TrueCount Blackjack Privacy Policy
TrueCount Blackjack is a blackjack entertainment app. There is no real-money gambling: no cash-out, no prizes, and in-app credits have no real-world value. This policy explains what data the app handles, why, and your choices.
The short version
- We don't ask for your name, email, phone number, or any account. The app has no login.
- We don't track you across other apps or websites, and we never ask for tracking permission; the app does not use Apple's App Tracking Transparency framework because it has nothing to track.
- We don't sell data, and we don't use third-party analytics or crash-reporting services.
- Ads are optional and rewarded-only: they appear only when you choose to watch one, and they are contextual, not based on a behavioral profile of you.
- Your game progress is backed up to iCloud under an anonymous Apple-generated identifier so it survives reinstalls.
What the app collects, and why
Device and ad-serving data (Unity Ads). When you choose to watch a rewarded ad, our ad partner Unity Ads receives the technical data needed to serve and account for the ad: a device identifier (Apple's identifier for vendor), your approximate country-level location derived from your IP address, ad-interaction events (which ads were shown and watched), basic device characteristics (model, language, screen size, connection type), and SDK performance diagnostics. We configure Unity Ads in non-personalized, contextual-only mode: consent flags are set before the SDK starts so no behavioral-advertising profile is built, and the app never requests the iOS tracking permission. Unity's handling of this data is described in Unity's privacy notice.
Purchase and paywall data (Superwall). Our paywall provider Superwall receives anonymous purchase events (which credit pack was bought, subscription status), an anonymous device identifier, and paywall-interaction data, used to operate and improve the in-app store experience. We never send Superwall your identity; the app has no identity to send.
Game-progress backup (Apple iCloud/CloudKit). Your credit balance is backed up to our app's iCloud database under an opaque, Apple-generated account token (CloudKit user record name). This token lets the app restore your bankroll after a reinstall. The token does not contain your name or contact details. The app shows it to you as your "Support ID": if you share it with us in a support request, we may use it to look up your backup record and associate it with your inquiry; that is the only way we can connect this token to a person, and only because you chose to share it.
Purchases (Apple). Payment is processed entirely by Apple. We never see your payment details. A record of processed transactions is kept on your device to deliver credits exactly once and to support refund reversals.
Game Center. If you use leaderboards, Apple's Game Center provides the app with your Game Center display name and avatar to render the leaderboard. This data stays within Apple's Game Center service; we do not transmit it to our servers or to any third party.
Push notifications. The app registers for silent push notifications used by iCloud to deliver credit grants and backups. The device token involved is handled by Apple's notification service; we do not store it on any server of ours.
What the app does NOT do
- No real-money gambling, no cash-out, no conversion of credits to anything of value.
- No accounts, no directly identifying data: we never collect your name, email, phone number, contacts, photos, or precise location.
- No cross-app or cross-site tracking; no data broker sharing; no sale of data.
- No standalone analytics or crash-reporting SDK (no Firebase, Amplitude, Crashlytics, or similar). The Unity Ads and Superwall SDKs described above perform operational analytics limited to ad serving and paywall function; nothing else profiles your usage.
- No interstitial ads; ads play only when you choose to watch one.
Note on terminology: device identifiers and IP-derived approximate location are "personal data" under laws such as the EU GDPR even though they don't directly identify you. Where we say "no directly identifying data," we mean exactly that: the technical identifiers above are still handled as personal data with the protections this policy describes.
Legal bases (EEA/UK users)
Where the GDPR applies, we process the data above on these bases: performance of our contract with you (delivering the game, credits, and iCloud backup), and our legitimate interests in funding a free app through optional rewarded advertising and in operating a reliable purchase experience. We do not process special-category data. Because ads are contextual-only, we do not rely on consent-based behavioral advertising.
Retention and deletion
- iCloud backup records (credit balance under the anonymous token) are retained while you use the app so your progress can be restored. You can request deletion at any time (see Contact below) and we will remove your backup record; deleting the app and its iCloud data from your device's iCloud settings also removes your data from your iCloud account.
- Unity Ads and Superwall retain the operational data described above for the periods set in their published privacy policies; the criterion is what each vendor needs to serve and account for ads and operate the paywall, plus their legal retention obligations. We forward any deletion or access request we receive to the relevant vendor.
- On-device data (statistics, transaction records, preferences) stays on your device and in your personal iCloud sync; it is deleted when you delete the app and its data.
Your rights
Depending on where you live (including the EEA/UK under GDPR and California under CCPA/CPRA), you may have rights to access, correct, delete, or receive a copy of your personal data, and to object to or restrict certain processing. Because we hold almost nothing about you, most requests reduce to deleting your anonymous iCloud backup record; contact us and we will action it. We do not sell or share personal information as defined by the CCPA/CPRA. We do not discriminate against you for exercising your rights.
Children
TrueCount Blackjack is rated 18+ (frequent simulated gambling) and is not directed at children. We do not knowingly collect data from children.
Changes
We will post any changes to this policy at this URL with an updated effective date. Material changes will be summarized in the app's release notes.
Contact
Questions, requests, or complaints:
admin@monarchgames.io
Support: monarchgames.io/truecount