where the Service provides that capability.

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 use service providers that process data in other countries (including the United States). 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, and consent where required.

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. Children's Privacy

The Service is not intended for children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

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:

Email: jeremy@acexmind.com

Mailing Address: No. 45, Aly. 20, Ln. 170, QingAn Rd., Xigang Dist., Tainan City 723023, Taiwan (R.O.C.)