Privacy Policy

1) Who we are

2) Scope

This Policy applies to:

• The GTOKiller website/app and its forms (account sign-up, contact, subscription/newsletter).
• Services hosted on Firebase (EU region).

3) Data we collect

• Identification & contact: name, email.
• Credentials: password (hashed/salted via Firebase Authentication).
• Technical data: IP address, device/browser identifiers, and cookies (first-party; future analytics cookies if enabled).
• Payment data: processed by Stripe. We do not store full card details; we only receive necessary metadata for subscription/billing management.
• Form content: messages and preferences provided through contact or subscription forms.
• Minors: Our services are not intended for users under 18, and we do not knowingly collect data from minors.

4) Purposes and legal bases

We do not carry out automated decisions with legal effects nor profiling to adjust prices or similar outcomes.

5) Cookies & similar technologies

We use first-party cookies for core functionality. In the future, we may enable analytics cookies (e.g., Google Analytics). A cookie consent banner will allow you to accept, refuse or configure non-essential cookies. Details will be provided in our Cookie Policy (when published).

6) Processors and data recipients

We use service providers acting as processors under GDPR Art. 28:

• Firebase (Google Cloud, EU region): hosting, database, authentication, security.
• Stripe Payments Europe / Stripe, Inc.: payment processing and subscription management.
• Additional providers for email delivery, monitoring or support may be used under equivalent contracts and will be reflected in this Policy or available on request.

We do not sell your personal data.

7) International transfers

Where a provider involves transfers outside the EEA (e.g., Stripe or Google support operations), we rely on appropriate safeguards under GDPR Arts. 44+ such as Standard Contractual Clauses (SCCs) and supplementary measures where needed.

Firebase: services are configured to EU region by default.

Stripe: may transfer data to group companies/sub-processors; Stripe applies SCCs and equivalent safeguards.

You can request more information at info@gtokiller.com.

8) Retention

• Active accounts: we keep data for the duration of the contractual relationship.
• After account deletion: we keep only what is strictly necessary for 1 year to handle legal/accounting obligations and potential claims (note: certain tax/accounting records may be retained longer if required by law).
• Marketing: until you withdraw consent or object.

9) Security

We apply appropriate technical and organizational measures, including: TLS/SSL encryption in transit; at-rest encryption provided by Firebase; Firebase Authentication with hashed/salted passwords; Firestore/Storage security rules, access controls and logging; backups and environment segregation aligned with industry good practices. No system can be 100% secure, but we work to minimize risks.

10) Your GDPR rights

You may exercise: access, rectification, erasure, restriction, objection, portability, and the right to withdraw consent (without affecting prior processing).

For now, please email info@gtokiller.com to exercise these rights. We plan to offer a self-service user section in the future.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) or your local authority.

11) Marketing communications

We send marketing/newsletters only with your consent. You can unsubscribe at any time by contacting info@gtokiller.com or via the unsubscribe link when available.

12) Payments

Payments are processed by Stripe. GTOKiller does not store full card details. Stripe may act as an independent controller for certain processing activities—please consult Stripe’s own privacy notices for details.

13) Additional legal bases

We may process and retain data to comply with legal obligations (e.g., tax/accounting) and for the establishment, exercise or defense of legal claims (legitimate interest).

14) Changes to this Policy

We may update this Policy to reflect legal or service changes. If the change is material, we will notify you (email or on-site notice). The current, effective version is always the one with the most recent Last updated date.

15) Contact

For questions or to exercise your rights: ADVANCED POKER RESEARCH, S.L. — info@gtokiller.com

P.º de Heriz, 40, Primero A, 20008 Donostia-San Sebastián, Gipúzkoa, Spain