Privacy Policy of Blackjack Trainer

Latest update: December 31, 2025

Owner and Data Controller
CWTI Ltd
24 Tax Suite 137b Westlink House 981 Great West Road
Brentford, TW8 9DN, UK
UTR: 7166128503

Official app name: Blackjack Trainer
Contact: ivan@ivanmorgillo.com

Overview

Blackjack Trainer is a mobile application designed to help you memorize and train Blackjack basic strategy. User accounts and gameplay statistics can be stored securely on our backend servers (Cloud Firestore) to ensure your data is synced and backed up across devices. We use third-party services for authentication, advertising, analytics, and error monitoring.

Types of Data collected

Data stored on our servers

When you use Blackjack Trainer and choose to sync your data, the following data is stored on our backend servers:

• Account information: Basic profile information (such as email address and user ID) provided by your chosen sign-in method or identity provider.
• Activity Data: Your gameplay statistics, including hands played, accuracy, and rule set preferences.
• Authentication tokens: Stored securely to maintain your session.

Data collected automatically by third-party services

Personal Data may be collected automatically by third-party SDKs integrated into the app. These may include:

• Device information: e.g., device model, OS version, advertising ID (GAID/IDFA).
• Usage Data: e.g., app opens, ad interactions, and crash reports.
• Cookies and similar technologies: Used by advertising partners to personalize ads.

Mode and place of processing

Methods of processing

Data processing is carried out using IT-enabled tools and organizational procedures strictly related to the purposes indicated below. In addition to the Owner, the Data may be accessible to certain types of persons in charge (administration, legal, system administration) or external parties (e.g., third-party technical service providers, hosting providers) appointed, if necessary, as Processors by the Owner.

Place

Processing occurs at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own (e.g., to Google servers in the US).

Retention time

• Account and activity data: Retained as long as your account is active. You may request deletion of your account and associated data at any time by contacting the Owner via email.
• Third-party data: Retained according to the retention policies of the respective third-party services (Google, Sentry).

The purposes of processing

• Service Provision: To store your gameplay history and sync progress across devices.
• Authentication: To securely log you in using Firebase Authentication.
• Monetization: To display advertisements (via AdMob) which support the development of the app.
• Analytics: To understand app usage and improve the user experience (via Firebase Analytics).
• Stability: To monitor app crashes and errors (via Firebase Crashlytics) to fix bugs.

Third-party services we use

Authentication

Firebase Authentication (Google LLC)
Firebase Authentication facilitates sign-in services. It may simplify the login process by using third-party identity providers.
Personal Data processed: email address; device information; unique user identifier.

Hosting and Backend

Cloud Firestore (Google LLC)
Cloud Firestore is a NoSQL database service provided by Google. It stores your gameplay statistics and user profile.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Advertising

Google AdMob (Google LLC)
AdMob allows us to display advertisements to you. To do this, AdMob may use cookies and unique device identifiers (Advertising ID) to serve personalized ads based on your interests and previous interactions.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA); Usage Data.
How Google uses data

Analytics

Google Analytics for Firebase (Google LLC)
Firebase Analytics provides aggregated app measurement (e.g., app opens, session duration).
Personal Data processed: Usage Data; device information; advertising identifiers.

Error Tracking

Firebase Crashlytics (Google LLC)
Crashlytics helps us identify and fix crashes in real-time.
Personal Data processed: device information; OS version; stack traces.

Information on opting out

• Ads: You can opt out of personalized advertising by changing your device settings (e.g., “Opt out of Ads Personalization” on Android or “Allow Apps to Request to Track” on iOS).
• Account Deletion: You can request deletion of your account and all server-stored data by contacting us at ivan@ivanmorgillo.com.

“Do Not Sell or Share” and US state privacy disclosures

We do not sell Personal Information for money. However, under some US state privacy laws (e.g., California’s CCPA), allowing advertising partners (like AdMob) to collect identifiers for personalized advertising may be considered “sharing” or “selling.” You can opt out of this by disabling ad personalization in your device settings.

Children’s privacy

Blackjack Trainer is intended for a general adult audience. We do not knowingly collect personal data from children. If you believe a child has provided us with Personal Data, please contact us so we can take appropriate action.

Contact us

For any questions regarding this Privacy Policy or your data, please contact:

Ivan Morgillo
Email: ivan@ivanmorgillo.com