Blackjack Privacy Policy

Welcome to Blackjack, a premium single-player casino card table game developed and published by Newgates (“we”, “our”, or “us”). This Privacy Policy details our transparent data handling practices when you install, play, and interact with the Blackjack mobile application on Android devices (Google Play package name: co.newgates.blackjack).

Our philosophy is grounded in privacy by design: Blackjack is built so that you can enjoy classic casino card play against the house without surrendering your identity, phone number, contacts, location, or financial details. All graphics, cards, suit glyphs, and chips are rendered on-device with zero external video streaming or asset downloading. This policy is written to comply with Google Play Developer Program Policies, Google Play User Data policies, and applicable international data privacy standards.

Our technical design and data governance model for Blackjack adhere strictly to the following principles:

• No User Accounts: You do not need to create an account, log in with social media, or supply your name, email, or credentials to play.
• Strictly Simulated Gaming: The game provides simulated virtual chips only. We never solicit, accept, or process real-world monetary payments, bank cards, or crypto assets.
• Sandboxed Local Persistence: Your bankroll, hands won, career statistics, felt themes, and engagement state are saved 100% locally on your device via standard sandboxed Android SharedPreferences.
• Minimal Anonymous Diagnostics: Telemetry is strictly limited to aggregated game mechanics and crash reports to verify stability, frame rendering quality, and difficulty balance across diverse Android hardware.
• Zero Data Brokerage: We do not sell, rent, monetize, or trade any player data, telemetry, or device identifiers to third-party data brokers.

When you play Blackjack, limited non-personal technical telemetry and gameplay interaction events are automatically logged through integrated Google Firebase SDKs. We do not collect direct personal identifiers.

1. Anonymous Gameplay & Interaction Telemetry (Firebase Analytics)

To evaluate card shoe balance, verify payout rules, and ensure smooth round transitions, the game logs pseudonymous, aggregated in-game events:

• Core Game Events: Game session start (game_start), bet placement events (bet_placed with wager amount and remaining bankroll), hand deal events (deal_hand with wager, table difficulty, and felt theme), player actions (player_action with action type — Hit, Stand, Double Down, Split, Surrender — and active hand value), and round result events (round_result with outcome — Win, Loss, Push, Blackjack, Surrender — net chip gain, player total, and dealer total).
• Engagement & Virtual Economy Events: Daily streak bonuses claimed (daily_streak_claimed with streak day and coin quantity), passive coin tank harvests (coin_tank_claimed), table felt theme selections (theme_changed), AI dealer difficulty level switches (difficulty_changed), career statistics resets (career_stats_reset), and configuration debug inspections (config_debug_viewed).
• Screen Navigation: Anonymous screen transitions (Home Table, Settings, Difficulty Menu, Career Stats) logged via logScreenView.

2. Crash Diagnostics & Stability Logs (Firebase Crashlytics)

To diagnose and repair application crashes or unexpected engine exceptions across various device configurations, Firebase Crashlytics automatically collects:

• Stack traces, exception names, and runtime error logs.
• Device technical specifications: device manufacturer, model, Android OS version, architecture, orientation, free storage, and memory pressure state at the time of the fault.

3. Frame Rendering & Startup Performance (Firebase Performance)

Automated performance traces monitor cold application startup latency and UI frame rendering traces, ensuring card animations, chip stacks, and particle effects operate fluidly at 60/120 FPS across budget and flagship chipsets.

4. Device & Installation Identifiers

Standard operating system identifiers generated by Google Play Services and Firebase client libraries:

• Firebase Installation ID (FID): A pseudonymous identifier assigned to each app installation to coordinate telemetry dispatches.
• Firebase Cloud Messaging (FCM) Token: A temporary push token generated by Google Play Services for receiving game announcements or notification dispatches (if notification permissions are granted).
• Google Play Advertising ID (AD_ID): Merged by Google Play Services client libraries for aggregated audience measurement. Note: Commercial third-party advertisements are not active in the current application release. Players may reset or zero-out this identifier anytime in Android device settings.

We strictly limit our technical scope. Blackjack does not collect, process, inspect, or store any of the following sensitive data categories:

• Personal Identifiers: No full name, home address, physical location, telephone number, or email address.
• Financial & Banking Information: No bank account credentials, debit/credit card numbers, billing addresses, or payment service accounts. (The game contains no real-money transactions or store purchases).
• Precise or Approximate Geolocation: No GPS coordinates, cell tower triangulation, or Wi-Fi beacon location scanning.
• Hardware Sensors & Media: No camera access, microphone recording, audio capture, photo library access, or external storage reading.
• Communication & Contacts: No contact book reading, SMS messages, calendar entries, or call history.
• Biometric Data: No fingerprint, facial recognition, or biometric sensor telemetry.

All non-personal information collected is processed solely for lawful and technical operational purposes:

• Game Stability & Reliability: Pinpoint runtime errors, stack anomalies, and device-specific memory bottlenecks via Crashlytics.
• Balancing Gameplay Rules & Difficulty: Review win/loss/push ratios across Easy, Normal, Hard, and Master modes to ensure fair, authentic blackjack shoe distributions and mathematical fidelity.
• Passive Economy Balancing: Adjust default bankroll, hourly coin tank accumulation rates, and streak reward milestones via non-personal remote configuration.
• Local Engagement: Reschedule local notifications for full coin tank alerts and table re-engagement without relying on external tracking servers.
• Compliance & Security: Verify that app binaries operate securely, with TLS encryption for all outbound network calls.

Blackjack integrates a minimal set of proven, industry-standard third-party SDKs to deliver analytics, notifications, and diagnostics. Below are their technical disclosures and privacy policies:

Please note the following technical disclosures regarding advertising:

• Simulated Ad Dialog Disabled: Development builds contained an experimental in-game reward simulation; this component is completely inactive in production releases.
• Advertising ID (AD_ID): Declared or merged by Google Play Services client libraries for potential future ad attribution and aggregated audience metrics. If commercial advertising networks (such as Google AdMob) are introduced in future versions, this Privacy Policy will be promptly updated to disclose all ad partners, data practices, and consent management mechanisms prior to release.

Our virtual currency model complies with all Google Play Simulated Gambling guidelines:

• No Real-Money Gambling (RMG): In strict compliance with the Google Play Real-Money Gambling, Games of Chance, and Contests policy, this application does not allow users to bet, wager, or stake real money or tangible property on the outcome of a game.
• No Real Cash Value: In-game chips, bankrolls, streak rewards, and coin tank balances are purely fictional scorekeeping units. They cannot be exchanged, transferred, redeemed, or cashed out for real currency, goods, or services.
• No In-App Purchases (IAP): The application does not feature an in-game store, credit card processing, or real-money token purchases. Virtual chips are awarded entirely free through gameplay, rebuy mechanisms, daily bonuses, and passive coin tank generation.
• No Social Gambling / No Multiplayer Wagering: The game is strictly single-player against an on-device automated dealer AI. There are no multiplayer tables, peer-to-peer wagering mechanisms, or betting pools.
• IARC Rating Compliance: The game is officially classified under the International Age Rating Coalition (IARC) standard as containing “Simulated Gambling” for age rating purposes, accurately representing its casino card game aesthetic without involving real monetary stakes.
• Practice Does Not Imply Real Casino Success: Success or high virtual chip balances in this simulated game do not guarantee or imply future success at real-money gambling or casino table play.

Blackjack operates on a local-first, sandboxed storage architecture. All player progress and preferences are written exclusively to local Android SharedPreferences and are never uploaded to any remote server:

The Android manifest declares only the minimal set of permissions required for gameplay, audio-haptic feedback, and local engagement:

We apply strict retention limits to all categories of data:

• Local Progress & Preferences: Retained locally on your device indefinitely until you clear application data or uninstall the application.
• Firebase Analytics Telemetry: Retained in pseudonymous, aggregated form on Google Firebase servers for a maximum period of 14 months, after which it is automatically purged according to Google's standard data retention rules.
• Crash & Diagnostic Logs: Firebase Crashlytics retains crash traces and stack logs for up to 90 days to facilitate ongoing debugging, after which reports are automatically destroyed.

You have full autonomy over your data and local gameplay history:

• In-App Career Stats Reset: You can reset all career gameplay records, win rates, and statistics to zero directly from the in-app Settings screen by tapping the Reset Career Stats option.
• Complete On-Device Data Deletion: To instantly and permanently erase all local bankrolls, streaks, chip balances, and preferences, navigate to your Android device settings: Settings → Apps → Blackjack → Storage → Clear Data (or simply uninstall the game).
• Resetting Advertising ID: You can reset or delete your Google Advertising ID anytime via: Settings → Google → Ads → Reset/Delete Advertising ID.
• Opting Out of Notifications: You can revoke notification permissions at any time via Android system settings (Settings → Apps → Blackjack → Notifications).
• Formal Privacy Inquiries: If you have questions regarding your data or wish to exercise your rights under GDPR, CCPA, or other laws, contact us at newgates.developer@gmail.com.

We employ industry-standard technical measures to safeguard the integrity and confidentiality of all operational data:

• Encryption in Transit (HTTPS / TLS 1.3): All network communications — including Firebase Analytics transmissions, Crashlytics reports, and remote JSON configuration queries — are transmitted exclusively over encrypted HTTPS connections using modern Transport Layer Security (TLS 1.2 / 1.3).
• Sandboxed Android Storage: All SharedPreferences data files are stored in internal, application-private directories inaccessible to other applications installed on non-rooted Android devices.
• ProGuard / R8 Code Hardening: Release builds are obfuscated and code-shrunk using R8/ProGuard to prevent tampering, unauthorized reverse-engineering, and telemetry spoofing.
• No Plain-Text Storage of Sensitive Data: Because we collect no passwords, credit cards, or personal identities, there is zero risk of plain-text personal credential leaks.

Blackjack is designed for a general audience and is targeted at users 13 years of age and older (or 18+ where local simulated gambling regulations mandate). The application does not intentionally solicit, collect, or store personal information from children under the age of 13 (or under 16 in certain European jurisdictions):

• COPPA Compliance: We comply fully with the U.S. Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, please notify us at newgates.developer@gmail.com, and we will take immediate steps to delete any associated technical logs.
• Google Play Families Policy: The application is not part of the Google Play Designed for Families program and does not target children under the age of 13.

Regardless of your geographic location, we respect your fundamental privacy rights under major international privacy statutes:

1. European Economic Area (EEA) & UK (GDPR / UK GDPR)

Under the General Data Protection Regulation (GDPR), users in the European Union and United Kingdom have the following rights regarding personal data:

• The right to be informed about how data is collected and processed (fulfilled by this Privacy Policy).
• The right to access, rectify, or request erasure of personal data.
• The right to object to or restrict processing of personal data.
• The right to data portability and the right to lodge a complaint with a competent supervisory authority.

Our lawful basis for processing minimal pseudonymous diagnostics (Firebase telemetry and crash reports) is our legitimate interest in ensuring game stability, security, and gameplay balancing (Article 6(1)(f) GDPR).

2. California Residents (CCPA / CPRA)

Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• We do not sell personal information: We have not sold and will not sell player personal information to third parties.
• We do not share personal information for cross-context behavioral advertising: Commercial advertising is inactive in the application.
• California consumers have the right to request disclosure of categories of personal information collected and the right to request deletion of such information.

3. Brazil (LGPD)

Users in Brazil have equivalent rights of access, correction, anonymization, and deletion under the Lei Geral de Proteção de Dados (LGPD).

When reviewing the Data Safety section for Blackjack on Google Play, the table below reflects our audited data declarations:

We may periodically update this Privacy Policy to reflect changes in our gameplay features, legal obligations, or technical architecture. Any updates will be posted to this page with an updated “Effective Date”. Continued use of the application following the posting of an updated policy signifies your acknowledgment of the changes.