Scope and Data Controller
This policy explains how Happy advert ("we", "us" or "our") collects, uses, retains and discloses information about you when providing the FeltCoach app, associated web pages, lessons and practice, AI text questions and answers, screen-sharing guidance and session reviews. Personal information includes information that, alone or together with other information, can identify an individual or reflect their activities.
This policy applies to the services we provide. Your accounts, deposits, transactions and information independently processed by other game platforms are separately governed by their rules and privacy policies. Displaying their names, icons or links does not mean that we jointly operate those platforms or have their authorization.
Features may vary by app version, operating system and region. Describing a feature in this policy does not automatically authorize data collection for a feature you have not enabled. Where a new purpose, sensitive information processing or disclosure to another controller requires additional notice or consent, we must complete those steps separately. Reading this page alone does not provide that authorization.
Information We Process
We process the following information according to the features you actually use. In the table below, "local" means the app's storage or the shared storage used by the main app and its broadcast extension. It does not mean that the information is excluded from device backups you enable.
| Feature or activity | Information involved | Purpose and location |
|---|---|---|
| Lessons and local practice | Lesson progress, practice selections, answers and results, practice time and completed practice records | Displaying learning progress and history. Existing local practice primarily runs and is stored on the device. |
| Preferences | Interface and voice language, sound, haptics, strategy style and recognition method | Saving your selections and providing the corresponding interface and features. Some session settings are sent with guidance requests. |
| Online guidance | Session identifiers, random access credentials, timestamps, capture sequence, strategy and recognition versions, and session status | Authentication, connection, synchronization, session recovery, duplicate prevention and session reviews. Processing takes place on the device and server. |
| Screen sharing and recognition | Image frames or image-change data; cards, positions, chip stacks, bet amounts, actions and recognition results. Images may also include nicknames, avatars and notifications. | Recognizing game situations, generating strategy suggestions, investigating recognition issues and creating session reviews. Information may be sent to the recognition service. |
| AI text questions and answers | Your questions, current lesson text, recent conversation submitted with a request and model responses | Sent through our service to OpenRouter and the actual model provider to generate lesson explanations and answers. |
| Operation and security | App-generated device identifiers, device model, operating system and app versions, network IP address, access time, request status, errors and performance data | Session association, compatibility, authentication, rate limiting and troubleshooting, including local diagnostics and server logs. An app-generated identifier is not your real name. |
| Reading web pages | Requested page, IP address, browser or request headers, access time and response status | Processed by the actual website hosting and network services to deliver pages and maintain security. These legal pages do not embed advertising, visitor analytics or third-party font scripts. |
Existing native features do not require your real name, identity documents, contacts or precise location for local practice. We do not ask for passwords or verification codes for third-party game accounts, payment passwords or bank card details. Please do not enter such information in questions or display it on a shared screen.
Important Information About Screen Sharing
Screen sharing starts only after you initiate it and confirm through the operating system. The system's sharing scope may include other apps, system screens or notifications you switch to. You should not assume that the service can automatically detect and exclude all unrelated content. Before starting, hide sensitive notifications and avoid opening chats, photo libraries, payment screens, passwords or confidential work information.
We may compress, sample or encode captured images, or recognize game situations from them. Image data, recognition results and session information needed for online guidance are sent to the server. Selecting "On-device recognition" does not mean that all data is processed only on your phone. The current protocol may still upload images for guidance and quality checks.
The current capture pipeline uses video images as input and does not process microphone or system audio. Voice prompts play suggestion text; they do not mean that your speech is being recorded. If audio input is added in the future, its purposes and permissions must be explained separately. This policy does not provide blanket authorization for future audio processing.
Selecting "Pause Guidance" stops sharing and voice prompts locally while retaining the session. Resuming guidance requires another system screen-sharing confirmation. Selecting "End" and confirming ends guidance. You can also use the operating system's stop-sharing control. If network problems occur or status messages conflict, check the system's sharing status and use its stop-sharing control.
Pausing, ending, turning off voice prompts or uninstalling the app does not automatically delete images or records already sent to the server. Turning off voice prompts only changes your playback preference; it does not withdraw screen sharing. During development, the server retains images for recognition quality review. See Section 7 for retention arrangements and current limitations.
Purposes and Legal Bases
We process information to provide the lessons, practice, questions and answers, and guidance you choose; save preferences and history; authenticate requests and sessions; recognize game situations and generate suggestions; prevent stale frames, duplicate instructions and expired results; troubleshoot issues; protect network and service security; and meet applicable legal requirements.
Under applicable law, processing must rely on the necessity of providing the service you request, your valid consent, a legal obligation or another lawful basis, as appropriate. Where consent is required, you may choose whether to give it and may withdraw it. Separate consent, guardian consent or written consent must be obtained separately where required. A general service agreement does not replace these requirements.
Recognition quality review and model training are different purposes. Participating in guidance does not, under this policy, automatically authorize us or third parties to train models indefinitely, publish datasets, conduct marketing or sell images. Any new, nonessential purpose must be explained, including its scope, retention arrangements and how to decline, and the applicable authorization procedures must be completed.
Declining online questions and answers or screen sharing affects those features, but should not prevent you from using local lessons and practice that do not depend on that information. Online services may be unavailable if necessary network authentication or security information cannot be provided.
AI Services and Automated Analysis
Live guidance generates reference suggestions from image recognition results, limited action history and the selected strategy. Text questions and answers generate responses from your question and lesson context. These outputs do not confirm facts, players' actual intentions, complete financial settlements or final outcomes.
Text questions and answers are routed through OpenRouter to model providers. Lesson content, your questions and conversation included with requests leave your device. Actual recipients, service locations, retention and training rules depend on the service configuration and model provider. OpenRouter's role as an intermediary does not establish that downstream providers do not retain data or use it for training. Specific recipients and applicable arrangements must be explained before the relevant processing is formally offered.
Do not submit identity documents, passwords, medical information, financial account details or other people's information without authorization to AI services. If you do not want questions and context sent to external AI services, do not submit online questions. You can still read local lessons.
We do not guarantee profits through strategy labels, or use questions and answers or guidance to make credit, employment, insurance or other decisions with legal or similarly significant effects. You retain any rights under applicable law to explanations of automated processing, to object or to refuse particular decisions.
Processors, Disclosures and Third Parties
Providing the service may require infrastructure hosting, network transmission, storage and AI processing. We must distinguish processing on our behalf from independent processing according to the actual relationships, and limit the purposes, scope and security requirements. Third-party involvement does not remove our responsibilities under applicable law.
| Service category | Information and purposes | Scope and limitations |
|---|---|---|
| Apple system services | Information necessary for system screen sharing, app distribution and device-level services. Voice prompts use system capabilities. | Apple provides system permissions. System permission does not replace consent for other purposes. Device backups depend on your settings and arrangements with Apple. |
| FeltCoach recognition and strategy services | Shared images, game situations and actions, sessions and device diagnostics | Used for recognition, suggestions, reviews and diagnostics. Ludora is the name of the recognition and strategy technology pipeline, not a separate user authorization. |
| OpenRouter and actual model providers | Lesson context, questions and conversation included with requests, to generate text responses | Downstream provider identities and data rules must be checked against the actual configuration. Naming only the aggregation service does not constitute complete disclosure. |
| Website and API infrastructure | IP addresses, request headers, access and security logs, and data necessary to host the service | Actual operating locations, providers and retention arrangements must be established before formal processing begins. |
This policy does not authorize public disclosure or sale of your personal information, or cross-service advertising profiling. Where personal information must be disclosed to an independent recipient under applicable law, we must explain the recipient, purpose, information involved and how to exercise rights, and meet applicable requirements such as separate consent.
For disclosures required by law, lawful business transfers or organizational changes, we must limit the disclosure, review requests and provide required notices under applicable law. Displaying a third-party brand, opening a third-party app or providing an external link does not mean that the third party can access all FeltCoach data.
You may also read the Apple Privacy Policy and the OpenRouter Privacy Policy. Third-party policies explain those parties' own rules. They do not replace our specific disclosures to you or our legal responsibilities.
Storage Locations and Retention
Practice progress, training records, preferences and some session and diagnostic information are stored in the app's device storage. Online guidance images, session metadata, recognition and suggestion records, and some diagnostics may be stored on servers we use. Text questions and answers are also processed by external AI services.
An API domain name does not establish the country or region where servers are physically located. This page does not currently confirm specific storage locations for each data category, backups or all recipients. We do not describe the data as "entirely stored locally" or "entirely stored domestically". Section 8 applies where processing crosses borders.
Retention must be limited to the shortest time necessary for the relevant purpose. Factors include whether you still need history or reviews; whether sessions and errors have been resolved; whether a necessary security investigation is ongoing; whether applicable law requires continued retention; and whether deletion or genuine anonymization can replace retention.
During development, the server retains images for recognition quality review. Specific retention periods by category, backup cleanup cycles and a complete deletion process remain to be confirmed. This page does not promise deletion when a session ends, automatic deletion within 24 hours or an existing one-click deletion feature. An undefined retention period does not authorize indefinite retention.
Information that is no longer needed must be deleted or anonymized. If legal retention requirements or technical reasons prevent immediate deletion, processing beyond necessary storage and security protection must stop, and access must be restricted. De-identification or removing nicknames is not necessarily anonymization. Information that can still be linked to an individual remains subject to personal information protection.
International Processing and Regional Protections
External AI, hosting, network and other services may process data outside your country or region. General statements in this policy alone should not authorize cross-border processing. Using a feature voluntarily does not establish that all legally required procedures have been completed.
Where cross-border disclosures require additional procedures by law, we must first explain the overseas recipient, contact details or an effective rights-request channel, processing purposes and methods, information categories and rights procedures. We must also complete any applicable separate consent, contracts, assessments, certifications or other requirements. Relevant processing should not begin before necessary arrangements are in place.
Where China's Personal Information Protection Law, European Economic Area or United Kingdom data protection rules, or other mandatory regional protections apply to you, using cross-border services does not exclude those rights. Using this service does not waive data protection rights available to you under applicable local law.
Security and Incident Response
The existing client uses HTTPS for production services, validates access credentials for guidance sessions and applies system file protection to some local files. We must also implement necessary access restrictions, credential management, security reviews and incident response according to the risks. These measures do not establish a security certification, mean that all stored data is encrypted or guarantee that a breach can never occur.
Protect your device and system accounts. Do not disclose session credentials, share diagnostics containing personal information or install software from untrusted sources. If you accidentally share information, stop sharing immediately. Merely hiding the app or muting audio does not ensure that capture has stopped.
If personal information is at risk of unauthorized disclosure, alteration or loss, we must promptly take remedial action and notify competent authorities and affected individuals as required by applicable law, including information about the incident, possible effects, actions taken and practical protective steps. Security risk notices in this policy do not remove those obligations.
Permissions, Preferences and Withdrawal
- Screen sharing: You can choose not to initiate system confirmation. During sharing, you can pause guidance, confirm that you want to end, or use the system stop control. Resuming guidance requires renewed sharing confirmation.
- Voice prompts: You can turn them off in the app's voice settings. Doing so does not mean that sharing or network processing has stopped.
- Language and other preferences: You can change these in the relevant app settings. Changes do not retrospectively rewrite existing history.
- Online questions and answers: Not submitting a question avoids a new request. Closing the question-and-answer screen does not automatically withdraw requests already sent.
- Device backups: Manage these through system or backup service settings. Clearing app data and deleting device backups are separate actions.
Withdrawing consent does not affect processing based on valid consent before withdrawal, but may make features that depend on that information unavailable. Where no other lawful retention basis exists after withdrawal, we must handle the information as required by law. The version and time of your locally recorded risk-notice acceptance do not constitute server-side identity verification, an electronic signature or a tamper-proof record.
Access, Correction, Copies and Deletion
To the extent provided by applicable law, you may request information about processing rules, access and copies of personal information, correction of inaccuracies, deletion of information that is no longer necessary or was processed unlawfully, withdrawal of consent, restriction of or objection to particular processing, and data transfer where the relevant conditions are met. Reading or accepting this policy must not be used to restrict those rights.
The app's history screens let you view existing training and session reviews. There is currently no complete self-service mechanism for exporting server-side personal information, deleting all relevant data or closing an account. The disappearance of local records or successful uninstallation does not mean server-side data has been erased. The current version primarily associates service use with device and session identifiers. You should not be required to close a registered account that does not exist.
Locating a request should generally require only necessary session identifiers, a time range, app version or an explanation of the issue. Third-party passwords, verification codes, complete identity documents or unrelated information should not be required. Identity checks, response periods, exceptions and reasons for refusal must comply with applicable law.
This page does not currently publish an available channel for data rights requests. Before the service is formally offered to the public, an effective way to receive and handle requests must be provided. This page cannot itself submit a request or be treated as confirmation of deletion. This limitation does not affect your right to complain to a competent authority or seek judicial remedies.
Protection of Minors
Live game guidance is intended for users who meet the minimum age requirements of their location and the relevant third-party platform. Live-play guidance is not offered to children who do not meet those requirements. The service must not be used for underage gambling, inducing minors to make deposits or other restricted activities.
If we discover information collected from an ineligible minor, we must investigate and take legally required measures, such as stopping the processing, deleting information or taking other necessary action. A general acceptance checkbox does not replace separate guardian consent or special protections required by law. An app store age rating does not constitute age verification.
Cookies, Web Pages and External Links
These legal pages can be read without signing in. Their content does not depend on JavaScript, they do not set advertising identifiers, and they do not write analytics cookies or localStorage data or embed marketing trackers. These pages do not actively send reading activity to an analytics service.
Website hosts and network infrastructure may still process access logs. Your browser may cache pages or store browsing history in synchronization services you enable. The absence of analytics scripts on these pages does not mean that the entire app or internet access involves no information processing.
Links to external legal sources and Apple or OpenRouter policies are provided by those organizations. Following them takes you to third-party websites, whose network requests and privacy rules are handled separately by the relevant third party. Reading those links does not mean you agree to submit shared screen images to that party.
Policy Updates and Interpretation
We will update this policy when features, processing purposes, data categories, recipients or legal requirements change, and identify the version and last updated date. Material changes must be communicated with appropriate prominence. Where fresh consent is required by law, we must obtain it; continued use does not automatically authorize every new purpose.
This version is a pre-release review document. Its last updated date is not the date of your acceptance and does not mean that operational arrangements awaiting clarification have been implemented. The formally applicable version and effective arrangements must be identified at release. Where this policy conflicts with mandatory local law, protections that cannot lawfully be excluded prevail.
Please read the Terms of Service for the associated service rules. Statements about the scope of the service do not waive our personal information protection obligations.