Privacy Policy

Last updated: 2026-06-28 · Version 5.0

Effective date: June 28, 2026

rivrplus Ltd. (“Company,” “we,” “us,” or “our”) operates the rivr+ mobile application (the “App”) and related services (together, the “Service”). This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and what rights you have over it.

Please read this policy carefully. By using rivr+, you acknowledge that you have read and understood it. If you do not agree, please do not use the Service.

This Policy should be read alongside our Terms of Service, which govern your use of the Service generally.

1. Who We Are & How to Reach Us

rivrplus Ltd.

Kiryat Ono, Israel, 5502703

Support: support@rivrplus.com

Privacy Contact / Data Protection Officer: info@rivrplus.com

User support: support@rivrplus.com

All other inquiries (legal, copyright, privacy rights): info@rivrplus.com

We are the data controller for personal data processed in connection with the Service.

2. What Data We Collect

We collect data in three ways: data you give us directly, data generated automatically when you use the Service, and data received from third-party sign-in providers.

2.1 Data you provide

CategoryExamples
Account informationUsername, email address, password (stored as a one-way cryptographic hash — we never store your plaintext password)
Profile informationDisplay name, first name, last name (optional), profile photo (optional), bio (optional)
User ContentPoker hands, hand descriptions, photos, screenshots, images from the Graphical Hand Builder, comments, votes, attachments such as solver charts and range visualizations
Club informationClub name, description, privacy setting (Public, Private, or Home Game), membership lists
Support communicationsMessages you send to support@rivrplus.com
Third-party sign-inName, email address, and unique identifier provided by Google or Apple when you use Sign in with Google or Sign in with Apple

2.2 Data collected automatically

CategoryExamples
Device & technical dataDevice type and model, operating system and version, app version, language/locale, time zone
Usage & analytics dataFeatures used, hands submitted, clubs joined or created, session length, screens viewed, in-app interactions, errors — collected via PostHog
Log dataIP address, request timestamps, crash reports, error logs — stored on Railway
Push notification tokenA device-level token used solely to deliver push notifications, collected only if you grant permission

2.3 Data we do NOT collect

Payment data
There is currently no paid tier. When a paid tier is introduced, payments will be processed entirely by Apple App Store or Google Play; we will receive only a confirmation that a purchase occurred, not your payment credentials.
Precise location
We do not request or store GPS or fine location data.
Contacts or address book
We do not access your device contacts.
Sensitive special-category data
We do not seek health, biometric, racial, political, or religious data. Do not submit such data through the Service.

3. Why We Collect It & Our Legal Basis

We process your personal data only where we have a lawful basis under applicable law, including Israel’s Privacy Protection Law 5741-1981 and Amendment 13, and the EU/UK GDPR, where applicable.

PurposeData usedLegal basis
Creating and managing your accountAccount information, sign-in dataPerformance of contract
Providing the core Service (hand sharing, clubs, feed)Account info, User Content, club dataPerformance of contract
Authentication and account securityAccount info, device data, log dataPerformance of contract; legitimate interests (security)
Delivering push notifications you have enabledPush notification tokenConsent (withdraw by disabling in device settings)
Analyzing usage and improving the ServiceUsage/analytics data via PostHogLegitimate interests (product improvement)
Detecting and preventing abuse and fraudLog data, usage data, User ContentLegitimate interests (security and integrity)
Responding to support requestsSupport communications, account infoPerformance of contract; legitimate interests
Complying with legal obligationsAny data required by lawLegal obligation
Displaying third-party advertising (see Section 9)Device data, general usage dataConsent where required (EU/EEA/UK: obtained via Google’s User Messaging Platform before personalized ads are served); legitimate interests otherwise

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Third-Party Sign-In (Google & Apple)

When you choose Sign in with Google or Sign in with Apple, the relevant platform authenticates you and shares a limited set of data with us (typically your name, email address, and a unique identifier). We use this solely to create or access your rivr+ account. We do not receive your Google or Apple password.

Your use of Google Sign-In is subject to Google’s Privacy Policy (policies.google.com/privacy). Your use of Sign in with Apple is subject to Apple’s Privacy Policy (apple.com/privacy).

5. Analytics — PostHog

We use PostHog to understand how users interact with the Service. PostHog receives usage events (for example, “hand submitted” or “club created”) along with device and session identifiers. It does not receive your name, email address, or User Content. We use PostHog for product analytics only; we do not use its session-recording feature.

PostHog processes data on our behalf under a Data Processing Agreement, and your analytics data is processed in PostHog’s EU region. Learn more at posthog.com/privacy.

We process analytics on the basis of our legitimate interests in understanding and improving the Service; analytics is integral to the Service and there is no in-app toggle to disable it. You may object to this processing at any time by contacting us at info@rivrplus.com (see Section 11).

6. Infrastructure & Hosting — Railway

The Service is hosted on Railway, which provides our application servers, primary database, and log management. User Content (such as hand images, screenshots, and profile photos) is stored on Cloudflare R2 object storage and delivered through the Cloudflare content delivery network. Railway and Cloudflare each process data on our behalf under a Data Processing Agreement. Backups may be replicated to a secondary region for resilience.

All data in transit is encrypted using TLS 1.2 or higher, and data at rest is encrypted using AES-256 via our infrastructure providers (Railway and Cloudflare) and the device OS.

7. How We Share Your Data

We do not sell your personal data. We share it only as described below.

7.1 With other users (as you direct)

Content posted to the main feed is visible to all rivr+ users. Content in a Public club is visible to all club members. Content in a Private or Home Game club is visible only to approved members. Your username and profile information are visible to other users in accordance with your privacy settings.

7.2 With service providers (sub-processors)

Sub-processorPurposeLocation
RailwayApplication servers, primary database, log managementEuropean Union
Cloudflare (R2 + CDN)Media storage (User Content) and image delivery / CDNGlobal (EU primary)
PostHogProduct analyticsEuropean Union
Google (Sign-In)AuthenticationGlobal
Apple (Sign in with Apple)AuthenticationGlobal
Firebase Cloud Messaging (Google)Push notificationsGlobal
ResendTransactional email (verification, password reset)Global
Google AdMobIn-app advertisingGlobal

We will update this table as our sub-processor list changes. Material changes will be communicated per Section 15.

7.3 Legal requirements and safety

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

7.4 Business transfers

If the Company is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a materially different privacy policy.

7.5 With your consent

We may share your data for other purposes with your explicit prior consent.

8. International Data Transfers

The Company is based in Israel. Israel has been recognized by the European Commission as providing an adequate level of data protection pursuant to GDPR Article 45 (adequacy decision). Accordingly, transfers of personal data from the European Economic Area (EEA) or the United Kingdom to Israel do not require additional safeguards.

Where the Company transfers personal data from the EEA, the UK, or Israel to sub-processors located in the United States or other third countries, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or other lawful transfer mechanisms, as our legal basis for such transfers. The sub-processors receiving EU/UK user data that are based in the US or process data outside the EEA include: Railway (application servers and primary database), Cloudflare (media storage and CDN), Firebase Cloud Messaging (push notifications), Google (Sign-In and AdMob), Apple (Sign in with Apple), and Resend (transactional email). Each of these sub-processors operates under a Data Processing Agreement that incorporates SCCs or equivalent safeguards.

By using the Service, you acknowledge that your personal data may be transferred to and processed in the United States or other countries outside your country of residence. We ensure all such transfers are subject to appropriate safeguards. You may request a copy of the applicable SCCs or further information about transfer safeguards by contacting us at info@rivrplus.com.

9. Advertising — Google AdMob

The App displays advertisements served by Google AdMob (“AdMob”). To deliver and measure ads, AdMob collects or receives the following data from your device: your advertising identifier (IDFA on iOS, GAID on Android), device type and model, operating system, screen size, language, IP address (used to infer general, non-precise location), and ad interaction data (impressions, clicks, and viewability metrics). AdMob processes this data under Google’s Privacy Policy (policies.google.com/privacy).

Where applicable law requires consent for personalized advertising — including in the EU, EEA, and UK — we use Google’s User Messaging Platform (UMP) to obtain your consent before personalized ads are served. If you do not consent, or if you are in a jurisdiction where we do not rely on consent, you will receive non-personalized ads that are not based on your interests or browsing behavior.

You may opt out of personalized ads at any time through your device’s advertising settings (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads), through the in-app consent dialog where available, or through Google’s Ad Settings (adssettings.google.com). Opting out does not remove ads from the App; it means the ads you see will not be tailored to your inferred interests.

We do not serve behaviorally targeted ads to users we know to be under 18. The App is configured to disable AdMob’s child-directed treatment flags because the Service is restricted to users aged 18 and older.

10. Data Retention

Data typeRetention period
Active account dataFor as long as your account is active
Deleted account dataPurged within 90 days of account deletion request, except where retention is required by applicable law
User Content (after account deletion)Removed from public display promptly upon account deletion; purged from backups within 90 days
Analytics events (PostHog)For as long as your account is active (not deleted)
Server and access logs (Railway)Up to 90 days
Support communications3 years from resolution
Payment and tax records (when applicable)7 years from transaction date, as required by Israeli tax law

11. Your Rights

11.1 Rights available to all users

Access
Request a copy of the personal data we hold about you.
Correction
Ask us to correct inaccurate or incomplete data.
Deletion
Request deletion of your account and data. You can also delete your account directly from the app’s Settings.
Objection
Object to processing based on legitimate interests.
Restriction
Ask us to restrict processing in certain circumstances.
Portability
Receive your data in a structured, machine-readable format.
Withdraw consent
Withdraw consent at any time for processing based on consent (for example, push notifications). You can opt out of personalized ads through your device’s advertising settings. Analytics is processed on the basis of legitimate interests, not consent — you may object to it as described above.

11.2 Israeli users

Under the Israeli Privacy Protection Law 5741-1981 and Amendment 13 (effective August 2025), you have the right to access, correct, and request deletion of personal data held about you. Contact info@rivrplus.com.

11.3 EU / EEA and UK users

Your rights under the GDPR and UK GDPR include those in Section 11.1. You may also lodge a complaint with your local supervisory authority. EU supervisory authorities: edpb.europa.eu. UK: ico.org.uk.

11.4 California users (CCPA / CPRA)

California residents have the right to know what personal information we collect and share (we do not sell it), to delete it, to correct it, and to non-discrimination for exercising these rights. Submit requests to info@rivrplus.com with the subject line “California Privacy Request.”

11.5 How to exercise your rights

Submit requests to info@rivrplus.com. We will respond within 30 days (or within the period required by applicable law) and may ask you to verify your identity.

11.6 Appeals

If you believe your data rights request was incorrectly denied or not handled appropriately, you may appeal by emailing info@rivrplus.com with the subject line “Privacy Rights Appeal” and a description of your original request and the basis for your appeal. We will review your appeal and respond within 30 days. You retain the right to lodge a complaint with your applicable supervisory authority at any time.

12. Children’s Privacy

rivr+ is not directed at children. You must be at least 18 years old to use the Service. We do not knowingly collect personal data from anyone under 18. If we learn we have done so, we will delete it promptly. If you believe a minor has provided us with data, contact info@rivrplus.com.

13. Security

We implement technical and organizational measures to protect your data, including:

  • TLS 1.2+ encryption for all data in transit
  • AES-256 encryption for data at rest via our infrastructure providers (Railway and Cloudflare R2)
  • One-way cryptographic hashing of passwords
  • Access controls designed to limit internal system access to authorized personnel
  • Commercially reasonable technical and organizational security measures, reviewed and updated periodically

No system is impenetrable. In the event of a breach likely to result in a high risk to your rights, we will notify you and the relevant authority as required by law.

14. Third-Party Links and Services

The Service may link to or integrate with third-party services. This Policy does not apply to those third parties. Please review their privacy policies independently.

15. Changes to This Policy

We may update this Policy from time to time. For material changes, we will notify you through the App, by email, or by updating the “Last updated” date. Continued use constitutes acceptance.

16. Contact

Privacy contact: info@rivrplus.com

General privacy inquiries: info@rivrplus.com

User support: support@rivrplus.com

rivrplus Ltd., Kiryat Ono, Israel, 5502703

Questions? Email info@rivrplus.com.