BlackJack: 21
Privacy Policy

1. Scope and operator

Gray Software Solutions, LLC ("Gray Software Solutions," "we," "us," or "our") operates BlackJack: 21. This Policy applies to the BlackJack: 21 mobile app on iOS (bundle identifier com.gss.blackjack) and Android (application identifier com.gsss.blackjack), and to this Privacy Policy page.

This Policy does not govern third-party websites, app stores, or services that have their own privacy policies. It also does not automatically apply to other Gray Software Solutions apps or pages that link to a different policy.

2. Information we process

The app does not request your name, phone number, physical address, contacts, photos, camera, microphone, health data, or precise GPS location as part of gameplay.

3. How we use information

We use information described above to:

• provide gameplay, save preferences, migrate legacy data, and maintain local progress;
• serve, attribute, measure, limit, and secure advertising in accordance with applicable consent choices;
• display products, validate chip purchases and optional tips, reconcile previous purchases, and deliver local virtual-chip rewards;
• understand app reliability, feature usage, and gameplay patterns when analytics is enabled;
• reduce replayed transactions, duplicate rewards, abuse, and security incidents;
• provide support and communicate about requests you initiate; and
• comply with law, enforce our rights, and protect users, the public, and our services.

Where applicable law requires a legal basis, we rely on consent for optional analytics and advertising choices; performance of a contract to provide purchases and requested services; legitimate interests in operating, securing, and improving the app; and compliance with legal obligations.

4. When information is shared

We do not sell personal information for money. We share information only as described in this Policy, including with service providers that operate features on our behalf, with app stores and advertising partners, when required by law, to protect rights and safety, or as part of a merger, financing, acquisition, or sale of assets subject to appropriate protections.

Advertising disclosures may be considered a "sale," "sharing," or use for targeted advertising under some United States state privacy laws even when no money is exchanged. You can use the controls described below to limit personalized advertising where available.

We require providers acting on our behalf to protect information consistently with their contractual obligations and applicable law. Their independent products and services are also governed by their own privacy terms.

5. Your choices and privacy rights

• App-usage analytics: On Android, use the persistent Privacy button in BlackJack: 21 to select or change Agree & Continue or No Thanks. On iOS, the Apple tracking choice controls optional Firebase/Meta measurement and can be changed in iOS Settings. Disabling collection stops future Firebase custom analytics and Meta install/activation events; information already processed may remain subject to provider retention rules.
• Advertising consent: Use consent controls presented by Google when available. You may also manage advertising or tracking settings through your device and Google My Ad Center or Meta ad preferences.
• iOS tracking: Change the app's tracking permission in iOS Settings under Privacy & Security > Tracking.
• Android advertising identifiers: Reset or delete the advertising ID using the controls available in Android Settings.
• Local game data: You can remove locally stored game data by clearing the app's data through your operating system or uninstalling the app. This can permanently remove your device-local chip balance and progress.

Depending on where you live, you may have rights to request access, correction, deletion, restriction, portability, or an explanation of personal information we control; withdraw consent; object to certain processing; opt out of targeted advertising, sale, or sharing; or appeal a decision. You will not be discriminated against for exercising applicable privacy rights.

To make a request, email us using the address below. BlackJack: 21 has no player account and does not ask for direct identity information, so we may be unable to connect an email address to a particular pseudonymous analytics, advertising, purchase, or installation record without additional information. We will use only information reasonably necessary to verify and fulfill your request. You may also contact the relevant provider directly for data it controls independently.

EEA, UK, and Swiss residents may lodge a complaint with their local data-protection authority. California and other eligible U.S. residents may use the same contact method to exercise applicable state-law rights and may designate an authorized agent where the law permits.

6. Retention and deletion

• Local data remains on your device until replaced by normal app operation, cleared through device controls, or removed by uninstalling, subject to operating-system backups.
• Analytics, attribution, and advertising data is retained under our configured Google and Meta provider settings and the providers' policies. We periodically review those settings and retain data only for the period reasonably needed for measurement, security, consent, and legal obligations.
• Purchase and reward records maintained by Apple, Google, and RevenueCat are retained under their policies and as needed for payment processing, Restore, refunds, fraud prevention, accounting, and legal obligations. The app's one-way duplicate hashes remain in local game data until that data is cleared or the app is uninstalled, subject to operating-system backups.
• Support messages are retained for as long as reasonably needed to resolve the request, maintain support and security records, and comply with law.

When data is no longer needed, we delete or de-identify it, unless continued retention is required or permitted for legal compliance, security, fraud prevention, dispute resolution, or enforcement.

7. Security and international transfers

We use reasonable administrative, technical, and organizational safeguards appropriate to the data, including encrypted network transport, native store validation, one-way hashing for selected transaction identifiers, and atomic duplicate-safe local processing. No method of storage or transmission is completely secure, so we cannot guarantee absolute security.

We and our providers may process information in the United States and other countries that may have different privacy laws from your country. Where required, transfers are made using recognized legal mechanisms and contractual safeguards.

8. Children

BlackJack: 21 is intended for adults age 18 and older and is not directed to children. We do not knowingly collect personal information from children. If you believe a child has provided personal information through the app or a support request, please contact us so we can investigate and take appropriate action.

9. Changes to this Policy

We may update this Policy to reflect changes to the app, providers, or legal requirements. We will update the date at the top of this page and provide additional notice or request renewed consent when required. Materially different data collection will not be covered retroactively by this Policy.