1. Who we are and what this covers
Growth Garage LLC, a limited liability company organized under the laws of the State of New Mexico, United States, is the controller of the personal information described in this policy. It covers the Blackjack Guru mobile app on iOS and Android, the web version of the app, and the website at www.blackjackguru.com, and for Blackjack Guru it replaces the general privacy policy previously published at growthgarage.studio.
Our contact details are in section 12, and you can reach us about anything in this policy at info@blackjacktrainingapp.com.
2. There is no account
This has two consequences worth understanding. The first is that the information we hold is not linked to your name, and in most cases we cannot connect it to you as a person. The second is that if you reset your device or move to a new device, the identifier changes and the previous progress cannot be recovered, because there is no account to log back into. Deleting and reinstalling the app on the same device normally keeps the same identifier, because it is associated with your device, so your progress usually survives a reinstall.
3. What we collect
- Information you give us
- Your email address and selected reason if you fill in the form on our cancellation page (stored in Airtable), and your email address and message if you write to us.
- Device and technical information
- The anonymous installation identifier, device model, operating system and version, app version, language, time zone, country or region derived approximately from your IP address, and crash and diagnostic reports.
- How you use the app
- Training activity and progress, session length and screens used, and Play section activity: chip balance, chips placed and settled, hands played, XP, and level.
- Purchases
- Which product was bought, price, currency, store, the transaction identifier issued by Apple, Google, or our payment provider, and subscription, trial, and refund status. We never receive your full payment card number.
- Advertising
- The ad networks we work with may collect your device advertising identifier (the IDFA on iOS, only where you allow tracking, and the Google Advertising ID on Android), your IP address, ad interaction data, and fraud detection signals, each under its own privacy policy. The named list is in section 5.
- This website
- The marketing pages run no analytics and set no advertising cookies. Our web server keeps standard request logs, and web fonts load from Google Fonts, which means Google receives your IP address.
We do not collect precise or GPS location, and we do not access your contacts, photos, microphone, or camera.
4. Why we use it, and our legal basis
If you are in the European Economic Area or the United Kingdom, the General Data Protection Regulation requires a legal basis for each purpose. Ours are:
- Running the app, saving and syncing your progress, and processing purchases and refunds
- Performance of our contract with you, and compliance with legal obligations such as tax and accounting.
- Diagnosing crashes, improving the app, and providing support
- Our legitimate interest in a working, improving product, and your consent where the law requires it.
- Preventing fraud, cheating, and refund abuse
- Our legitimate interest in protecting the Service, and compliance with legal obligations.
- Showing personalised advertising
- Your consent: the App Tracking Transparency prompt on iOS, and the consent tool shown in the European Economic Area and the United Kingdom.
- Showing non personalised advertising, and measuring our own marketing
- Our legitimate interest in funding a free app and knowing which marketing works, and your consent where required.
- Complying with the law and defending claims
- Compliance with legal obligations, and our legitimate interest in establishing or defending legal claims.
Where we rely on legitimate interests, you can object at any time: see section 10.
6. Advertising, and the choices you have
On iOS, the App Tracking Transparency prompt asks before any tracking identifier is used, and you can change your answer in Settings > Privacy and Security > Tracking. On Android, you can reset or delete your advertising ID and turn off ad personalisation in Settings > Google > Ads. In the European Economic Area and the United Kingdom, a consent tool built on the IAB Transparency and Consent Framework asks before any personalised advertising happens, and you can change your choices at any time in the app settings. Declining does not reduce the features available to you.
In United States states: we do not sell personal information for money, but personalised advertising can count as a sale, a share, or targeted advertising under state laws, and you have the right to opt out. Do so by turning off ad personalisation in the app settings, by limiting your advertising identifier as above, or by writing to info@blackjacktrainingapp.com with the subject line Do Not Sell or Share My Personal Information. On this website we honour the Global Privacy Control signal as an opt out. We do not knowingly sell or share the personal information of anyone under 18.
7. Where information is processed
We are based in the United States, and our service providers process information there and in other countries. Where information is transferred out of the European Economic Area or the United Kingdom, we rely on an appropriate safeguard, normally the European Commission’s Standard Contractual Clauses together with the United Kingdom Addendum, or an adequacy decision where one applies.
8. How long we keep it
- Progress and usage data held against your installation
- While the installation is in use, and for up to 24 months after the last activity.
- Chips you have bought, and paid entitlements
- For as long as your anonymous guest account exists, never deleted on a time based schedule, because chips you have bought do not expire. Removed only when you delete your data.
- Purchase records
- As long as required for tax, accounting, and disputes, typically seven years, set by law rather than by us.
- Crash and diagnostic data
- Up to 90 days.
- Support emails and cancellation form submissions
- Up to 24 months.
- Advertising identifiers and ad interaction data
- Held by each advertising network under its own policy, not by us.
9. Security, and age
We use measures appropriate to the information we hold, including encryption in transit and access controls, and we keep the amount of information collected small in the first place: not collecting your name is itself a security measure. No method of storage is completely secure, and if a breach affects your personal information and the law requires notification, we will notify you or the regulator within the time the law allows.
Blackjack Guru is for adults aged 18 and over, is not directed to children, and we do not knowingly collect information from anyone under 18. If you believe someone under 18 has used the app, write to us and we will delete the associated data.
10. Your rights, and deleting your data
Deleting your data
You delete your data in the app: open the More tab, then Delete my data. This deletes your local data and the cloud record held against your installation identifier. Deleting also removes any chip balance and unlocks, including chips that were bought, and cannot be undone. Purchase records are kept where the law requires, as described in section 8.
In the European Economic Area and the United Kingdom
You have the right to access, correct, and erase your personal information, to restrict or object to its use, to receive it in a portable format, to withdraw consent at any time, and to complain to your data protection authority. One honest caveat: because we hold nothing that identifies you, Article 11 of the GDPR may apply, and we may be unable to act on a request unless you give us the installation identifier from the app. We will always tell you if that is the position.
In the United States
Depending on your state, you may have the right to know what we have collected, to have it deleted or corrected, to opt out of sale, sharing, and targeted advertising, and not to be discriminated against for exercising those rights. In the statutory categories: we collect identifiers (installation identifier, advertising identifiers, IP address, shared with ad networks where you allow it, which may count as a sale or share), commercial information (purchases, not sold or shared), internet activity (app usage and ad interactions, ad interaction data shared with ad networks), and inferences (training difficulty, not sold or shared). We do not collect sensitive personal information.
Making a request
Write to info@blackjacktrainingapp.com. We respond within one month where the GDPR applies and within 45 days where a United States state law applies, in each case extendable as the law allows, and free of charge unless a request is manifestly unfounded or excessive. You may use an authorised agent. We do not make automated decisions that produce legal or similarly significant effects about you.
11. Changes to this policy
We will update this policy when what we do changes, in particular when an advertising network or another service provider is added or removed. The effective date at the top shows the current version, and we will give notice in the app or on this website before a material change takes effect. We keep dated copies of previous versions and will send you one on request.
12. How to reach us
- Controller
- Growth Garage LLC
- Form
- A limited liability company organized under the laws of the State of New Mexico, United States
- Registered address
- 2201 Menaul Blvd NE, STE A, Albuquerque, New Mexico 87107, United States
- Website
- www.blackjackguru.com
If you are in the European Economic Area or the United Kingdom and would rather raise something with a regulator, you can contact your national data protection authority, or the Information Commissioner’s Office in the United Kingdom. We would still rather hear from you first.