Privacy Policy

Last updated: 1 July 2026

1. Who we are

PokerLens is a product of Gutterbugs Limited ("we", "us"), a company registered in England and Wales. PokerLens is a desktop poker study tool that analyses hand histories from PokerStars and provides AI-powered coaching insights.

2. What data we collect

Hand histories. PokerLens parses PokerStars hand history files stored on your local machine. These files contain gameplay data (hands, actions, pot sizes, player names). This data is processed locally on your computer and is never sent to our servers.

Account data. If you create a PokerLens account, we store your email address and a randomly generated authentication token. We do not collect passwords — authentication is token-based.

Usage data. We track the number of AI coach questions you ask per billing period for credit metering. We log the model used and token counts for cost tracking. We do not log the content of your coach conversations.

Payment data. Payments are processed by Stripe. We do not store your card details — Stripe handles all payment information. We receive only your Stripe customer ID and subscription status.

3. How AI calls work

When you use the AI Coach, your hand history data and coaching questions are sent to our Cloudflare Worker proxy, which forwards them to our LLM provider (Z.AI or Anthropic). The data is transmitted over HTTPS and is not stored on our servers beyond the duration of the API call. The LLM provider may retain data according to their own policies.

If you use PokerLens in personal mode (with your own API key), your data goes directly from your computer to the LLM provider — it never touches our servers.

4. Data residency

Your hand history database lives on your local machine in ~/.pokerlens/. It is never uploaded to any server. You can delete it at any time by removing that directory.

5. Your rights (UK GDPR)

• Access: Email us to request a copy of your account data.
• Erasure: Email us to delete your account and all associated data.
• Portability: Your hand history data is already on your machine — export it anytime.
• Objection: You can stop using the service at any time.

Contact: [email protected]

6. Cookies

The PokerLens website uses minimal analytics (Google Analytics 4) to understand traffic. The desktop application does not use cookies.

7. Changes to this policy

We will update this policy if our data practices change. We will notify active users via email for any material changes.