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Privacy Policy
Effective date: 06 December 2025
This Privacy Policy explains how MORTECHA (Windmühlenstrasse 1, 53111 Bonn, Germany) processes information when you use Premium Blackjack Trainer (“App”) or visit our support pages. By using the App you agree to the practices described here. If you disagree, please do not use the App. MORTECHA is the data controller for processing described in this policy.
Data we collect
On-device training data
Hands played, accuracy, preferred rules/language, and other configuration values are stored locally on your device via AsyncStorage so the App can display past performance and remember your settings. We do not copy this data to our own servers.
Subscription and purchase data
When you buy a subscription Apple or Google share purchase tokens with RevenueCat, Inc., our in-app purchase partner. RevenueCat provides us with an anonymous App User ID, your active products, renewal status, country/currency, and billing platform so we can unlock premium content. We cannot see your full name, email address, or payment details.
Diagnostics and crash data
Apple and Google may provide us with aggregated crash reports or performance metrics if you opted in to share analytics with them. We use these reports only to debug issues and improve stability.
Support interactions
If you email info@mortecha.com or call us, we will receive the contact information and any details you include so we can answer your request.
Purposes and legal bases
- Provide and personalize the App (training progress, settings): performance of the contract (Art. 6(1)(b) GDPR).
- Process purchases, manage entitlements, prevent fraud: performance of the contract and our legitimate interests (Art. 6(1)(b) & 6(1)(f) GDPR).
- Respond to support requests: performance of the contract and legitimate interests (Art. 6(1)(b) & 6(1)(f) GDPR).
- Diagnose crashes or misuse: legitimate interests (Art. 6(1)(f) GDPR).
- Fulfil legal obligations (billing records, tax rules): Art. 6(1)(c) GDPR.
Third parties and processors
Apple Inc. (App Store) and Google LLC (Google Play Store): handle payments, account authentication, and store any billing information you provide. Their privacy policies apply to that data.
RevenueCat, Inc.: processes purchase receipts and subscription status on our behalf (privacy policy: https://www.revenuecat.com/privacy/).
We do not share or sell data with advertisers, social networks, or data brokers.
Storage and retention
On-device training data stays on your device until you delete it through the in-app reset option, uninstall the App, or erase your device.
RevenueCat keeps subscription records for as long as necessary to confirm entitlements and comply with applicable accounting rules. Contact us if you would like your App User ID to be reset.
Support emails are kept only for as long as needed to resolve your request and to comply with statutory retention duties (usually six years under German commercial law).
International transfers
We are based in Germany but rely on service providers that may process data in the United States or other countries. When we transfer data outside the EU/EEA, we rely on measures such as the EU Commission’s Standard Contractual Clauses or equivalent safeguards to protect your information.
Security
We use industry-standard safeguards including transport encryption, limited access to RevenueCat dashboards, and device-level security features provided by iOS and Android. No system is 100% secure, so please keep your device locked and updated.
Your rights
Under GDPR you may request access, rectification, deletion, restriction, portability, or object to processing. Because most data is stored on your device, you can erase it by uninstalling the App or using your device settings. For subscription data handled through Apple/Google/RevenueCat, contact us and we will help facilitate your request. You also have the right to lodge a complaint with your local supervisory authority (e.g., Landesbeauftragte für Datenschutz NRW).
California residents have the right to know, delete, and opt out of the sale or sharing of personal information; we do not sell or share personal information for cross-context advertising.
Children
Premium Blackjack Trainer is intended for adults interested in casino strategy training. The App is not intended for real-money gambling and is aimed at adults who are legally allowed to enter casinos in their jurisdiction. We do not knowingly collect personal data from children under 16. If you believe a child has provided us information, contact us so we can delete it.
Changes
We may update this Privacy Policy to reflect product, legal, or regulatory changes. We will post the new version in the App and update the effective date. Continued use of the App after the update means you accept the revised policy.
Contact
MORTECHA
Windmühlenstrasse 1, 53111 Bonn, Germany
Email: info@mortecha.com
Phone: +49 177 4249237