Privacy Policy

Last updated: October 14, 2026

This policy applies to the Pookie app and website operated by L70 Labs LLC, a Florida limited liability company.

1. Who we are

Pookie is operated by L70 Labs LLC, a Florida limited liability company ("L70 Labs LLC", "we", "us"). We are responsible for the personal information described in this policy. Contact: contact@l70labs.xyz.

This policy explains what we collect when you use the Pookie app, website and related services (the "Service"), why we collect it, who we share it with and the choices and rights you have.

2. Information we collect

Information you give us:

• account details: your email address (or the private relay email Apple provides if you use Sign in with Apple and hide your email), and the first name you choose;
• eligibility details: confirmation that you are 18 or older and your state of residence. We ask for your date of birth to check your age and store only the confirmation, not the date;
• shipping details: name, address and, if you give it, phone number, when you request shipping;
• messages you send to support.

Information created when you use the Service:

• your purchases, the packs you open and their results, the items in your vault, items you sell back or ship, and your Pookie credit balance and history;
• technical and usage information: an anonymous device or browser identifier, app and page events (such as opening the app, viewing a pack or starting a purchase), the referring link and campaign tags, device type, app version, and IP address recorded in our providers' security logs.

Information from others:

• Apple, when you use Sign in with Apple: a user identifier, your email or relay email, and your name if you choose to share it;
• Stripe, our payment provider: the result of your payment and limited payment details such as card brand and the last four digits. We never receive or store your full card number;
• shipping carriers: delivery status.

3. How we use it

We use personal information to:

• create and secure your account and let you sign in;
• confirm you are eligible (age and state) and enforce where the Service is offered;
• process purchases, open packs, maintain your vault and credit, and ship your items;
• provide support, send service messages (such as receipts, shipping updates and changes to our terms), and handle refunds and claims;
• detect, prevent and investigate fraud, abuse, chargebacks and security issues, and enforce our Terms;
• measure and improve the Service, including which features and campaigns bring people to it;
• with your consent where required, measure our advertising;
• comply with law, tax and accounting obligations, and respond to lawful requests.

If you are in the European Economic Area, the United Kingdom or Switzerland, our legal bases are: performance of our contract with you, our legitimate interests (security, fraud prevention, improving the Service), compliance with legal obligations, and your consent where we ask for it.

4. Who we share it with

We do not sell your personal information for money. We share it only with:

• service providers who run the Service for us under contract: Supabase (database, sign in and server hosting), Vercel (website hosting), Stripe (payments and fraud prevention), Apple (Sign in with Apple and app distribution), and our email provider for sign in codes and service emails;
• brands, authorized retailers and shipping carriers, only the name, address and contact details needed to deliver your items;
• advertising platforms such as Meta, only on our website and only if we enable their measurement tools: they may receive your browser's visit and purchase events to measure our ads. You can opt out as described in section 6;
• professional advisers, insurers and auditors, under confidentiality duties;
• authorities, courts or others when the law requires it, or to protect the rights, property or safety of our users, the public or us;
• a buyer or successor if our business is sold, merged or reorganized, subject to this policy.

5. How long we keep it

We keep account information while your account is open. When you delete your account, we delete or anonymize your personal information within 30 days, except records we must keep for legal, tax, accounting, fraud prevention or dispute purposes, such as purchase, payment and shipping records, which we keep for up to 7 years. Anonymous usage statistics may be kept longer.

6. Your choices

• Delete your account at any time in the app: Profile, then Delete account. You can also email us.
• Turn off advertising measurement on our website with your browser's Global Privacy Control signal, which we honor as an opt out of sharing for advertising, or by emailing us.
• Unsubscribe from any marketing email with the link in the email. Service messages about your account and orders are not optional while your account is open.
• Choose to hide your email with Sign in with Apple.

7. Your privacy rights

Depending on where you live, including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida and other states, and in the EEA, UK and Switzerland, you may have the right to: know and access the personal information we hold about you; correct it; delete it; receive a portable copy; opt out of the sale or sharing of personal information and of targeted advertising; limit the use of sensitive information; object to or restrict certain processing; and not be discriminated against for using these rights.

To make a request, email contact@l70labs.xyz from the email on your account. We will verify your request, and answer within the time the law requires (usually 45 days in the United States, one month in the EEA and UK). You may use an authorized agent where the law allows. If we deny your request, you can appeal by replying to our answer; if you remain unsatisfied you can contact your state attorney general or your data protection authority.

California notice. In the last 12 months we collected the categories described in section 2: identifiers, customer records, commercial information, internet activity, approximate geolocation from your state and IP address, and inferences used for fraud prevention. We collected them from the sources and for the purposes in sections 2 and 3, and disclosed them to the categories of recipients in section 4. We do not sell personal information for money. If we enable advertising measurement on our website, it may count as "sharing" for cross context behavioral advertising; you can opt out as described above. We do not knowingly sell or share the personal information of anyone under 16, and we do not use sensitive personal information to infer characteristics about you.

8. Security

We protect personal information with encryption in transit, access controls, row level security in our database, server side validation of every purchase and sign in session keys stored in your device's secure keychain. No system is perfectly secure, so we cannot guarantee absolute security. If a breach affects you, we will notify you as the law requires.

9. Children

The Service is only for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has given us information, email us and we will delete it and close the account.

10. International users

We are based in the United States and store information in the United States. If you use the Service from another country, your information is transferred to and processed in the United States, where protections may differ from your country. Where required, we rely on appropriate safeguards such as standard contractual clauses with our providers.

11. Changes to this policy

We may update this policy. The date at the top shows the latest version. For material changes we will notify you in the app or by email before they take effect.

12. Contact us

L70 Labs LLC, a Florida limited liability company. Privacy questions and requests: contact@l70labs.xyz.