Privacy Policy

Roulette Ace is a statistical analysis and entertainment application operated by CodeCraft Solutions LLC ("we", "us", or "our"). This Privacy Policy explains how we collect, use, and protect information when you use the Roulette Ace mobile application ("App").

By using the App, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

We do not collect, store, or process any of the following:

• Account information — no user accounts exist
• Email addresses
• Payment information — all billing is handled entirely by the Apple App Store or Google Play Store; we never see or store your payment details
• Advertising identifiers
• Usage analytics or behavioral tracking
• Device contacts, photos, or files

We share data with the following third parties only as described:

• Google Firebase Crashlytics: Receives anonymous crash diagnostic reports to help us fix bugs. No personal data or gambling history is included. Governed by Google's Privacy Policy.
• Google Places API: Receives your device location (when you initiate a casino search) to return nearby casino results. This is a one-time per-search query; your location is not stored or tracked by us.
• OpenStreetMap — Overpass API: Receives your GPS coordinates and search radius as a fallback service to find nearby casinos. This is a free, open-source mapping service operated by the OpenStreetMap Foundation. No personal data is stored. Governed by OpenStreetMap's Privacy Policy.
• OpenStreetMap — Nominatim: Receives your GPS coordinates or search text for geocoding (converting coordinates to place names and vice versa). No personal data is stored. Governed by OpenStreetMap's Privacy Policy.
• Wikipedia API:When you search for a casino, its name may be sent to Wikipedia's public API to retrieve general casino information. No personal data is stored. Governed by the Wikimedia Foundation Privacy Policy.
• RevenueCat: Manages in-app subscriptions and validates purchases. When you purchase or restore a subscription, RevenueCat receives a device identifier, your purchase receipt data, and the app version. RevenueCat does not receive your roulette data, location, or personal information. Governed by RevenueCat's Privacy Policy.
• Apple App Store / Google Play Store:Handle all subscription billing and payment processing. We do not receive or store any payment information. Subject to Apple's and Google's respective privacy policies.
• Google Analytics 4 (Website only): This website uses Google Analytics 4 to understand aggregated visitor behavior (page views, traffic sources, general geography). GA4 uses anonymized identifiers and does not collect personally identifiable information from visitors. Data is governed by Google's Privacy Policy.

We do not sell, rent, or trade your personal information. We may disclose information if required by law or to protect the safety of users or the public.

• All App data (sessions, spins, casino records, bankroll figures) is stored locally on your device and encrypted using SQLCipher, a widely used encrypted SQLite library.
• The encryption key is stored in your device's secure enclave, which means it cannot be extracted even if your device is compromised.
• We operate no user accounts and maintain no server-side storage of your App data. We have no technical ability to access your spin history, session records, or bankroll data.
• Crash report data retained by Firebase Crashlytics is governed by Google's Privacy Policy.

• Session, casino, and bankroll data stays entirely on your device. We cannot access it, and it is never transmitted to any server.
• Crash reports are used solely to identify and fix bugs in the App.
• Location data is used only in the moment of a casino search request and is not retained by us.

Under the EU General Data Protection Regulation (GDPR), we process your information on the following legal bases:

• Contract performance: Processing subscription and purchase data via RevenueCat and the App Stores is necessary to provide the premium subscription you have purchased.
• Legitimate interest: Anonymous crash reporting via Firebase Crashlytics is processed under our legitimate interest in maintaining a stable, functional application. You may opt out at any time (see Section 11).
• Consent:Location data for the Casino Finder feature is processed only with your explicit permission, granted via the device's location permission prompt. You may revoke this consent at any time in your device settings.

• Local app data (sessions, spins, bankroll, casino records): Retained on your device until you delete it via Settings → Privacy & Data → Delete My Data, or until you uninstall the App.
• Crash reports (Firebase Crashlytics): Retained by Google for up to 90 days from the date of the crash, after which they are automatically deleted.
• Subscription records (RevenueCat): Retained for the duration of your subscription and as required for tax, accounting, and legal compliance after cancellation.

Some of our third-party processors (Google Firebase, Google Places API, RevenueCat) are located in the United States. When data is transferred from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States, we rely on:

• Standard Contractual Clauses (SCCs) approved by the European Commission, as implemented by Google and RevenueCat in their respective Data Processing Addenda.
• EU-U.S. Data Privacy Framework where applicable.

You may request copies of the relevant SCCs by contacting us at help@codecraftsolutionsllc.com.

• Roulette Ace offers a free tier with limited features and a premium subscription at $2.99/month.
• All billing is handled exclusively by the Apple App Store or Google Play Store. We never receive, process, or store your payment information.
• You may cancel your subscription at any time through your App Store or Play Store account settings. Access continues until the end of the current billing period.

Depending on where you live, you may have the following rights regarding your personal information:

• Right of access: Request a copy of any personal data we hold about you.
• Right to rectification: Request correction of inaccurate or incomplete data.
• Right to erasure (“right to be forgotten”): Delete your local app data via Settings → Privacy & Data → Delete My Data. For crash data, contact help@codecraftsolutionsllc.com.
• Right to restrict processing: Request that we limit how we process your data (e.g., pause crash reporting).
• Right to object: Object to processing based on legitimate interest, including crash reporting.
• Right to data portability: Export your data as a JSON file via Settings → Privacy & Data → Export all my data.
• Right to withdraw consent: Where processing is based on consent (e.g., location), you may withdraw it at any time in your device settings.
• Right to lodge a complaint: EU/EEA residents may lodge a complaint with their local data protection supervisory authority. A list is available at edpb.europa.eu/about-edpb/about-edpb/members_en.

Because the majority of your data is stored only on your device, exercising these rights is largely under your direct control through the App's settings. For any rights that require our action (crash data opt-out, SCC copies, complaints), contact us at help@codecraftsolutionsllc.com. We will respond within 30 days as required by GDPR.

In addition to the rights described in Section 11, residents of specific jurisdictions have rights under their local privacy laws. Roulette Ace honors these rights worldwide regardless of where you reside.

Roulette Ace is intended for users who are 18 years of age or older. The App is not directed to children, and we do not knowingly collect, use, or disclose personal information from anyone under the age of 18.

COPPA Compliance (United States):We comply with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13 in the United States.

GDPR Compliance (EU): We do not knowingly collect personal information from children under 16 in the European Union (or the applicable lower age limit set by individual EU member states, which may be as low as 13).

If we learn that we have inadvertently collected personal information from a minor, we will delete that information promptly. If you believe a minor has used the App or that we may hold personal information about a minor, please contact us at help@codecraftsolutionsllc.com and we will take appropriate action within 30 days.

Roulette Ace is a mobile application and does not use:

• Cookies
• Web beacons or pixels
• Advertising identifiers (IDFA, AAID)
• Cross-app or cross-device tracking
• Behavioral or targeted advertising
• Third-party analytics SDKs that profile users
• Session replay or heatmap tools

The only automated data collection is anonymous crash reporting via Firebase Crashlytics, as described in Section 2. No tracking technology is used to build a profile of you or your behavior across apps, websites, or devices.

This privacy policy covers the Roulette Ace mobile application. The rouletteace.app website uses Google Analytics 4 cookies, governed by a separate Cookie Policy.

Roulette Ace performs statistical analysis of roulette spin data using on-device machine learning models (Markov Chain, Bayesian, XGBoost, Transformer-LSTM, CNN, and Ensemble engines). These predictions are:

• Generated entirely on your device
• Based solely on the spin data you manually enter
• Not transmitted to our servers or any third party
• Used only for entertainment and statistical analysis purposes
• Not used to make decisions about you, profile you, or determine any service eligibility, pricing, or treatment

You are not subject to any decision based solely on automated processing that produces legal or similarly significant effects concerning you under Article 22 of the GDPR.

We may update this Privacy Policy from time to time. Changes will be posted within the App and on our website with an updated effective date. Continued use of the App after changes constitutes acceptance of the revised policy.

If you have questions or concerns about this Privacy Policy, please contact us:

Data Protection Inquiries: For any privacy-related question, data subject request, or complaint, email help@codecraftsolutionsllc.com with the subject line “Privacy Request” and we will respond within 30 days.