Your sessions. Your iCloud.

01

Who we are and how to contact us

WinLoss is provided by SPEAK OF THE LTD, company number 12426635, at Unit A, James Carter Road, Mildenhall Industrial Estate, Bury St. Edmunds, Suffolk, England, IP28 7DE. Contact us about the app or your privacy at apps@speakofthe.com.

This notice covers the WinLoss app for iPhone and iPad. Our website has a separate privacy policy covering its contact form and security checks.

We are responsible as controller for the support, analytics and diagnostic processing described below, whose purposes and means we decide. Keeping your records in your iCloud account does not make them public or create a WinLoss account. Apple also processes information to run its own iCloud, App Store and Maps services, under its own terms and privacy information.

• Email our privacy contact
• Website privacy policy

02

The information in your records

WinLoss stores what you enter. Depending on the features you use, that includes:

• Sessions: the casino, the game, buy-ins, cash-outs, the times you started and ended, notes, tags, comps and photos.
• Casinos you save, with their names and, if you choose one from Apple Maps, their address and location.
• Trips, with their dates, budget, currency and exchange rate, expenses and comps.
• Deposits and withdrawals, your loss limit, your session reminder and your other settings.

03

On your iPhone and in iCloud

Your records and their photos are kept on your iPhone and in your own private iCloud database, through Apple's CloudKit, when iCloud is available. There is no company-hosted database receiving a copy of your records or photos.

We have no administrator access to browse, read or retrieve the records in your private iCloud database. The app reads and writes them on your iPhone for your signed-in Apple Account. Settings and some working files stay on the iPhone, and may be included in backups made under your device settings.

Sync needs an Apple Account with iCloud turned on for WinLoss, available iCloud storage and a connection. Changes and deletions can take time to reach your other devices. Settings › iCloud in WinLoss shows how sync stands. Sync is not a backup: keep your own copy of anything important, for example an export.

04

Age

WinLoss is for adults aged 18 and over. Where the law requires it, the app asks Apple whether you are 18 or over through Apple's Declared Age Range feature. Apple tells the app only whether you are in the adult range; WinLoss does not receive your date of birth, keep the answer anywhere but on your iPhone, or send it to us.

05

Location

You can choose a casino's location through Apple Maps search; the search text is sent to Apple to find matching places. Its location is then saved with the casino, in your records.

If you turn on the reminder for when you arrive at a casino, iOS asks to allow location access, including Always. iOS watches for your arrival at your saved casinos on the iPhone, and WinLoss shows a notification. Your location is not sent to us or recorded in your sessions. You can change or remove location access at any time in iOS Settings.

06

Photos, camera, Face ID, notifications and widgets

You choose photos through the iOS picker, which gives WinLoss only the photos you pick, or take one with the camera if you allow it. WinLoss keeps a copy of each photo with the session, on your iPhone and in your iCloud. That copy is a JPEG without the photo's location or camera details, and it is the copy that goes to your iCloud and that you share. Saving a shared picture to your photo library uses the iOS permission for adding photos.

App Lock uses Face ID, Touch ID or your passcode through iOS. WinLoss only learns whether you were recognised; it never receives your face or fingerprint data.

Session reminders, arrival reminders and the reminder before a free trial ends are notifications scheduled on your iPhone. The app uses Apple's background CloudKit notifications for sync; it does not use a marketing push service.

Widgets, the Live Activity on the Lock Screen and in the Dynamic Island, Control Centre and Siri show or change your sessions on your iPhone, and can be visible when your iPhone is locked. Hide Amounts in Settings replaces amounts with dots.

07

Exports, reports and sharing

Exports (CSV and JSON), reports, trip recap cards and the year in review are made on your iPhone. They can contain amounts, casinos, dates and notes. Nothing is sent until you choose where through the share sheet, and the app you choose handles the copy under its own terms. A trip recap card leaves amounts out unless you choose to show them.

Copies saved or sent outside the app are independent: deleting a session, or WinLoss itself, does not delete files you saved elsewhere or copies other people received.

08

Usage analytics

WinLoss uses Google Analytics for Firebase to understand how the app is used, so we can fix problems and decide what to improve. Our events record things such as a session started or ended, a screen opened, a feature used, the paywall shown or a purchase made, with fixed values the app defines: the type of game, the screen, whether a session was a win, a loss or even, its length in broad bands, your currency code and the subscription plan.

These events never include amounts of any kind, casino or trip names, notes, tags, photos, your location or your records' identifiers, and WinLoss never sets a user ID. Firebase also processes its own app-instance identifiers, session and interaction information, device and app details, and an approximate country derived from IP information. This is pseudonymous information, not a promise of anonymity.

The app configuration disables advertising identifier collection, IDFV collection and advertising personalisation signals, and our Google Analytics property has Google signals, ads personalisation, granular location and data sharing with Google turned off. We do not sell your personal information or use your records to target advertising.

Analytics is always on in WinLoss; there is no setting in the app to turn it off. The website's cookie choices do not control the app.

• Google Analytics privacy information

09

Crash reports and app updates

Google Firebase Crashlytics receives crash and error information to help investigate faults: the device model, iOS and app version, the code that failed, an error's name and code, installation identifiers and recent analytics events. Crash reporting is always on, because it is how we detect and fix faults in the app.

The app removes the text of error messages before reporting them, so nothing you typed is included, and Crashlytics receives no user ID. Stack traces and device details can still be linked to an installation identifier, so we do not describe crash reports as anonymous.

Expo delivers app updates. Requests include technical information such as platform, project and runtime versions, installation and update identifiers, and network information including an IP address. These requests do not attach your records or photos.

• Firebase privacy and data processing
• Expo privacy policy

10

Purchases and contacting us

WinLoss Pro is bought through the App Store. Apple handles payment and your Apple Account; the app processes product and transaction identifiers, purchase and expiry dates and refund or revocation information to recognise Pro. We do not receive your payment-card details. Firebase records purchase events, such as the plan bought.

If you contact us, we receive your name, reply address and what you send, including an app version, screenshots or files if supplied. We use that information to answer you and investigate the issue. Please leave out amounts, passwords and payment details unless they are needed.

The website support form uses AWS to deliver messages to our support inbox and Cloudflare Turnstile to check for automated abuse. The website privacy policy explains the form's additional technical processing.

• Website and contact-form privacy

11

Purposes and lawful bases

Your records are processed on your iPhone and in your iCloud to provide the app. Where we process information to provide features or support you request, our basis is performing our contract with you, or taking steps you request before entering it. This includes recognising Pro and answering an enquiry.

We use legitimate interests for proportionate security, preventing misuse, investigating faults and managing correspondence, taking account of people's rights and expectations. We may retain or disclose information to meet legal obligations or establish, exercise or defend legal claims.

Understanding how the app is used, so we can improve it, is also a legitimate interest. We keep analytics to the events described above and do not use it for advertising or to profile you. Crash reports are collected only to detect and fix technical faults.

We do not use this information for solely automated decisions with legal or similarly significant effects on you.

12

Retention and deleting information

Your records stay until you delete them. You can delete a session, casino, trip or photo in the app. To delete everything, go to Settings › Your Data › Delete Everything: your records and photos go from your iPhone and, as it syncs, from your iCloud on all your devices, and your settings and reminders go back to how they were when you installed WinLoss. If iCloud is off for WinLoss at the time, what is already in your iCloud stays there; you can also delete it in iOS Settings under your name › iCloud › Manage Account Storage › WinLoss. Uninstalling alone does not delete iCloud records.

Deleting your data does not cancel a WinLoss Pro subscription, which belongs to your Apple Account, or erase Apple's transaction records or copies you sent elsewhere. It does not itself request deletion of data already received by analytics or crash-reporting services.

Google Analytics keeps event-level and user-level data for up to 2 months after an installation was last active; aggregated reports that do not identify an installation are kept longer. Google states that Crashlytics keeps crash traces and associated identifiers for 90 days before beginning removal from live and backup systems, rather than guaranteeing completed deletion on day 90. Expo keeps update-request information only for as long as reasonably necessary, as its privacy policy describes.

Support correspondence is kept as long as needed to resolve the enquiry and follow-up issues. Records needed for a complaint, legal obligation or claim may be kept longer, according to the issue and applicable time limits.

13

Providers and international transfers

The services involved are Apple for iCloud, the App Store, Maps, notifications and Face ID; Google for Firebase Analytics and Crashlytics; Expo for updates; and AWS, Cloudflare and our mailbox provider for website support. Services you choose for sharing receive information for those actions. Relevant information may also be disclosed to professional advisers or authorities where necessary for legal obligations or claims.

These services may process information outside the UK, including in the United States. We cannot promise UK-only storage. Google and Expo are certified under the UK Extension to the EU–US Data Privacy Framework, which UK law recognises as providing adequate protection, and Google also offers contractual safeguards through its data processing terms, which we have accepted. Contact us for details of the safeguards that apply to information we handle.

• Apple privacy policy
• Firebase privacy information
• Cloudflare privacy information

14

Your rights and choices

Under applicable data-protection law, you may ask for access, correction, erasure, restriction or portability of personal information. Email apps@speakofthe.com. These rights have conditions and exceptions; we may need information to verify your identity and locate records. We normally respond within one month and will explain any lawful extension.

You have a right to object to processing based on legitimate interests on grounds relating to your circumstances. Contact us to exercise it.

Your records are in your control: you can view, change, export or delete them in the app at any time. We may be unable to retrieve records held only in your iCloud, or associate pseudonymous diagnostics with you without further information; we will explain any limitation. Location, photos, camera, notifications and Face ID can each be turned off in iOS Settings; the feature that needs it then stops working.

You can complain to the UK Information Commissioner's Office without contacting us first, although we welcome the chance to resolve concerns. Where applicable, you can also contact your local data-protection authority.

• Contact us about your privacy
• Raise a concern with the ICO

15

Children and keeping data safe

WinLoss is for adults aged 18 and over and is not directed at children. Contact us if you believe a child has supplied information to us that should not be held.

Your records are protected by iOS and your Apple Account, and in iCloud by Apple's security. App Lock adds Face ID, Touch ID or your passcode when you open WinLoss, and Hide Amounts keeps amounts off your screen. Keep devices updated and accounts secure. No system is completely secure; we do not claim that every CloudKit field is end-to-end encrypted.

16

Changes to this notice

We will update this page when practices change and show the new date. Material changes will be brought to your attention in an appropriate way, such as the app's release notes. Where a new use requires consent, updating this notice will not replace that consent.