Privacy Policy

1. Who we are

This Privacy Policy explains how L'Extase Ltd collects, uses, shares, stores and protects personal information when you use No Jokers: Black Jack. L'Extase Ltd is the controller for the processing described here unless stated otherwise. L'Extase Ltd Company number: 12431763 Registered office: 128 City Road, London, EC1V 2NX, United Kingdom Privacy and support enquiries: support@nojokers.co.uk

2. Scope

This Policy applies when you install or use the App, create or use an account, sign in through supported providers, play games, use multiplayer, leaderboards or tournaments, purchase or use Coins, use virtual items and social features, communicate with players, contact support, submit reports, visit associated No Jokers web services or otherwise interact with the Service.

3. Information we collect directly

Depending on your use, we may collect username, display name, email address, date of birth, age or age category, profile image, account identifiers, authentication provider, account creation date, account status, country or approximate region and account preferences. We seek to collect only information reasonably necessary for the relevant purpose.

4. Age and date of birth

We may process date of birth or derived age status to determine age, apply age appropriate functionality and privacy settings, protect younger users, manage communications, comply with law or platform requirements and determine access to restricted features. Where greater certainty is reasonably required for a higher risk feature, additional proportionate age assurance may be used.

5. Authentication providers

If you use Sign in with Apple, Facebook Login or another supported authentication service, we may receive information permitted by that provider and authorised by you, such as an authentication identifier, name, email address, profile information or authentication tokens. We do not receive your password for those third party services. The provider separately processes information under its own privacy terms.

6. Guest accounts

Guest accounts may use device, installation or guest profile identifiers to associate gameplay and account information with the relevant guest account. Guest accounts can still involve personal information even where less directly identifying information is collected.

7. Gameplay data

We may process games played, game modes, cards played, turns, outcomes, wins and losses, scores, ranking points, leaderboard position, tournament participation, match history, opponents, achievements, streaks, rewards, gameplay statistics, disconnections, abandoned matches, duration, matchmaking information and other gameplay events. This supports game operation, rankings, matchmaking, integrity, support, abuse investigations and product development.

8. Coin and virtual item data

We may process Coin balances, purchases, earnings, rewards, Coin entry, wins, losses, spending, transaction history, purchase identifiers and balance adjustments. We may also process virtual gifts sent or received, badges, cosmetic items, room access, digital purchases and unlocked content. No Jokers Coins are virtual game currency, not a monetary account.

9. Purchase data

Where you purchase digital content, we may process the item or Coin package, price, currency, transaction identifier, purchase date, payment status, refund status, store or platform, receipt or validation information and fraud or transaction risk information. Where Apple, Google or another payment provider processes the transaction, that provider handles the payment information necessary to complete it. We generally do not receive full payment card details when the app store or payment provider handles payment.

10. Social and communication data

Where available, we may process friend lists, invitations, blocked users, social connections, profile visibility settings, direct messages, table chat, preset messages, reactions, reports, moderation information and associated metadata. Communications may be processed to deliver features, respond to reports, enforce Terms, protect users, detect abuse, prevent exploitation and comply with law. Private communications should not be assumed to be immune from lawful moderation, safeguarding or legal access.

11. Multiplayer match recordings, saved games, replays and highlights

When you participate in a multiplayer match, No Jokers automatically records information about that match. This recording enables the multiplayer match saving, replay and highlight sharing features available through the Service. A multiplayer match record may include your username and player identifier; the usernames and player identifiers of other participants; cards dealt and cards played; turns and in game actions; game events; scores and match results; relevant gameplay statistics; timestamps and match identifiers; and other gameplay information reasonably necessary to record, reconstruct and replay the match. Where this information relates to an identifiable player, we treat it as personal information.

11.1 Why we record multiplayer matches

We process multiplayer match records to provide multiplayer gameplay; allow participating players to save matches; provide saved match history and replay functionality; allow players to revisit previous matches; enable players to generate and share highlight clips; maintain rankings and gameplay statistics; investigate cheating, collusion or exploitation; investigate reports and complaints; resolve gameplay disputes; provide customer support; maintain the integrity and security of No Jokers; enforce our Terms and Conditions; and troubleshoot, maintain and improve the Service. For processing necessary to provide the multiplayer recording, saving, replay and sharing functionality requested as part of the Service, our lawful basis will generally be performance of our contract with you. For related processing involving game integrity, security, cheating prevention, dispute resolution and protection of the Service and its users, we may rely on our legitimate interests where those interests are not overridden by the rights and interests of affected users. We give particular consideration to the rights and interests of children where younger users are involved.

11.2 Saved matches

Players who participated in the same multiplayer match may save that match within their No Jokers account. This means that another participant may retain access through No Jokers to a recording of a match containing your username and gameplay. Saved matches may be available through match history or other replay functionality provided by the Service. We may impose reasonable retention, storage or availability limits on saved matches.

11.3 Replays

Participating players may replay a saved match through No Jokers. A replay may reproduce cards, turns, actions, results and other events from the original match and may display the usernames of participating players. We may control when a replay becomes available and which information is displayed where reasonably necessary to prevent cheating, collusion or unfair competitive advantage.

11.4 Highlight clips

A participating player may use No Jokers to generate a short highlight clip from a recorded multiplayer match. A highlight may include your username, gameplay, in game actions, cards or game events appearing within the relevant sequence, match result, virtual items or reactions and other information displayed as part of that gameplay sequence. Highlight clips are designed to contain information forming part of the multiplayer gameplay experience. They are not intended to include your email address, date of birth, payment information, authentication credentials or private account security information.

11.5 Sharing highlights outside No Jokers

Participating players may share authorised highlight clips outside No Jokers using compatible sharing options available through their device. These may include WhatsApp, Messages, email, social media and other compatible applications or services. When a player chooses to share a highlight through an external service, the selected third party service and the recipient may independently process the shared content according to their own terms and privacy practices. A recipient may also save, forward, copy or reshare that content. Once another player has lawfully shared a copy outside No Jokers, L'Extase Ltd may not have the technical ability to identify, retrieve or delete every subsequent external copy. This does not remove or limit our obligations under applicable data protection law in relation to processing for which L'Extase Ltd remains responsible.

11.6 Children and multiplayer recordings

Multiplayer recordings may contain usernames and gameplay belonging to younger users. We therefore take age appropriate privacy and safety considerations into account when operating replay and sharing functionality. We may apply additional restrictions to the visibility, accessibility, retention, generation or external sharing of recordings or highlights involving child accounts where reasonably necessary to protect younger users or comply with applicable law. We will not intentionally include additional account information in a shared highlight merely because that information is held elsewhere within No Jokers.

11.7 Retention of match recordings

We retain identifiable match records for as long as reasonably necessary to provide saved match and replay functionality; provide highlight functionality; maintain appropriate gameplay records; support game integrity; investigate cheating or abuse; resolve disputes; provide customer support; maintain security; and meet legitimate legal or enforcement requirements. The retention period may vary according to the type of record and the reason for which it is retained. We may delete, anonymise or aggregate match information when identifiable information is no longer reasonably required. Deleting your No Jokers account does not necessarily cause copies of highlight clips previously shared outside No Jokers by other players to be deleted from recipients' devices or third party services.

11.8 Your data protection rights

Personal information contained in multiplayer match recordings remains subject to the data protection rights described in this Privacy Policy. Those rights are not absolute. For example, we may have a lawful reason to retain particular match information where it is reasonably necessary to investigate cheating or abuse, resolve a dispute, protect another user's rights, meet a legal obligation or establish, exercise or defend legal claims. Privacy requests can be made to support@nojokers.co.uk.

12. Support, reports and enforcement

If you contact support or submit or receive a report, we may process names, email addresses, account identifiers, correspondence, screenshots, attachments, device information, complaint information, report categories and descriptions, relevant communications and gameplay records, moderation history, technical logs, enforcement decisions, appeals and evidence reasonably necessary to investigate and resolve the matter.

13. Device and technical information

We may collect device type and model, operating system and version, App version, language, time zone, IP address, device or installation identifiers, session identifiers, network information, crash logs, performance and diagnostic information, security events and server logs. This information is used to operate, secure, troubleshoot and improve the Service. Where advertising is enabled, this may include your device's advertising identifier, as described in section 24.

14. Location

We may infer approximate location from technical information such as IP address for localisation, regional functionality, security, fraud prevention, legal compliance and general Service analysis. We will not collect precise location unless there is a genuine product need, an appropriate lawful basis and appropriate user information or permission. Non essential location tracking for children will be disabled by default.

15. Information we generate

We may generate player level, ranking, skill or matchmaking rating, fraud indicators, cheating indicators, moderation status, age category, account risk status and behavioural or gameplay statistics. Such information may be personal data where it relates to an identifiable user.

16. Information from other users and sources

We may receive information about you when another user sends a friend request or virtual gift, reports your account, refers to your username in a support matter or interacts with you in multiplayer gameplay. We may also receive authentication and transaction confirmation data from platforms or service providers. We use such information only for appropriate Service related purposes.

17. Why we use personal information

Purposes include account creation and authentication, gameplay, multiplayer services, matchmaking, leaderboards and tournaments, maintaining Coin balances, processing digital purchases, rewards and virtual gifts, social features, customer support, child protection and age appropriate restrictions, fraud and cheating prevention, abuse investigation, moderation, enforcement, security, technical diagnosis, performance analysis, Service improvement, legal compliance and establishing, exercising or defending legal rights.

18. Lawful bases

We rely on different lawful bases depending on the processing. Contract may apply where processing is necessary to create and operate an account, provide gameplay, maintain Coin balances, provide purchased content, matchmaking and requested support. Legitimate interests may apply to securing the Service, preventing fraud and cheating, maintaining integrity, improving performance, understanding use, preventing abuse, enforcing Terms and protecting users and the business, provided those interests are not overridden by individual rights. Legal obligation may apply to valid legal, accounting, consumer protection or safeguarding requirements. Consent is used where the law requires consent for a particular activity.

19. What happens if you do not provide information

Some personal information is necessary to create or operate an account or provide requested functionality. If you do not provide information that is necessary for a contractual feature, we may be unable to provide that feature. Optional information does not have to be provided unless clearly stated. Where age information is required for safety or legal reasons, failure to provide sufficient age information may result in restricted access.

20. Privacy acknowledgement and consent

Acknowledging this Privacy Policy does not mean you consent to every processing activity described. Where consent is legally required, it will be requested separately. You may withdraw consent at any time where processing relies on consent, without affecting processing lawfully carried out before withdrawal.

21. Children and the Children's Code

No Jokers may be accessed by children. We therefore aim to take account of the UK Children's Code and other applicable child privacy requirements. Protections may include high privacy by default, reduced profile visibility, restrictions on direct messaging or communications with unknown users, limits on data sharing, profiling, location processing and personalised marketing, simplified privacy information and additional age appropriate controls.

22. Best interests and high privacy by default

When developing features likely to affect children, we consider their best interests in relation to personal data processing. We will not intentionally design privacy settings to encourage children to provide more information than reasonably necessary. Where an account is identified as belonging to a child, privacy settings should provide a high level of protection by default unless a compelling, lawful and child appropriate reason justifies otherwise.

23. Age assurance and parental involvement

Age assurance measures may be used where proportionate to risk, and we aim to collect no more information than reasonably necessary for that purpose. If age cannot be established with sufficient confidence for a restricted feature, access may be restricted. Where legally required or appropriate, parents or guardians may be provided with relevant information or controls, depending on age, law, device and platform.

24. Marketing, advertising and push notifications

24.1 Marketing

We will not knowingly use children's personal information for direct marketing where inappropriate or unlawful. Where electronic marketing requires consent, we will obtain it and provide an unsubscribe mechanism.

24.2 Rewarded advertising

The App uses Google AdMob, provided by Google, to show optional rewarded video advertisements. You choose whether to watch a rewarded video, and in return you may receive Coins or another in-game reward. You do not have to watch advertisements to play. A daily limit applies to rewarded videos.

24.3 Information processed for advertising

When an advertisement is requested or shown, Google may process information such as your device's advertising identifier where permitted (the Identifier for Advertisers on iOS or the Android Advertising ID), IP address, approximate location derived from IP address, device type, operating system, App information, and information about the advertisements shown and your interactions with them. Google may use this information to deliver and measure advertisements, limit how often they are shown, prevent fraud and, where you have consented, personalise advertisements. Google acts as an independent controller for some of this processing. You can find out more at https://policies.google.com/technologies/partner-sites.

24.4 Crediting rewards

When you finish a rewarded video, Google sends a signed confirmation to our servers containing a transaction reference and an identifier we generate for that reward. We use it to confirm that the video was completed and to credit your reward once. Our lawful basis for this is performance of our contract with you.

24.5 Consent

Where the law requires consent, including for players in the United Kingdom, the European Economic Area and Switzerland, we show a consent message provided through Google's consent management tools before advertisements are requested. You can consent, decline or manage your choices. If you decline, you may still be offered rewarded videos, but they will be non-personalised or limited advertisements that do not use your information for personalisation. Where the law requires consent to store or access information on your device, or to personalise advertising, we rely on your consent, which you may withdraw at any time.

24.6 Apple App Tracking Transparency

On iOS, we ask adult players for permission through Apple's App Tracking Transparency prompt before your device's advertising identifier can be accessed for tracking. If you do not allow tracking, the advertising identifier is not made available and advertisements will not be personalised using it. You can change this at any time in your device's Settings under Privacy & Security, then Tracking.

24.7 Children

Accounts identified as belonging to someone under 18, and accounts without a confirmed age, receive non-personalised advertisements only, with Google's protections for children and users under the age of consent applied. We do not request App Tracking Transparency permission for these accounts. Reward offers linked to advertising, such as doubling a daily wheel reward, and time-limited reward offers based on activity, are not offered to these accounts.

24.8 In-game reward offers

We may use information about your gameplay and purchase activity, such as how recently you have played or made a purchase, to decide whether to offer adult players time-limited in-game reward offers. These offers are delivered to the App inbox and, where push notifications are available and enabled, by push notification. They use only information we hold and do not involve sharing your information with advertisers. You may ignore any offer. Our lawful basis is our legitimate interest in encouraging continued play, balanced against your rights, and this processing does not produce legal or similarly significant effects.

24.9 Managing your choices

Where the option applies to you, you can review or change your advertising consent choices at any time through the App's Settings. On Android, you can reset or delete your advertising identifier in your device settings. Push notifications require applicable device permission and can be controlled through device settings.

25. Analytics, cookies, SDKs and similar technologies

We may use analytics to understand app performance, crashes, gameplay usage, feature adoption, retention, technical issues and general Service performance. The App or associated website may use cookies, SDKs, local storage, device identifiers, pixels, server logs and similar technologies. Strictly necessary technologies may operate without optional consent where lawful. Non essential technologies requiring consent will not be activated until appropriate consent has been obtained. The App uses the Google Mobile Ads SDK and Google's User Messaging Platform to provide rewarded advertising and to collect advertising consent, as described in section 24.

26. Who we share information with

We may share personal information with service providers that help operate No Jokers, including cloud hosting and database providers, authentication providers, payment platforms and app stores, advertising providers, analytics and crash reporting providers, customer support and email providers, security and fraud prevention providers, content moderation providers and professional advisers. Providers acting on our behalf are expected to handle information consistently with applicable data protection requirements.

27. Current service providers

Replit provides application hosting and infrastructure. The underlying production database is provided by Neon. Resend provides transactional email delivery, including password reset communications. Firebase, provided by Google, handles authentication processing across supported sign-in methods. Apple provides App Store distribution, Sign in with Apple, and payment processing through StoreKit. Google provides Google Play distribution, Play Billing payment processing, Google AdMob for rewarded advertising through which users may earn Coins, and, where enabled, Google Sign-In. Meta Platforms provides Facebook Login where enabled. GoDaddy provides domain registration and hosts email associated with nojokers.co.uk, including support@nojokers.co.uk. This disclosure will be updated if production processors materially change.

28. Legal disclosures and corporate transactions

We may disclose personal information where reasonably necessary to comply with law or a valid court or authority request, protect a person's rights or safety, investigate fraud or serious abuse, protect children, establish or defend legal claims or secure the Service. In a genuine sale, reorganisation, financing or transfer of the business or Service, relevant information may be disclosed to advisers and transaction parties subject to appropriate confidentiality and data protection measures.

29. International transfers

Some providers may process information outside the United Kingdom. Where a restricted international transfer occurs, we will use an appropriate lawful transfer mechanism where required, such as applicable adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses or another lawful mechanism, together with supplementary safeguards where appropriate. You may contact support@nojokers.co.uk for information about applicable safeguards.

30. Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for legitimate legal, security, accounting, fraud prevention and dispute resolution purposes. Account data is generally retained while an account remains active. After deletion, some information may be deleted or anonymised while limited records may be retained for legal obligations, security, fraud prevention, accounting, chargebacks, disputes or user protection. Gameplay, communication and purchase data have retention periods based on operational, safety, legal and accounting needs.

31. Security

We use appropriate technical and organisational measures designed to protect personal information. Measures may include encrypted transmission, controlled access, authenticated administrative access, database security, secure password handling, security logging, environment separation, access management, vulnerability management, backups, incident response and contractor or staff access controls. No digital system can guarantee absolute security. Passwords, where used, should be stored using appropriate cryptographic password hashing rather than readable plain text.

32. Personal data breaches

If a personal data breach occurs, we will assess it and take appropriate action. Where UK law requires notification to the Information Commissioner's Office or affected individuals, we will make the required notification.

33. Your data protection rights

Depending on the circumstances, you may have rights to be informed, access personal data, rectify inaccurate data, request erasure, restrict processing, receive applicable data in portable form, object to certain processing, withdraw consent and exercise rights relating to automated decision making. These rights are subject to legal conditions and exemptions. Requests may be sent to support@nojokers.co.uk and we may reasonably verify identity before responding.

34. Right to object

Where we rely on legitimate interests, you may have the right to object to processing. We will consider your circumstances and whether compelling legitimate grounds justify continued processing. You have an absolute right to object to direct marketing. Contact support@nojokers.co.uk to exercise an applicable objection right.

35. Automated decision making and profiling

We may use automated systems to assist with matchmaking, fraud and cheating detection, moderation, security, ranking and account risk detection, and to decide eligibility for in-game reward offers. Most support game operation and are not intended to produce legal or similarly significant effects. Where solely automated processing produces legal or similarly significant effects and applicable law imposes additional requirements, we will provide required information and safeguards. Profiling involving children receives particular care.

36. Your right to complain

If you have concerns about our processing, contact support@nojokers.co.uk so that we can investigate. You also have the right to complain to the Information Commissioner's Office, the UK's independent data protection supervisory authority.

37. Changes to this Policy

We may update this Policy for changes to the Service, technology, functionality, law, regulatory guidance, security or providers. The latest version will display its effective date. Material changes will receive appropriate notice. New processing requiring consent will not be justified merely by changing this Policy, and consent will be obtained separately where required.

38. Records of notices and acknowledgement

We may maintain records showing which version of this Privacy Policy was presented or acknowledged by an account. This supports transparency, compliance records and dispute resolution.

39. Contact

For privacy, data protection and general support enquiries contact: L'Extase Ltd Company number: 12431763 128 City Road London EC1V 2NX United Kingdom Email: support@nojokers.co.uk