Privacy Policy

1. Who We Are

CuePal is operated by CuePal Inc., a company registered in Canada. Our platform is designed for billiard and snooker players, clubs, and associations worldwide. We are committed to protecting your personal information and processing it lawfully, fairly, and transparently.

Contact us at:

• Website: www.cuepal.co
• Email: contact@cuepal.co
• Mailing address: CuePal Inc., Vancouver, British Columbia, Canada

2. Information We Collect

We collect the following categories of personal information:

2.1  Account & Identity Information

• Full name and display name
• Email address and password (encrypted)
• Profile photo (optional)
• Country and city of residence

2.2  Gameplay & Performance Data

To power the CuePal Global Rating (CGR) system and your player profile, we collect:

• Tournament and match results you submit or that are submitted by a club or association on your behalf
• Historical achievements you voluntarily claim upon joining CuePal
• Practice sessions, scores, drill logs and practice routines you create, including table layouts generated with our AI routine setup
• League standings and ranking positions

2.3  Club & Association Data

If you manage or are affiliated with a club or association on CuePal, we also collect:

• Club/association name, logo, and contact details
• Member roster and player affiliation records
• Table booking and scheduling information
• Tournament and league configurations and results

2.4  Device & Usage Information

• Device type, operating system, and app version
• IP address and approximate location derived from it
• Pages or features you access and how long you use them
• Crash logs and error diagnostics

2.5 Communications, Community and AI Features

• Messages you send to our support team, your conversations with the in-app AI Coach, and the descriptions you type into the AI routine setup. Technique analysis videos: if you upload a cue action video, we detect the position of 17 body points (for example shoulders, elbows, wrists, hips, knees, ankles and a single point for the head) in each frame to score your stroke. We do not use face recognition, do not create face geometry or a faceprint, and do not identify you from your face. The body-point positions exist only in memory while the video is processed and are then discarded; we keep only the resulting scores, a motion timeline and stroke timings. Your original video and the annotated copy are stored so you can watch them again. You can ask us to delete them at any time at contact@cuepal.co.
• Posts, photos, videos, comments, likes, reports and follows you make in Community, and feedback, survey responses and app store reviews you submit voluntarily

2.6  Information from Third Parties

If you sign in using Apple ID or Google, we receive basic profile information (name and email) from those providers, subject to your privacy settings with them.

2.7 Subscription and Payment Data

CuePal Pro subscriptions are processed entirely by Apple (App Store) or Google (Google Play). CuePal Inc. does not collect, store, or have access to your payment card details or billing information. We receive only the following from Apple or Google upon a successful transaction:

• Confirmation that a purchase or renewal has occurred
• Your subscription status (active, expired, or cancelled)
• The subscription tier and billing period you selected

This information is used to activate and maintain your Pro features within the app. Our subscription provider, RevenueCat, also sends trial and subscription events to Meta so we can measure which of our ads bring in new players (see Sections 5.2 and 6).

3. How We Use Your Information

We use your information to:

• Create and manage your account and player profile
• Calculate and maintain your CuePal Global Rating (CGR)
• Operate and display city, national, and global leaderboards
• Enable clubs and associations to manage tournaments, leagues, and member records
• Process table bookings and scheduling requests
• Provide and improve the app, website, and platform features
• Send transactional communications (account confirmations, match notifications, booking reminders)
• Send optional marketing emails and in-app notifications (only with your consent)
• Investigate and resolve disputes or technical issues
• Comply with our legal obligations
• Detect and prevent fraud, abuse, or violations of our Terms of Service

We process your data on the following legal bases (where applicable under law):

• Contract performance – to deliver the services you signed up for
• Legitimate interests – to improve our platform and ensure its security
• Consent – for optional marketing communications and analytics (you may withdraw at any time)
• Legal obligation – to comply with applicable laws and regulations

We also use subscription status information received from Apple and Google to grant, maintain, and revoke access to CuePal Pro features, and share trial and subscription events with Meta to measure the performance of our advertising, as described in Section 6. Billing, renewals, cancellations, and refunds are managed entirely through your App Store or Google Play account and are subject to Apple's and Google's respective terms and refund policies.
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4. The CuePal Global Rating (CGR)

The CGR is a core feature of CuePal. Your rating and ranking are visible to other users on the platform as part of the community experience. By using CuePal, you acknowledge that your CGR, match history, and ranking position are public to other registered users of the platform.

You may contact us to request corrections to your CGR if you believe it has been calculated based on inaccurate match data. We do not share identifiable CGR data with third parties for advertising or commercial profiling purposes.

5. How We Share Your Information

We do not sell your personal information. We may share it as follows:

5.1  With Other CuePal Users

Your public profile (name, photo, CGR, ranking, match history) is visible to other registered CuePal users. Anything you post in Community, including photos, videos, comments and the practice, match or routine cards you attach, is visible to other CuePal users, as are your likes, comments and follower counts. Club and association administrators can also see the records of members affiliated with their organization.

5.2  With Service Providers

We work with trusted third-party vendors who process data on our behalf, including: cloud hosting and database providers; Clerk (sign-in and account security); RevenueCat (subscription management); PostHog (product analytics); Sentry (crash and error reporting); ImageKit (photo and video storage); Modal (cloud computers that run our technique analysis on your video, which is not kept after processing); OpenAI (powering the AI Coach, AI routine setup, technique feedback, AI-written match and practice summaries, monthly reports and pre-match insights); and Meta (advertising measurement, see Section 6). OpenAI only receives data after you allow it in the app, and you can turn this off at any time in Settings > AI Features. When allowed, OpenAI receives the text you send to these features, your first and last name, your opponents' first names, and relevant match results, ratings, practice scores and match notes. OpenAI never receives your videos, email, phone number or location, and it does not use this data to train its models. These providers are contractually bound to handle your data securely, with protections at least equal to those in this policy, and only for the purposes we specify.

5.3  With Clubs and Associations

When you join a club or association on CuePal, the administrators of that organization can view your profile, match records, and CGR. This sharing is necessary to provide the services you requested. You may leave an organization at any time through the app settings.

5.4  For Legal Reasons

We may disclose your information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of CuePal, our users, or others.

5.5  Business Transfers

If CuePal is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you in advance of any such transfer via email or a prominent notice on our platform.

6. Cookies and Tracking Technologies

Our website (cuepal.co) uses cookies and similar technologies to improve your browsing experience, analyze site traffic, and understand how visitors use our site. You can control cookie preferences through your browser settings or our cookie consent banner.

We use the following categories of cookies:

• Essential cookies: Essential cookies

   Required for the website to function. These cannot be disabled.

• Analytics cookies: Analytics cookies

   Help us understand how visitors interact with our site (e.g., pages viewed, time spent). Used only with your consent.

• Marketing cookies: Marketing cookies

   Used to deliver relevant content. Only set with your explicit consent.

Our mobile app does not use web cookies. It uses analytics and crash-reporting SDKs to understand how the app is used, and the Meta SDK to measure the effectiveness of our ads: it records app installs, app opens and account sign-ups, and our subscription provider shares trial and subscription events with Meta. On iOS, the Meta SDK only uses your device's advertising identifier if you allow it in the "Allow CuePal to track your activity" prompt; if you decline, Meta receives these events only for aggregated, non-identifying measurement. You can change this at any time (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads, where you can reset or delete your advertising ID). We do not show third-party ads in the app.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our services. Specifically:

• Account and activity data: retained while your account is active, and after you delete your account as described below
• Match and tournament records: retained for up to 5 years to maintain the integrity of ranking histories
• Support and communication records: retained for up to 3 years
• Legal compliance records: retained for the period required by applicable law

You can delete your account at any time in the app (Profile > Delete Account). Deletion happens immediately: your sign-in account is permanently deleted, so you can no longer sign in and the account cannot be recovered. You are removed from rankings, search and suggestions, and other players see you as "Deleted account". We keep the records of your past activity, such as matches, ratings, tournament results and messages you sent, so that other players' match histories and ratings stay correct, and for our own records. You can ask us to delete your remaining personal information at any time at contact@cuepal.co, unless we are required to keep it for legal reasons. If you sign up again later with the same email, you will start with a new, empty account.

8. Your Privacy Rights

Depending on where you are located, you may have the following rights regarding your personal information:

8.1  Rights for All Users

• Access: Request a copy of the personal information we hold about you
• Correction: Ask us to correct inaccurate or incomplete information
• Deletion: Request deletion of your account and associated personal data
• Objection: Opt out of marketing communications at any time

8.2  Additional Rights for EEA, UK & Switzerland (GDPR)

• Data portability: Receive your data in a structured, machine-readable format
• Restriction: Request we limit processing of your data in certain circumstances
• Objection to automated decision-making: Our CGR is calculated algorithmically; you may request a human review of any CGR dispute
• Lodge a complaint: With your local data protection authority

8.3  Additional Rights for California Residents (CCPA/CPRA)

• Know: Request details about the categories of personal information we collect and how it is used or shared
• Non-discrimination: We will not discriminate against you for exercising your privacy rights
• Opt-out of sale or sharing: We do not sell your personal information. We share limited app activity and device identifiers with Meta to measure our advertising, which may count as "sharing" under California law. You can opt out by declining tracking on iOS, limiting ad tracking on Android, or emailing contact@cuepal.co

To exercise any of these rights, please contact us at privacy@cuepal.co. We will respond within 30 days (or as required by applicable law).

9. Children's Privacy

CuePal is not directed at children under the age of 13 (or 16 in the EEA/UK). We do not knowingly collect personal information from children under these ages. If you believe we have inadvertently collected such information, please contact us immediately at privacy@cuepal.co and we will delete it promptly.

Users aged 13–17 should use CuePal only with parental or guardian consent. We encourage parents to monitor their children's online activity.

10. International Data Transfers

CuePal operates globally, including in English and Chinese (Simplified). Your information may be transferred to and processed in countries other than your own, including Canada, the United States, and other jurisdictions where our service providers operate.

When we transfer personal data from the European Economic Area (EEA), United Kingdom, or Switzerland to countries not deemed to provide an adequate level of data protection, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.

For users in China: we handle data in accordance with the Personal Information Protection Law (PIPL) of the People's Republic of China. Data collected from users in China may be stored locally or transferred internationally with your consent and subject to applicable cross-border data transfer mechanisms.

11. Security

We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Secure, hashed password storage
• Access controls limiting data access to authorized personnel on a need-to-know basis
• Regular security reviews and vulnerability assessments

No method of transmission or storage is 100% secure. If you become aware of any security concern relating to your account, please contact us immediately at security@cuepal.co.

12. Third-Party Links and Services

Our app and website may contain links to third-party websites or integrate with third-party services (e.g., Apple App Store, Google Play). We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies before providing them with any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated policy on this page with a revised "Last updated" date
• Notify you via email or an in-app notification for significant changes
• Where required by law, request your renewed consent

Your continued use of CuePal after the effective date of a revised policy constitutes your acceptance of the changes.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Privacy Enquiries

contact@cuepal.co

Security Issues

contact@cuepal.co

Mailing Address

CuePal Inc., Vancouver, British Columbia, Canada

Website

www.cuepal.co/contact

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