Privacy Policy of Blackjack Trainer

Latest update: November 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

Overview

We do not create user accounts or collect contact information.
We do not maintain our own backend for user data and do not store user data on our servers.
Gameplay statistics are stored locally on the device. If the app is uninstalled, such local data is lost.
We display ads and use third-party SDKs solely to deliver ads, basic analytics (e.g., app starts, sessions), and crash diagnostics.
Third-party services we integrate may process device identifiers and usage data. See “Third‑party services we use.”

Types of Data collected

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

Advertising identifiers (e.g., Google Advertising ID or IDFA)
Device information (e.g., device model, OS version, app version)
Usage Data (e.g., app opens, session duration, approximate location inferred from IP)
Crash data and diagnostics
Trackers and similar technologies used by third-party services

We do not directly collect names, email addresses, or other contact details, and we do not run our own analytics servers.

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, in some cases, 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, analytics and advertising 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. For details, see the privacy policies of the third‑party services referenced below.

Retention time

Local gameplay statistics are stored only on the User’s device and are deleted when the app is uninstalled or app data is cleared.
Third‑party services retain Data according to their own retention policies. See their respective privacy policies.

The purposes of processing

Provide advertising within the app
Monitor basic app usage for aggregate analytics
Improve stability and investigate crashes

Third‑party services we use

Advertising — AdMob (Google)

AdMob is an advertising service provided by Google. AdMob may use advertising identifiers, cookies, and similar technologies to deliver, measure, and improve ads, including interest‑based ads where permitted.

Personal Data processed: Trackers; usage data; unique device identifiers for advertising (e.g., AAID/IDFA); device information.

Place of processing: Global, with primary processing commonly in the EU/US (see Google’s notices).

How Google uses data from partners · Ads personalization controls (Android)

Analytics — Google Analytics for Firebase (Google)

Firebase Analytics provides aggregated app measurement (e.g., app opens, sessions). We do not configure custom event tracking for individual user interactions beyond basic app usage.

Personal Data processed: Trackers; usage data; device information; advertising identifiers (where available).

How Google uses data from partners

Crash reporting — Firebase Crashlytics (Google)

Crashlytics helps us understand crashes and stability issues.

Personal Data processed: crash data; diagnostics; device information; an app instance identifier.

How Google uses data from partners

Information on opting out of interest‑based advertising

Use device settings to limit or reset advertising identifiers and opt out of ads personalization. See: Google support
Use the Digital Advertising Alliance’s AppChoices app to control interest‑based ads in mobile apps: AppChoices
Where available, use a user‑enabled global privacy control (GPC). We will honor such requests in a frictionless manner where applicable.

Legal bases for processing (EEA/UK/CH)

Where required, we rely on consent for the use of advertising identifiers and cookies/Trackers for interest‑based advertising and analytics. In limited cases, we may rely on legitimate interests (e.g., ensuring app stability via Crashlytics), provided such interests are not overridden by Users’ rights and interests.

Children’s privacy

Blackjack Trainer is intended for a general adult audience and is not directed to children. Users must comply with applicable laws regarding gambling-related content. 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.

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

We do not sell Personal Information for money. We do not maintain a data marketplace or exchange your Personal Information for consideration beyond using standard third‑party services to operate the app.
However, under some US state privacy laws (e.g., California), certain disclosures of identifiers to advertising partners to facilitate cross‑context behavioral advertising may be deemed a “sale” or “sharing.” Our use of AdMob could fall within these definitions.
Users can opt out of interest‑based advertising through the methods described above, and we honor user‑enabled Global Privacy Control signals where applicable.
We do not process Sensitive Personal Information for the purpose of inferring characteristics.

California (CCPA/CPRA) rights (and similar US state rights)

Know, access, and obtain a portable copy of specific pieces of Personal Information
Correct inaccurate Personal Information
Request deletion of Personal Information
Opt out of the sale or sharing of Personal Information and of targeted advertising
Limit use and disclosure of Sensitive Personal Information (where applicable)
Be free from discrimination for exercising your rights

To exercise your rights, contact us at [email protected]. We will verify your request and respond within the timeframes required by applicable law.

EEA/UK/Switzerland — your rights

Subject to conditions and exceptions, you have the rights to access, rectify, erase, restrict or object to processing, and data portability. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. You also have the right to lodge a complaint with your local supervisory authority.

Brazil (LGPD) — your rights

Brazilian Users may have rights including confirmation of processing, access, correction, anonymization, blocking, deletion, data portability, information about sharing, and revocation of consent, among others, as provided by law.

International transfers

Third‑party service providers may process data in multiple countries. Where required, such transfers occur subject to appropriate safeguards (e.g., Standard Contractual Clauses) as described in those providers’ policies.

Security

We take appropriate technical and organizational measures to prevent unauthorized access, disclosure, modification, or destruction of Data. No method of transmission or storage is 100% secure; we strive to protect your information but cannot guarantee absolute security.

Additional information about Data collection and processing

We may provide Users with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

Changes to this policy

We may update this policy to reflect operational or legal changes. We will post the updated policy within the app and/or on our website. Please check this page periodically and note the latest update date above.

Contact us

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

Notes:
– We do not create user accounts, collect emails, or run our own user databases.
– Local gameplay stats remain on your device; uninstalling the app removes them.
– Third‑party SDKs (AdMob, Firebase Analytics, Crashlytics) may process certain identifiers and usage data to provide ads, basic analytics, and crash diagnostics.