Security & Data Protection Policy

1. Purpose

Tiltwise is committed to protecting user data and maintaining a high standard of security across all systems and services.

This policy outlines how we approach data security, what information we collect at different stages of the platform, and the measures we take to safeguard user information.

2. Data Minimisation

Tiltwise follows a data minimisation approach.

At the pre-launch and early access stage, we collect only the information required to provide the service, such as:

• email addresses for waitlist registration

• user-provided content such as hand histories, journal entries, or notes

We do not collect unnecessary personal data.

3. Hand History Privacy and Anonymisation

Tiltwise recognises that poker hand histories may contain sensitive or personally identifiable information, including player aliases and table identifiers.

To protect user privacy:

• hand history data is treated as confidential user content

• Tiltwise does not publicly expose raw hand histories

• users are provided with options to anonymise player names and identifying details within hand history data

Where anonymisation is enabled:

• opponent names may be replaced with generic identifiers

• hand data may be stored or displayed in a non-identifying format

Users retain control over whether hand histories are stored or reviewed in anonymised form.

4. Data Storage and Encryption

User data is stored using secure, cloud-based infrastructure.

Where appropriate:

• data is encrypted at rest

• data is encrypted in transit using industry-standard protocols

Access to production systems is restricted and protected using secure authentication practices.

5. Access Control

Access to user data is limited to authorised systems and personnel only.

We apply the principle of least privilege, ensuring access is granted only where necessary for development, maintenance, or support purposes.

6. Proactive Security Practices

Tiltwise takes a proactive approach to security.

We regularly:

• review system architecture and access controls

• monitor dependencies and third-party packages for known vulnerabilities

• apply security updates and patches in a timely manner

• follow established best practices for secure software development

Security is treated as an ongoing process and is continually reviewed as the platform evolves.

7. Desktop Application Security

The Tiltwise desktop application is designed with security and isolation in mind.

It:

• operates independently of poker client software

• does not access live game data

• does not capture screen contents

• does not read poker client memory or network traffic

Its primary purpose is background file management and user-initiated uploads.

8. AI Processing and Analysis

Where AI-based analysis is used, it operates on user-provided data only.

Analysis is performed:

• on completed hands or sessions

• after data has been uploaded or manually entered

• without access to live gameplay or real-time decision-making

AI systems do not act autonomously and do not initiate actions on behalf of users.

9. Third-Party Services

Tiltwise may rely on trusted third-party infrastructure providers for hosting, storage, analytics, or processing.

We select providers that adhere to recognised security standards and limit data sharing to what is required for service operation.

We do not sell user data or share personal information with third parties for advertising or marketing purposes.

10. Incident Response

We take security incidents seriously.

In the event of a data breach or security issue that poses a material risk to users, we will:

• investigate promptly

• take appropriate corrective action

• notify affected users where required

11. User Responsibility

Users are responsible for safeguarding their account credentials and ensuring their own devices are secure.

Tiltwise cannot guarantee security where access credentials are shared or devices are compromised outside of our control.

12. Policy Updates

This Security & Data Protection Policy may be updated as Tiltwise evolves.

Any material changes will be reflected on this page to maintain transparency as the platform develops.