Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. We collect, use, and disclose Your information as described in this Privacy Policy and, where required by applicable law, only where We have a valid legal basis to do so, including Your consent (where consent is required).

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access Our Service or parts of Our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to No Rush Hold'em, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Jessica Yohanan, operating under the name “Made by Samyo”, the developer and operator of No Rush Hold'em.
• For the purposes of the GDPR, the Company is the Data Controller.
• Country/State refers to: Israel.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service, such as a computer, a cell phone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
• GDPR refers to the EU General Data Protection Regulation.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.
• For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Service refers to No Rush Hold'em, including the Application and the web version of the Service.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• For the purposes of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• User means any individual who accesses or uses the Service.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
• Under GDPR, You can be referred to as the Data Subject since You are the individual using the Service.

Collecting and Using Your Personal Information

Types of Data Collected

Personal Data

When You create or use an Account, certain Personal Data may be collected or processed in connection with the Service. This may include:

• Email address
• First and last name, where provided through the authentication service
• Account and user identifiers
• Display name and profile/avatar information, where provided
• Game progress, gameplay history, statistics, achievements and Journey progress
• Purchase and Premium entitlement information
• Information You choose to provide when contacting support, including optional screenshots

Usage Data

Certain technical and usage information may be collected automatically when You use the Service. Depending on how You access the Service and the services involved, this may include app and build information, device or platform type, screen or viewport information, online status, app activity and analytics events, diagnostic information, and identifiers used to operate the Service.

The Service also creates an app-specific device identifier to support features such as gaming-device management. This identifier is generated by the Application and is not a hardware identifier.

Our service providers, including Base44 and Google, may independently process additional technical information such as IP address, device information, advertising identifiers, approximate location derived from IP address, advertising interactions, and diagnostic or performance information in accordance with their respective privacy practices.

Tracking Technologies, Local Storage and SDKs

We use local storage and software development kits (“SDKs”) to operate and improve the Service, maintain sessions and preferences, support offline functionality, measure app usage, process purchases, and provide advertising.

The Application stores certain information locally on Your Device, which may include authentication information, Premium entitlement information, game and Journey session data, offline synchronization queues, cached game data, preferences, and diagnostic information.

Third-party SDKs, including Google AdMob, may use device identifiers and similar technologies for advertising, measurement, fraud prevention and related purposes. Where required by applicable law, consent or other privacy choices will be requested before applicable advertising technologies are used.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain the Service: including operating gameplay, maintaining Your Account, saving game progress, statistics, achievements and Journey progress, and providing offline and cross-device functionality where available.
• To manage Your Account: including authentication, account administration, profile settings and access to features available to registered users.
• To process purchases and Premium access: including verifying Google Play purchases, providing Premium entitlements, restoring eligible purchases, processing refunds or revocations, and preventing fraudulent reuse of purchase tokens.
• To provide advertising: including displaying banner, interstitial and rewarded advertisements to eligible users and managing applicable advertising consent and privacy choices.
• To analyze and improve the Service: including understanding feature usage, identifying technical issues and improving gameplay, performance and user experience.
• To provide customer support: including responding to requests, feedback and problem reports and reviewing information or screenshots that You voluntarily provide.
• To maintain security and integrity: including preventing fraud, abuse, unauthorized economic changes and other misuse of the Service.
• To comply with legal obligations: including responding to lawful requests and maintaining records where required by applicable law.
• For business transfers: We may use or transfer Personal Data in connection with an actual or proposed merger, acquisition, restructuring, financing, sale of assets or similar transaction, subject to applicable law.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of Our Service, to show advertisements to You to help support and maintain Our Service, for payment processing, and to contact You.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside the Service.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Retention of Your Personal Data

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain security and integrity, comply with legal obligations, resolve disputes, and enforce Our agreements.

Retention periods may vary depending on the type of information, the purpose for which it is processed, and the systems and Service Providers involved.

Account and Game Data: Information associated with Your Account, including profile information, game history, statistics, achievements, Journey progress and related application data, is generally retained while Your Account remains active. When You delete Your Account, We initiate deletion of the application data associated with Your Account, subject to the exceptions and technical limitations described below.

Purchase and Billing Records: Certain records relating to Google Play purchases may be retained after Account deletion where reasonably necessary for purchase verification, refunds, fraud prevention, financial recordkeeping, legal compliance, and protection against reuse of previously claimed purchase tokens. Where applicable, retained purchase records are anonymized or disassociated from the deleted Account.

Support Data: Support requests and information voluntarily submitted with them may be retained for as long as reasonably necessary to respond to the request, investigate technical or security issues, and maintain appropriate support records.

Analytics, Logs and Service Provider Data: Certain analytics, security logs, technical information and other information processed by Our Service Providers may be retained according to those providers' systems, policies and retention practices. We may not control or be able to individually delete all historical analytics, logs or similar provider-level records.

Locally Stored Data: Certain Account-related information is stored locally on Your Device to operate features such as authentication, game sessions, offline functionality, Premium access, caching and synchronization. Account-linked local data is cleared as part of Our logout or Account-deletion processes where applicable.

Uploaded Files: If You voluntarily upload files through the Service, such as a profile avatar or a screenshot submitted with a support request, copies of those files may remain in Our infrastructure provider's storage after the associated Account or database record is deleted due to current technical limitations of the storage service. We do not use such residual files for new purposes after Account deletion.

We may retain information for a longer period where necessary to comply with applicable law, establish, exercise or defend legal claims, prevent fraud or abuse, or protect the security and integrity of the Service.

Information that has been aggregated or anonymized so that it can no longer reasonably be associated with an identifiable individual may be retained for longer periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and, where relevant, supplementary measures. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request deletion of Personal Data that We have collected about You, subject to certain legal, security, fraud-prevention and technical exceptions.

Deleting Your Account through the Application: You may permanently delete Your Account from within the Application by going to Settings and selecting the Delete Account option. You will be asked to confirm the deletion before it is processed.

Account deletion is permanent. When Your Account is deleted, We initiate deletion of the application data associated with Your Account, including Your profile and settings, game sessions and history, statistics, achievements, Journey progress, session data, and support records associated with the Account.

Requesting deletion outside the Application: If You no longer have access to the Application, information about requesting Account deletion is available at:

https://delete.norushholdem.app

Information that may be retained: Account deletion does not necessarily result in deletion of every record that has ever been associated with Your use of the Service. We may retain limited information where reasonably necessary for legal compliance, purchase verification, refunds, fraud prevention, security, dispute resolution, or protection of the integrity of the Service. In particular, certain Google Play purchase records may be retained in anonymized or disassociated form, and records used to prevent reuse of previously claimed purchase tokens may be retained.

Certain information processed or stored by third-party Service Providers, including historical analytics, logs, backups, or uploaded files, may also remain for a period of time or may not be individually deletable by Us due to the technical operation and retention practices of those providers.

You may also contact Us at madebysamyo@gmail.com to request access to, correction of, or deletion of Personal Data, subject to applicable law. We may need to verify Your identity before fulfilling certain requests.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Where required by applicable law, We obtain consent or provide applicable privacy choices before using non-essential cookies, advertising technologies, SDKs, or similar tracking technologies. Depending on how You access the Service, these technologies may operate through the Application or through the web version of the Service. Consent and privacy choices may be managed through tools made available by Us or Our Service Providers.

Analytics

We may use third-party Service Providers to monitor and analyze the use of Our Service.

Depending on the provider and how the relevant tool is configured, these analytics providers may also use the information collected on Our Service for their own purposes, including to improve their own services.

Base44 Analytics

• Their Privacy Policy can be viewed at https://base44.com/privacy-policy
• Base44 provides application infrastructure, authentication, data storage, backend functionality and analytics services used by the Service. Certain analytics events may be associated with an authenticated Account by Base44.

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

AdMob by Google

• AdMob by Google is provided by Google Inc.
• You can opt out of the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
• For more information on how Google uses the collected information, please visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the Privacy Policy of Google: https://policies.google.com/privacy
• Depending on Your location and applicable law, Google AdMob may process information such as device and advertising identifiers, IP-derived approximate location, advertising interactions and diagnostic information. Where required, We use Google's consent tools to obtain or manage applicable advertising consent and privacy choices.

Payments

The Service may offer paid digital products or features through Google Play. Purchases are processed by Google Play, and We do not receive or store Your full payment card or bank account details.

We receive and process limited purchase-related information necessary to verify purchases and manage Premium access, which may include product identifiers, purchase tokens, order identifiers, purchase status and timestamps, package information, and an account-related identifier used for purchase verification and fraud prevention.

Purchase information may also be processed for purposes such as restoring eligible purchases, refunds, revocations, fraud prevention and preventing reuse of previously claimed purchase tokens.

Google Play In-App Payments

• Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

Authentication

We use third-party authentication services to help create and manage Accounts.

Google Sign-In

Where You choose to sign in using Google, authentication is provided through Google and Our authentication infrastructure. Google may process information in accordance with its own Privacy Policy. We receive the Account information made available through the authentication process as necessary to create and manage Your Account.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or those of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

The legal basis We rely on depends on the purpose of the processing:

• Performance of a contract: creating and administering Your Account, providing and maintaining the Service, processing purchases and payments, and providing customer support.
• Legitimate interests: securing the Service and preventing fraud and abuse; monitoring, analyzing, and improving the Service; sending non-marketing service communications; enforcing Our agreements and establishing, exercising, or defending legal claims; and evaluating or completing business transfers. Where We rely on legitimate interests, Our interest is the effective, secure, and commercially sustainable operation and improvement of the Service, and We balance that interest against Your rights and freedoms.
• Consent: sending marketing communications where consent is required; placing and reading non-essential cookies and similar technologies, as described in the "Tracking Technologies, Local Storage and SDKs" section, where consent is required;
• Legal obligation: retaining transaction, tax, and accounting records, and responding to lawful requests from courts and public authorities.

Where the provision of Personal Data is a statutory or contractual requirement, or necessary to enter into a contract with Us, We will make this clear at or before the point of collection, including whether You are obliged to provide the Personal Data and the possible consequences of not providing it. If You have questions about the legal basis for any specific processing activity, please contact Us.

International Transfer of Personal Data

We may transfer, store, and process Personal Data in countries other than the country in which You are located, including countries outside the European Economic Area ("EEA") and the United Kingdom ("UK"), where data protection laws may differ.

Where We transfer Personal Data outside the EEA/UK to a country that has not been recognized as providing an adequate level of protection, We rely on appropriate safeguards, such as:

• Transfers to countries that the European Commission or the UK Government has decided provide an adequate level of data protection, including, for transfers to the United States, recipients certified under the EU-U.S. Data Privacy Framework (and its UK Extension), where applicable
• The European Commission's Standard Contractual Clauses ("SCCs") and/or the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the SCCs (as applicable)
• Supplementary measures where appropriate, such as encryption in transit and at rest, access controls, data minimization, and vendor security reviews.

We transfer Personal Data internationally only as needed to provide the Service and to work with Our Service Providers (for example, hosting, analytics, email delivery). You may contact Us using the details in the "Contact Us" section of Our Privacy Policy to request further information about the safeguards We use for international transfers, including copies of relevant contractual protections (redacted where necessary).

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law where the GDPR or the UK GDPR applies to Our processing of Your Personal Data (including, in particular, if You are in the European Economic Area (EEA) or the United Kingdom (UK)), to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Where possible, You can access, update or request deletion of Your Personal Data directly within Your Account settings section. If You are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request restriction of processing. You have the right to ask Us to restrict processing of Your Personal Data in certain circumstances (for example, while We verify accuracy or consider an objection).
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation that makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent to Our use of Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise any of the rights described above by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible. We generally respond within one month, and may extend by two further months where necessary, in accordance with applicable law.

You have the right to complain to a supervisory authority about Our collection and use of Your Personal Data. If You are in the EEA, please contact Your local data protection authority. If You are in the UK, You can complain to the Information Commissioner's Office (ICO).

Automated Decision-Making

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning You or similarly significantly affect You. If this changes, We will update this Privacy Policy and provide the information and safeguards required by the GDPR.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's and Minors' Privacy

The Service is intended for users who are 18 years of age or older and is not directed to children or minors under the age of 18.

We do not knowingly collect Personal Data from anyone under the age of 18. We do not currently use age-verification technology, and users are expected to use the Service only if they meet the applicable age requirement.

If You are a parent or guardian and believe that a child or minor has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from a person under the applicable age requirement, We will take reasonable steps to delete that information, subject to applicable legal and technical limitations.

Where applicable law imposes additional requirements concerning the processing of Personal Data relating to children or minors, We will process such information in accordance with those requirements.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When We do, We will post the updated Privacy Policy and update the "Last updated" date at the top of this Privacy Policy.

Where required by applicable law, including where changes are material or affect how We process Your Personal Data or Your privacy rights, We will provide appropriate notice before the changes take effect. Such notice may be provided through the Service, by email, or by other appropriate means.

You are advised to review this Privacy Policy periodically for changes. Changes become effective when posted, unless a different effective date or additional notice is required by applicable law.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us:

• By email: madebysamyo@gmail.com