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PERSONAL DATA

Privacy Policy

Last updated: September 8, 2026

1. Data controller

Paul Lamoulen EI, 70 rue de la République, 27500 Pont-Audemer, France. Contact to exercise your rights: plamoulen.webflow@gmail.com.

2. Data processed

Depending on your use, Black Room processes your email address and account ID; Free or Pro status; Stripe references required for subscriptions; simulated bankroll, round history, decisions and statistics; technical data and logs needed for security; and information stored locally on your device to maintain your session. Black Room does not receive or store your full payment-card number.

3. Purposes and legal bases

Account, sign-in, synchronization and Pro accessPerformance of the contract
Payment, billing and accounting obligationsContract and legal obligation
Security, fraud prevention and defense of rightsLegitimate interest
Personalized advertising, non-essential measurement and marketingPrior consent, when enabled

4. Recipients and service providers

Data is accessible to authorized persons and necessary providers: Supabase for authentication and the database, Stripe for payments and subscriptions, OpenAI Ireland Ltd for site publishing, and strictly necessary technical providers. Some providers may process data outside the European Economic Area under applicable contractual safeguards and transfer mechanisms.

5. Retention periods

  • Account and statistics: while the account is used, then deleted or anonymized after three years of inactivity unless requested earlier.
  • Subscription data: during the contractual relationship, then for the period needed for evidence and disputes.
  • Billing records: ten years where required by accounting rules.
  • Security logs: limited to the period needed for incident detection, generally twelve months.

6. Your rights

You may request access, correction, deletion, restriction or portability of your data, object to processing based on legitimate interests, and withdraw consent at any time. Proof of identity may be requested only where there is reasonable doubt about your identity. You may also lodge a complaint with the CNIL.

7. Account deletion

A request may be sent to plamoulen.webflow@gmail.com. Deleting an account does not automatically cancel an active subscription: also use the Cancel my subscription.

8. Security

Reasonable authentication, access-control and communication-encryption measures are used. As no online service can guarantee absolute security, any incident likely to create a risk is handled in accordance with applicable obligations.