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Privacy Policy
Room 533 Games Ltd | South London Blackjack | Last updated: April 2026
1. Introduction
Room 533 Games Ltd ('we', 'us', 'our') is committed to protecting your privacy and ensuring your personal data is handled in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
This Privacy Policy explains how we collect, use, store, and protect your personal information when you use South London Blackjack, including our website at room533games.co.uk and our mobile application available on the Apple App Store.
2. Data Controller
Room 533 Games Ltd is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or how we handle your data, please contact us:
Email: info@southlondonblackjack.com
3. Information We Collect
We collect and process the following types of personal data:
3.1 Account Information
When you register to play South London Blackjack, we collect:
- Email address (used to create and manage your account)
- Display name / username (shown on the leaderboard and in multiplayer games)
- Password (stored in encrypted form via Firebase Authentication; we never see your plain-text password)
- Custom avatar image, if you choose to upload one
3.2 Gameplay Data
As part of delivering the game, we collect and store:
- Game scores and match results
- Leaderboard rankings
- Game history and session data
- In-game activity during multiplayer sessions (handled in real time via Socket.IO)
3.3 Purchase and Transaction Data
When you make in-app purchases, we collect:
- Records of purchases made through the Apple App Store, including items purchased and transaction dates
- Your virtual coin balance and transaction history within the app
Payment processing is handled entirely by Apple. We do not collect, store, or have access to your payment card details.
3.4 Advertising Data
We use Google AdMob to display advertisements in South London Blackjack. AdMob may collect:
- Device identifiers, including your Advertising Identifier (IDFA) if you have granted permission
- IP address and approximate location
- Information about your interactions with advertisements
- Device type, operating system, and app usage data
The data collected by AdMob is subject to Google's Privacy Policy, available at policies.google.com/privacy.
3.5 Information You Provide
If you contact us directly, we may collect:
- Your name and email address
- The content of your message or enquiry
3.6 Technical and Usage Data
We automatically collect certain technical information when you use our services:
- IP address
- Device type, operating system, and browser or app version
- Usage data, including how you navigate and interact with the game
- Crash reports and performance data
4. How We Use Your Information
We use your personal data for the following purposes:
- To create and manage your game account
- To deliver the multiplayer game experience, including real-time gameplay and leaderboard updates
- To display your display name and avatar to other players during games
- To process and fulfil in-app purchases and manage your virtual coin balance
- To deliver advertisements through Google AdMob, including personalised ads where you have given consent
- To maintain and improve the game and our services
- To respond to your enquiries and provide customer support
- To send you important service-related updates where you have consented
- To analyse usage patterns and improve user experience
- To detect and prevent fraud, cheating, or other misuse of the platform
- To comply with our legal obligations
5. Legal Basis for Processing
Under UK GDPR, we process your personal data on the following grounds:
- Contract Performance: Processing your account data, gameplay data, and purchase records is necessary to deliver the game services you have requested.
- Consent: Where you have given explicit consent, including consent to personalised advertising via the App Tracking Transparency prompt, and consent to receive marketing communications or to upload a custom avatar.
- Legitimate Interests: To improve our services, prevent fraud, and analyse usage, where these interests do not override your rights and freedoms.
- Legal Obligation: Where processing is required to comply with applicable law.
6. In-App Purchases and Virtual Currency
6.1 Purchases
South London Blackjack offers in-app purchases through the Apple App Store, including:
- Avatars: Cosmetic items that personalise your player profile
- Coins: Virtual currency that can be used within the app to acquire in-game items
All payments are processed by Apple. By making a purchase, you agree to Apple's Media Services Terms and Conditions. We do not store your payment details.
6.2 Virtual Currency (Coins)
Please read the following carefully regarding our virtual coin system:
- Coins are a virtual currency with no real-world monetary value.
- Coins cannot be transferred to other users, exchanged for real money, or redeemed outside of South London Blackjack.
- Coins are non-refundable except where required by applicable law or Apple's refund policy.
- We reserve the right to modify, suspend, or remove the virtual currency system at any time. We will provide reasonable notice where possible.
- Your coin balance may be lost if your account is deleted or if the app is discontinued.
7. Advertising and App Tracking Transparency
7.1 Google AdMob
We use Google AdMob to display advertisements within South London Blackjack. AdMob may serve both personalised and non-personalised advertisements depending on the permissions you grant.
7.2 App Tracking Transparency (ATT)
In accordance with Apple's App Tracking Transparency framework, when you first open South London Blackjack on iOS, you will be asked whether you consent to the app tracking your activity across other companies' apps and websites for the purpose of serving personalised advertisements.
- If you select 'Allow': AdMob may use your Advertising Identifier (IDFA) and other data to serve personalised ads tailored to your interests.
- If you select 'Ask App Not to Track': AdMob will serve non-personalised ads only. Your IDFA will not be used for advertising purposes.
You can change your tracking preference at any time in your device Settings under Privacy and Security > Tracking.
7.3 Opting Out of Personalised Ads
In addition to the ATT prompt, you can opt out of personalised advertising by Google at any time by visiting adssettings.google.com or by adjusting your device's advertising settings.
8. Third-Party Services
We use the following third-party services to operate South London Blackjack:
8.1 Firebase (Google LLC)
We use Firebase for user authentication, data storage, and file storage including custom avatars. See Google's Privacy Policy at policies.google.com/privacy.
8.2 Railway
Our game server, which handles real-time multiplayer connections via Socket.IO, is hosted on Railway. See Railway's privacy policy at railway.com/legal/privacy.
8.3 Google AdMob
AdMob is used to serve advertisements within the app. AdMob's data practices are governed by Google's Privacy Policy at policies.google.com/privacy.
8.4 Google Analytics
We use Google Analytics to understand how users interact with our website and app. You can opt out at tools.google.com/dlpage/gaoptout.
8.5 Apple App Store
If you download South London Blackjack via the Apple App Store, Apple may collect data in accordance with Apple's own Privacy Policy at apple.com/legal/privacy.
9. Leaderboard and Publicly Visible Data
Your display name and game scores appear on the South London Blackjack leaderboard, which is visible to all players. Please choose a display name you are comfortable sharing publicly. We do not display your email address or payment information to other players.
10. Data Sharing
We do not sell your personal data. We may share your information with:
- Service Providers: Third-party companies that help us operate our services, including those listed in Section 8. All third parties are required to handle your data in accordance with applicable law and our instructions.
- Advertising Partners: Google AdMob may receive data as described in Sections 3.4 and 7 for the purpose of serving advertisements, subject to your ATT consent.
- Legal Authorities: Where required by law, court order, or to protect the rights and safety of Room 533 Games Ltd, our users, or the public.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity. We will notify you in advance.
11. International Transfers
Your personal data may be transferred to and processed in countries outside the United Kingdom, including the United States, where our third-party service providers operate their infrastructure. Where we transfer your data internationally, we ensure appropriate safeguards are in place, such as:
- Standard contractual clauses approved by the UK Government
- Transfers to countries with adequacy decisions recognised by the UK
12. Data Retention
We retain your personal data only for as long as necessary:
- Account data (email, display name): Retained for the duration of your account, deleted within 30 days of account deletion.
- Gameplay data and scores: Retained for the duration of your account and removed from the leaderboard on deletion.
- Purchase and coin transaction records: Retained for 7 years to comply with financial record-keeping obligations.
- Custom avatars: Deleted within 30 days of account deletion or when you remove your avatar.
- Advertising identifiers: Managed by Google AdMob in accordance with Google's retention policies.
- Contact and support correspondence: 2 years from the date of submission.
- Analytics data: 26 months.
- Legal compliance records: As required by applicable law.
13. Account Deletion
You can delete your account at any time from within the South London Blackjack app or by contacting us at info@southlondonblackjack.com. On deletion:
- Your account, email address, and display name will be permanently removed within 30 days.
- Your scores will be removed from the leaderboard.
- Any custom avatar will be deleted from Firebase Storage.
- Your virtual coin balance will be permanently lost. Coins are non-refundable on account deletion except where required by law.
- Purchase transaction records will be retained for 7 years for legal compliance.
- Anonymised or aggregated data that cannot identify you individually may be retained for analytical purposes.
14. Your Rights
Under UK GDPR, you have the following rights:
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data ('right to be forgotten').
- Right to Restriction: Request that we restrict processing of your data.
- Right to Data Portability: Request transfer of your data to another organisation.
- Right to Object: Object to processing based on legitimate interests or direct marketing.
- Right to Withdraw Consent: Withdraw consent at any time, including your ATT advertising preference via your device settings.
To exercise any of these rights, contact us at info@southlondonblackjack.com. We will respond within one calendar month.
15. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- HTTPS encryption for all data in transit
- Firebase Authentication for secure, encrypted password management
- Access controls and authentication procedures for our systems
- Regular security assessments
- Staff and contractor awareness of data protection obligations
16. Children's Privacy
South London Blackjack is rated for users aged 4 and over on the Apple App Store. However, we do not knowingly collect personal data from children under the age of 13 without verifiable parental consent. In-app purchases require an Apple ID, which children under 13 cannot hold independently without Family Sharing and parental approval.
If you are a parent or guardian and believe your child under 13 has created an account without your consent, please contact us at info@southlondonblackjack.com and we will promptly delete the account and associated data.
17. Cookies
Our website at room533games.co.uk uses cookies and similar technologies to improve your browsing experience and analyse site usage. The South London Blackjack app does not use cookies but uses similar technologies for session management, analytics, and advertising as described in this policy.
18. Third-Party Links
Our website and app may contain links to third-party websites. We are not responsible for the privacy practices or content of those external sites. We encourage you to read the privacy policies of any third-party websites you visit.
19. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated 'Last updated' date. Where changes are material, we will notify you by email or through a notice in the app.
20. Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
We would appreciate the opportunity to address your concerns before you contact the ICO, so please contact us in the first instance at info@southlondonblackjack.com.
21. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us: