Privacy Policy

1. Data Controller

The data controller responsible for your personal data under the EU General Data Protection Regulation (GDPR, Regulation 2016/679) is:

HuddleHud
Contact: info@huddlehud.com
Website: https://huddlehud.com
Country of establishment: Italy

For any privacy-related questions, requests, or complaints, contact Us at info@huddlehud.com.

2. What Data We Collect

We collect only the minimum data necessary to provide and improve the Service:

(a) Information You provide directly:

• Name and email address, when submitted through Our contact form or account registration
• Message content voluntarily submitted through Our contact form
• PokerTracker.com account identifier, when subscribing to the Service
• Communications with Us via email or Discord

(b) Information collected automatically:

• Technical browser data (browser type, operating system, referral URL) via strictly necessary session cookies
• Aggregated, anonymized website traffic statistics via Cloudflare Web Analytics — no personal identifiers, no cross-site tracking

(c) Information from third parties:

• Payment and billing information processed by third-party payment processors (Merchant of Record model). We do not directly collect or store credit card details.

We do not collect: sensitive personal data (racial or ethnic origin, political opinions, religious beliefs, health data, sexual orientation, biometric or genetic data). We do not sell or rent personal data to any third party under any circumstances.

3. How We Collect Data

Data is collected through:

• Direct submission (contact form, subscription registration, email)
• Website interaction (session cookies, Cloudflare Web Analytics)
• Third-party integrations (payment processor, PokerTracker.com, Discord)

4. Legal Basis for Processing (GDPR Art. 6)

We process personal data on the following legal bases:

• (a) Contract performance (art. 6(1)(b)): to provide the Service you have purchased or subscribed to;
• (b) Legitimate interest (art. 6(1)(f)): to operate, secure, and improve the Service, prevent fraud, and communicate with users;
• (c) Legal obligation (art. 6(1)(c)): to comply with applicable laws, tax regulations, and legal requests;
• (d) Consent (art. 6(1)(a)): where explicit consent is required and provided (e.g., certain communications).

5. Purpose of Processing

Personal data is used strictly to:

• Deliver and maintain the Service you have subscribed to
• Respond to inquiries and provide customer support
• Process payments and manage subscriptions
• Send transactional communications (order confirmations, account notices, updates to legal documents)
• Improve the Service and troubleshoot technical issues
• Comply with legal, tax, and accounting obligations
• Protect against fraud, abuse, or security threats

We do not use personal data for advertising, marketing profiling, or automated decision-making with legal effects.

6. Data Retention

We retain personal data only as long as necessary for the purposes for which it was collected:

• Account and subscription data: for the duration of the subscription, plus a reasonable period thereafter (typically 24 months) for legal, accounting, and audit purposes;
• Contact form submissions: for up to 12 months after the last interaction;
• Transactional records: for the period required by applicable tax and accounting law (10 years for invoicing under Italian law);
• Website analytics: aggregated and anonymized, retained by Cloudflare under their retention policy.

After the retention period, data is permanently deleted or anonymized.

7. How We Store and Protect Data

Personal data is stored on secure internal systems accessible only to authorized personnel. We apply reasonable technical and organizational measures to protect data against unauthorized access, disclosure, alteration, or loss, including:

• Strong access authentication (two-factor authentication where applicable)
• Encrypted data transmission (HTTPS/TLS)
• Restricted access on a need-to-know basis
• Regular review of security practices

Despite these measures, no system can guarantee absolute security. You acknowledge that data transmission over the Internet involves inherent risks.

8. Third Parties We Work With

We share personal data only with trusted third parties strictly required to deliver the Service. These include:

• Payment processors (e.g., LemonSqueezy) — for subscription billing and payment. These processors act as Merchants of Record and handle their own compliance and privacy practices.
• Formspree — for handling contact form submissions.
• Cloudflare — for website infrastructure, security, and privacy-friendly analytics.
• PokerTracker.com — for delivery and activation of Premium Add-Ons.
• Discord — for community-based communications, if you choose to join.
• Email services (e.g., Google Workspace / Gmail) — for correspondence.

Each of these third parties is subject to its own privacy policy. We select providers that offer strong data protection standards.

We do not sell, rent, or share personal data with any third party for marketing purposes.

9. Cookies

HuddleHud uses only strictly necessary cookies required for the technical functioning of the website:

• __cf_bm (Cloudflare) — security and bot detection
• __dpl — deployment routing
• session-id — session state management

These cookies do not track your activity across other websites, do not collect personal data for marketing purposes, and do not require your consent under GDPR regulations (art. 122 D.Lgs. 196/2003 for Italy). No third-party analytics, advertising, tracking, or retargeting cookies are used.

Cloudflare Web Analytics operates without cookies and without personal data collection.

If you disable cookies in your browser, some functionality may be impaired.

10. International Data Transfers

Some of Our third-party providers may store or process data outside the European Union (for example, Cloudflare, Discord, or Formspree). Where this is the case, transfers occur under appropriate legal safeguards such as Standard Contractual Clauses (SCCs) or equivalent GDPR-approved mechanisms.

11. Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights regarding your personal data:

• (a) Right of access — request a copy of your data;
• (b) Right to rectification — correct inaccurate data;
• (c) Right to erasure ("right to be forgotten") — request deletion, subject to legal exceptions;
• (d) Right to restriction of processing — limit how your data is used;
• (e) Right to data portability — receive your data in a structured, machine-readable format;
• (f) Right to object — object to processing based on legitimate interest;
• (g) Right to withdraw consent — where processing is based on consent;
• (h) Right to lodge a complaint — with a supervisory authority (in Italy: Garante per la Protezione dei Dati Personali, https://www.garanteprivacy.it).

To exercise any of these rights, contact Us at info@huddlehud.com. We will respond within one month of receiving your request.

12. Children's Privacy

HuddleHud is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided personal data to Us, contact Us at info@huddlehud.com and We will promptly delete such data.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in Our practices, technology, or applicable law. Material changes will be communicated via the Service or by email to registered users. The "Last updated" date at the top of this Policy indicates the most recent revision.

Continued use of the Service after any change constitutes acceptance of the updated Policy.

14. Contact

For any questions, requests, or concerns regarding this Privacy Policy, or to exercise any of Your GDPR rights, contact Us at:

Email: info@huddlehud.com

Website: https://huddlehud.com