Last Updated: 27/01/2026

1. Introduction

Royal Draw ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we handle information when you use our iOS application (the "App").

2. Data Collection Practices

2.1 What We Do NOT Collect or Transmit

Our application does NOT:

• Collect personal identifiers (name, email, birthdate, etc.)

• Track usage analytics or behavior

• Access or store location data

• Access contacts, photos (except what you explicitly choose), or other personal media

• Require internet connectivity or connect to any servers/APIs

• Use cookies, beacons, or tracking technologies

• Integrate third-party analytics, advertising, or social media SDKs

• Store any data externally or in the cloud

2.2 Camera Usage

The App requests access to your device's camera only for the following purpose(s):

• To detect and classify playing cards

Important: All camera processing occurs locally on your device:

• Camera images/video are processed in real-time and never saved to our servers (we have no servers)

• Images are not transmitted over the internet

• We do not access, view, or retain any camera data

3. Local Storage Only

Any data you create within the app (such as saved preferences, game progress, or user-generated content) is stored exclusively on your personal device using Apple's local storage frameworks. This data never leaves your device and is not accessible to us. You may delete this data at any time by uninstalling the app.

4. Camera Permission Details

• One-time permission: iOS will ask for camera access the first time the feature is used

• You control access: You can enable/disable camera access at any time via iOS Settings > Royal Draw

• No background access: The camera is only accessed while you are actively using the pertinent feature in the app

• Minimal data access: The app only accesses the camera feed temporarily for immediate processing

5. Age Rating

This application is rated 4+ ("Made for Ages 4 and Up") in all countries and regions where it is available for download. The app contains no inappropriate content, ads, in-app purchases, or data collection mechanisms.

6. Children's Privacy

We comply with the Children's Online Privacy Protection Act (COPPA) and similar international regulations. Since we do not collect any data from any users, we inherently do not collect data from children under 13. Parents and guardians are welcome to review the app's features and may supervise their children's use.

7. Security

While the app does not transmit or store your data externally, we encourage users to maintain standard device security practices (e.g., using passcodes, keeping iOS updated) to protect any locally stored app data.

8. Changes to This Policy

We may update this Privacy Policy occasionally. If we make material changes, we will update the "Last Updated" date and, where feasible, provide notice within the App. Continued use of the App after any changes constitutes your acceptance of the updated policy.

9. Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

orlandodanteleone@gmail.com

10. Compliance and Jurisdiction

This Privacy Policy is designed to comply with:

• Apple's App Store Review Guidelines

• General Data Protection Regulation (GDPR) principles—specifically, by not collecting data, we avoid requirements for lawful bases, data subject rights, etc.

• California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)—as we do not "sell," "share," or "collect" personal information.

For users in the European Economic Area (EEA), United Kingdom and other regions with specific privacy laws: because our app collects zero data, many regulatory obligations do not apply. However, we remain committed to the principle of privacy by design.

11. Your Rights

Since we collect no data, typical data subject rights (access, correction, deletion, portability) are not applicable. If you have any concerns about your privacy while using our app, please contact us.