Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to No Dice, the software program provided by the Company, available on iOS and Android devices.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Ben Leavitt International Inc., 523 Oriole Dr, Oakville, Ontario, Canada.
• Country refers to: Ontario, Canada
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Sensitive Personal Data refers to Personal Data that reveals information about Your health, wellness, or recovery journey, including data related to gambling habits, app-blocking preferences, relapse events, and recovery progress.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Types of Data Collected Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Self-reported gambling-related information (e.g., monthly spending estimates, apps You choose to block, recovery mode preferences)

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from Your Device's camera and photo library (for challenge proof submissions and profile photos)
• Video recordings from Your Device's camera (for documenting Your recovery journey)

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.

App-Blocking and Screen Time Data

Our Application uses operating system-level features to help You block access to apps You choose to restrict:

• On iOS: We use Apple's Family Controls and Screen Time frameworks (DeviceActivityMonitor, ManagedSettingsStore). The list of apps You choose to block is processed on-device using Apple's privacy-preserving APIs. We do not receive or store the names or identifiers of the specific apps You block — Apple's framework handles this entirely on Your Device.
• On Android: We use Android's Accessibility Service to detect and block app launches. We collect the package names of apps You choose to block so We can enforce Your blocking preferences. This data is stored securely on Our servers and is not shared with third parties.
• We record events related to Your blocking activity (e.g., when You temporarily unblock apps, bypass events, and focus session schedules) to provide features such as streak tracking, savings calculations, and accountability partner notifications.

Recovery and Wellness Data

Because No Dice is a gambling recovery application, some of the data We collect may be considered sensitive or health-related under applicable privacy laws (such as PIPEDA in Canada or GDPR in the European Union). This includes:

• Your chosen recovery mode (Cold Turkey or Cut Back)
• Relapse events and history
• Daily challenge completion and streak data
• Estimated money saved from reduced gambling
• Activity logs related to app-blocking behavior

We process this data solely to provide You with the recovery and accountability features of the Service. We do not use this data for advertising, profiling, or any purpose unrelated to Your use of the Service. We do not sell this data to any third party.

Accountability Partner Data

If You choose to use Our accountability partner (buddy) feature, We collect and share limited information between linked partners:

• Your display name and profile information You choose to share
• Notifications when a partner bypasses their app-blocking settings
• Challenge completion status

Accountability partnerships are mutual and opt-in. Both parties must consent to be linked. You can remove an accountability partner at any time through the Application.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to process payments, to deliver push notifications, and to contact You. See the "Third-Party Service Providers" section below for details.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
• With other users: When You opt in to accountability features (such as the buddy system), certain information may be shared with Your linked partner as described in the "Accountability Partner Data" section above.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

We use the following third-party services to operate and improve the Application. Each service receives only the data necessary for its specific purpose:

We do not sell Your Personal Data to any third party. We do not use Your data for third-party advertising. These Service Providers are contractually obligated to use Your data only for the purposes described above and in accordance with this Privacy Policy.

Subscription Plans

Some features of the Service require a paid subscription. Subscriptions are managed through the Apple App Store (iOS) or Google Play Store (Android) via our payment processor, RevenueCat. The following subscription plans are available:

• Monthly Subscription: Billed once per month (auto-renewable). Price: $9.99 per month as displayed in the App Store.
• Yearly Subscription: Billed once per year (auto-renewable). Price: $79.99 per year as displayed in the App Store.

Prices are displayed in USD and may vary by region based on App Store pricing. The exact price applicable to You will be shown before You complete Your purchase.

Free Trials

We may offer free trial periods. At the end of a free trial, Your subscription will automatically convert to a paid subscription unless You cancel before the trial period ends. You can cancel a free trial at any time through Your device's subscription management settings.

Billing and Renewal

Subscriptions automatically renew at the end of each billing period (monthly or yearly) unless You cancel before the renewal date. You will be charged through Your Apple ID or Google Play account.

Cancellation

You can cancel Your subscription at any time through Your device's subscription management settings (Apple Settings or Google Play Store). Cancellation takes effect at the end of the current billing period — You will continue to have access to premium features until then. We do not provide refunds for partial billing periods.

Refunds

Refund requests are handled by the Apple App Store or Google Play Store in accordance with their respective refund policies. Please contact Apple or Google directly for refund requests.

As of the date of this Privacy Policy, the Application does not use artificial intelligence (AI) or machine learning models to process Your Personal Data or make automated decisions about You.

If We introduce AI-powered features in the future, We will update this Privacy Policy to describe what data is processed, how it is used, and what choices You have. We will notify You of any such changes in accordance with the "Changes to this Privacy Policy" section below.

We may send You push notifications to help You stay on track with Your recovery goals. These may include:

• Welcome and onboarding messages after You sign up
• Reminders about daily challenges
• Focus session reminders (when a scheduled blocking session is about to end)
• Accountability partner notifications (e.g., if Your buddy bypasses their blocking settings)

Push notifications are delivered via Firebase Cloud Messaging (FCM). Your device's push notification token is stored securely on Our servers. You can disable push notifications at any time through Your Device's notification settings or within the Application.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us. When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures: Deletion: Personal Data is removed from Our systems and no longer actively processed. Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance. Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Your information, including Personal Data, is processed at the Company's operating offices and by Our third-party Service Providers. This means that Your data may be transferred to — and maintained on — servers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in Your jurisdiction.

Specifically, Our primary Service Providers (Supabase, Firebase, Google Cloud, RevenueCat) operate servers in the United States. If You are located outside the United States, please be aware that Your Personal Data will be transferred to and processed in the United States.

Where required by applicable law (including PIPEDA and GDPR), We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service provides You with the ability to delete Your account and associated data directly within the Application. When You request account deletion:

Your account is deactivated and Your Personal Data is removed from active systems. Challenge media (photos and videos) stored in cloud storage are deleted. Your accountability partner links are severed. Push notification tokens are removed.

You may also contact Us at hello@nodice.app to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note that We may need to retain certain information when we have a legal obligation or lawful basis to do so. Residual copies may remain in encrypted backups for a limited period as described in the Retention section above.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

The security of Your Personal Data is important to Us. We implement the following measures to protect Your data:

• Row-Level Security (RLS) on our database ensures that users can only access their own data
• Authentication tokens are securely managed and automatically refreshed
• Service-level access controls restrict administrative operations to authorized backend functions only
• Push notification tokens and scheduling data are protected from direct user manipulation
• On iOS, app-blocking data is processed using Apple's privacy-preserving frameworks and never leaves Your Device

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Depending on Your location, You may have the following rights regarding Your Personal Data:

• Right of Access: You have the right to request copies of Your Personal Data.
• Right of Rectification: You have the right to request that We correct any information You believe is inaccurate or complete information You believe is incomplete.
• Right of Erasure: You have the right to request that We erase Your Personal Data, under certain conditions.
• Right to Restrict Processing: You have the right to request that We restrict the processing of Your Personal Data, under certain conditions.
• Right to Data Portability: You have the right to request that We transfer the data We have collected to another organization, or directly to You, under certain conditions.
• Right to Withdraw Consent: Where We rely on Your consent to process Personal Data, You have the right to withdraw that consent at any time.

To exercise any of these rights, please contact Us at hello@nodice.app. We will respond to Your request within a reasonable timeframe and in accordance with applicable law. For residents of Canada, these rights are provided under the Personal Information Protection and Electronic Documents Act (PIPEDA). For residents of the European Economic Area, these rights are provided under the General Data Protection Regulation (GDPR).

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

For material changes — particularly those affecting how We handle Sensitive Personal Data or introducing new third-party services — We will provide at least 30 days notice before the changes take effect.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.