Privacy notice
The short version
- Players don't have accounts. You give a first name and build an avatar. A photo is optional.
- A photo is shown only at the live table and is deleted when the table closes. We never run face detection on it.
- Each table, and everything in it, is deleted 24 hours after its last activity.
- If you pay, we keep your email address and your Stripe customer record. Stripe handles your card.
- The commentary services receive public game events and first names only. Never photos.
- No ads, no third-party trackers, and we never sell or share personal information.
1. Who we are
Carolina Hold 'em is a party game run by MDO Labs ("we", "us"). We decide how the data described here is used, except where a company runs games for its staff (see Games at work).
2. What we collect
Players
- A first name, up to 16 characters, shown on the TV and on the other phones at your table. Please use a first name only.
- An avatar descriptor: a few bytes describing the cartoon you build (face shape, hair, skin tone, glasses and so on). It is a description, not an image.
- An optional photo, if you choose to use one instead of the avatar (see Photos).
- What happens in the game: antes, bets, folds, picks, chip counts and the cards dealt to you. Your own cards are shown only on your phone, unless you choose "Show my cards" or they are shown at a showdown.
- A seat credential kept in your phone's browser storage, so a refresh puts you back in your own seat.
Players give no email address, surname, phone number or password.
Hosts
- A host token kept in the browser of the device that starts a table, so it can run that table.
- Table settings, such as whether photos are allowed and whether the booth speaks.
People who pay
- Your email address, to send your licence key, sign-in link, receipts and renewal reminders.
- Your Stripe customer record: the customer ID, plan, status and renewal date Stripe gives us. We never receive full card numbers.
- Your licence: we store only a hash of the licence key, plus the device tokens issued under it.
- Company branding (Corporate only), if you upload a logo or event name.
Technical data
- IP address and request details, handled by our host Cloudflare to deliver pages, protect the service from abuse (for example, limits on how fast tables can be created) and keep short-lived operational logs.
- Aggregate product measurements, such as table sizes and response times, recorded without cookies and not used to identify anyone.
3. Photos
A photo is always optional. The avatar is an equal alternative, and choosing it costs you nothing in the game.
- Consent. Choosing "Use a photo instead" is your opt-in. Before you pick a photo, the screen says what happens: it shows on the TV for this game only, it is deleted when the table closes, and it is never used for face recognition.
- Where it lives. You crop the photo and it is resized on your phone (256 × 256 pixels), then stored in the table's own folder in our host Cloudflare's storage. It is shown only to the TV and phones at that table: fetching it needs a key only that table's devices hold.
- When it's deleted. When you remove it, when you leave or are removed, when the host hides it, or when the table closes (no later than 24 hours after the table's last activity). As a backstop, our storage deletes every photo 2 days after it was added, whatever happens.
- Never analysed. We never run face detection, face recognition, landmarking, automatic cropping or filters on your photo, on your phone or on our servers. You line up the crop yourself.
- Never passed on. Photos are never sent to the commentary services, never kept in saved history, and never used in recaps or share cards.
- Host controls. The host can hide any photo instantly (you go back to your avatar) or switch photos off for the table.
Only use a photo of yourself.
4. How long we keep it
| A table: names, avatars, game events, commentary lines | Deleted 24 hours after the table's last activity. |
|---|---|
| Photos | Deleted when removed or hidden, when the player leaves or when the table closes (never more than 24 hours after the table's last activity), and in any case 2 days after they were added. |
| Saved history (Corporate, only if the host turns it on) | First names, avatar descriptors, final standings and a few game stats, kept until the host deletes them. No photos. |
| Payer and licence records | While your plan is active, then as long as tax and accounting rules require. |
| Operational logs | A short period, set by our host. |
5. Commentary
The booth's two commentators are automated. Groq runs the language model that writes their lines, and Microsoft Azure turns the lines into speech on the TV.
- They receive public game events only: bets, calls, folds, the shared cards, cards shown at a showdown, pot sizes and results, with players' first names.
- They never receive photos, private cards, email addresses, or any name beyond a first name.
- The lines are kept with the table and deleted with it. Spoken clips may be cached so a repeated line isn't generated twice; clips that contain names are deleted with the table.
Automated commentary can occasionally get something wrong. The host can mute the booth at any time.
6. Payments
Stripe is the merchant of record. When you buy a plan, Stripe sells it to you, takes the payment (card, Apple Pay or another wallet) and handles sales tax and VAT. Stripe's own privacy policy covers the data Stripe collects at checkout and in its customer portal. We receive your email address, customer ID, plan and payment status, and never your full card details.
7. Who we share it with
We use these service providers, and only for the purposes described:
- Cloudflare: hosting, the live tables and their storage, and sending licence emails.
- Stripe: payments, as merchant of record.
- Groq: writing the commentary lines.
- Microsoft Azure: voicing the commentary lines.
We don't sell personal information or share it for advertising. There are no ad networks and no third-party trackers. We may disclose data if the law requires it.
8. Why we're allowed to use it
For people in the EEA, the UK and similar places:
- Running the game you join: to provide the service you asked for, and our legitimate interest in running a fair, working game.
- Your photo: your consent, which you can withdraw at any time by removing the photo.
- Plans, licences and receipts: to perform our contract with you, and legal obligations for tax records.
- Security and abuse prevention: our legitimate interest in keeping the service safe.
9. Games at work
When a company buys the Corporate plan and runs games for its staff, the company decides how the game is used, and we process player data on its behalf under a data processing agreement. Staff should direct privacy questions about the event to the company as well as to us.
10. Your choices and rights
- Play with an avatar instead of a photo, or remove your photo at any time.
- Leave a table whenever you like, or ask the host to remove you.
- If you pay, manage or cancel your plan in Stripe's customer portal.
- Ask us for a copy of your data, or to correct or delete it. Because we keep so little, and tables delete themselves, there is often nothing left to find.
- Depending on where you live (for example under the GDPR, UK GDPR or California's CCPA), you may have further rights, including to object, to restrict use, and to complain to a data protection authority. We don't sell or share personal information, so there is nothing to opt out of.
11. Age
Hosts, and anyone who pays, must be 18 or over. The service is not directed at children, and we don't knowingly collect personal information from children under 13.
12. Cookies and browser storage
We don't use advertising or analytics cookies. The game uses your browser's storage only for what it needs to work: your seat credential for a table and the host token. If you open an invite link, one cookie (holdem_licence) holds the invite's key on that device so the tables you start use its plan; it lasts until the invite ends, at most 400 days, and "Remove the invite from this device" on the invite page deletes it. Stripe's checkout and portal pages are run by Stripe and set their own cookies.
13. Changes and contact
If we change this notice, we'll update the date at the top. If a change matters for people who pay, we'll email them first.
Questions or requests: [privacy contact address].