Privacy Policy — The Vault

Last updated: 22/09/2026

1. Introduction and Scope

This Privacy Policy explains how Shahar Ben David, Akiva st Israel ("The Vault", "we", "us") collects, uses, discloses and protects personal information in connection with the The Vault mobile application (the "App") and the website at thevaultpokerapp.com (the "Website"), together the "Services".

The Vault is a recording and analytics tool for home poker games. The Vault does not offer real-money gambling, does not accept, process or facilitate bets or wagers, and does not hold, transmit or process funds.

Controller / operator: Shahar Ben David, Akiva st Israel Privacy contact: Contact@thevaultpokerapp.com

By using the Services you acknowledge that you have read this Policy. If you do not agree with it, please do not use the Services.

2. Information We Collect

2.1 Information you provide

  • Account information: your name (full name, which must be unique within the App), your sign-in identifier from Apple Sign In (Apple may provide a private relay email address instead of your real one), and EMAIL ADDRESS

  • Game and club information: clubs or groups you create or join, sessions you host or attend, RSVP responses, buy-ins, rebuys, results, balances and settlement records, and club rules you enter.


2.2 Information collected automatically

  • Device and technical data: device push-notification token, operating system, app version, IP address, and diagnostic and log data.


3. How We Use Information

We use personal information to:

  1. create and manage your account and authenticate you;

  2. provide the App's features, including recording sessions, calculating balances, leaderboards, player statistics and rank tags;

  3. send service notifications (such as session invitations and reminders) and, where you have enabled them, push notifications;

  4. maintain security, prevent abuse and fix errors;

  5. improve and develop the Services;

  6. communicate with you, including responding to requests and, where you signed up, about the App's launch; and

  7. comply with legal obligations.

4. What Other Users Can See

The App is social by design. Your name, participation in sessions, results, statistics, leaderboard position and rank tags are visible to other members of the clubs or groups you belong to. Please do not join a club whose members you do not want to see this information.

5. Sharing of Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

We share information only with:

  • Service providers (processors) who process it on our behalf under appropriate terms: DigitalOcean (server hosting), MongoDB Atlas (database), Apple (sign-in, push notifications and app distribution),

  • Other users, as described in Section 4.

  • Authorities or third parties where required by law, legal process or to protect rights, safety and security.

  • A successor, in the event of a merger, acquisition or sale of assets, subject to this Policy.

6. International Transfers

Our providers may process information in countries other than your own, including [SERVER / DATABASE REGION]. Where required, we rely on appropriate safeguards for such transfers, such as standard contractual clauses or an adequacy decision.

7. Retention

We keep personal information for as long as your account is active and as necessary to provide the Services, comply with legal obligations, resolve disputes and enforce our agreements. When you delete your account we delete or anonymize your personal information within 10 days, except where retention is required by law.

8. Security

We use reasonable technical and organizational measures to protect personal information, including encrypted connections and access controls. No system is completely secure, and we cannot guarantee absolute security.

9. Your Rights

Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict certain processing, to withdraw consent, and to lodge a complaint with a supervisory authority. To exercise these rights, contact [Contact@thevaultpokerapp.com]. We may need to verify your identity first.

European Economic Area, United Kingdom and Switzerland (GDPR). Our legal bases are: performance of a contract (providing the App), legitimate interests (security, improvement, and enabling the social features), consent (where requested, for example push notifications), and legal obligation. You may also object to processing based on legitimate interests and lodge a complaint with your local data protection authority.

California (CCPA/CPRA). You may request to know, access, correct and delete the personal information we hold about you. We do not sell or "share" personal information as those terms are defined under California law, and we will not discriminate against you for exercising your rights.

Israel. Under the Protection of Privacy Law, 5741-1981, you may request to review information about you held in our databases and to have it corrected or deleted where it is inaccurate. Provision of information to us is voluntary, but some features cannot work without it.

Appeals and authorized agents. If we decline to act on your request, you may appeal our decision by contacting us at Contact@thevaultpokerapp.com within a reasonable time after receiving our response. If you would like another person to make a request on your behalf, that agent may submit the request through the same channel; we may ask for proof that you have authorized them to act for you.

Other jurisdictions. If your local law grants additional rights, we will honor them as required.

10. Account Deletion

You can delete your account and associated data in the App under Settings > Delete Account, or by emailing Contact@thevaultpokerapp.com.

11. Children

The Services are not intended for anyone under 18 years of age, and we do not knowingly collect personal information from them. If you believe a minor has provided us with personal information, contact us and we will delete it.

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated version with a new "Last updated" date and, where changes are material, notify you through the App or the Website.

13. Contact

TheVault
Contact@TheVaultPokerApp.com

© 2026 The Vault. All rights reserved.

© 2026 The Vault. All rights reserved.

© 2026 The Vault. All rights reserved.