Privacy & Cookies Policy

Last updated: 09/2025

Article 1 – Introduction

This Privacy and Cookies Policy is intended to inform users of the AstralGTO platform (the “Platform”) about the processing of personal data carried out by AstralGTO, a simplified joint-stock company (SAS) with share capital of €1,000.00, registered with the Bastia Trade and Companies Register under number 990 559 254, with registered office at 920 Chemin De Mucchitana, 20200 Ville-di-Pietrabugno, France (the “Publisher”).

Article 2 – Data controller

The data controller is AstralGTO. Contact: [email protected]

Article 3 – Data collected

The data that may be collected includes in particular: - Identification data: name, surname, email address, account ID. - Connection and usage data: IP address, connection logs, Platform activity. - Service-related data: poker hand histories uploaded by the user, analysis statistics and results. - Billing data: payment methods, transaction information (via Stripe).

Article 4 – Purposes of processing

Data is collected for the following purposes: - Provision of the services offered on the Platform. - Management of user accounts and authentication. - Payment processing and invoicing. - Customer support and communication with users. - Continuous improvement of services and internal statistics. - Compliance with legal and regulatory obligations.

Article 5 – Legal basis

Data processing is based on: - performance of the contract (subscription, access to services), - compliance with legal obligations (billing, accounting), - the Publisher’s legitimate interest (service improvement, fraud prevention), - user consent (non-essential cookies, marketing communications).

Article 6 – Data retention period

Data is retained for the period strictly necessary for the purposes pursued, including: - account-related data: subscription period + 3 years after termination, - billing data: 10 years (legal obligation), - technical data (logs): 12 months.

Article 7 – User rights

In accordance with the GDPR, users have the following rights: - right of access, rectification, deletion, - right to object and restrict processing, - right to data portability, - right to withdraw consent at any time. To exercise these rights: [email protected]

Article 8 – Data sharing

Data may be transmitted only to third parties necessary for the operation of the Platform: - Stripe Payments Europe Ltd for payment processing, - Supabase Inc. for data hosting and authentication.

Article 9 – Transfers outside the European Union

Some data is hosted in the United States via Supabase Inc. The Publisher implements appropriate safeguards to govern such transfers in accordance with the GDPR (European Commission Standard Contractual Clauses).

Article 10 – Cookies

The Platform uses cookies and trackers to: - ensure the technical operation of the site, - measure audience and improve user experience, - provide personalized content and, where applicable, marketing campaigns. Users may accept or refuse non-essential cookies via the consent banner displayed during their first visit.

Article 11 – Data security

The Publisher implements appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of personal data.

Article 12 – Governing law and jurisdiction

This policy is governed by French law. Any dispute shall fall within the exclusive jurisdiction of the courts within the jurisdiction of the Court of Appeal of Bastia, subject to mandatory legal provisions to the contrary.