Effective October 20, 2026 · Version 1.0

Privacy Policy

What Back to Even collects, why, who helps us run it, how long we keep it, and the choices you have.

1. Scope and data controller

This policy covers the Back to Even iPhone app, this website, our support email and the small set of servers the app talks to (together, the “Service”, “we”, “us”).

Controller: the operator of Back to Even is the developer named as the seller on the app’s App Store page. Privacy requests go to back2app@fluagency.com.

Back to Even helps people stop betting. That means you may tell it things you haven’t told anyone, so we designed it to keep almost all of that on your phone. There is no account: we never ask for your name, email or phone number. Back to Even is not a gambling operator, a treatment provider or an emergency service.

2. Personal data we process

The app uses your notification permission for reminders and game-time warnings, and Screen Time permission for the Shield. It does not use your location, contacts, camera, microphone or photos. The first time you turn on voice guidance in Calm, the app downloads a recorded voice pack from this website; after that it works offline. The download contains nothing about you.

3. Purposes and legal bases

To provide the Service (performance of our agreement with you): run the Shield, reminders, Calm and SOS, answer you in Pip chat when you ask, unlock and restore your subscription, and answer support email.

Legitimate interests, balanced against your rights: keep purchase and refund records, prevent fraud and abuse (App Check, a daily cap on Pip messages), fix crashes, and count which features help, in aggregate.

Consent or device choice: notifications, Screen Time access, Pip chat and Apple’s App Tracking Transparency prompt are all asked for in context and can be withdrawn in the app or iOS Settings. Declining any of them doesn’t lock you out of the rest of the app.

Legal obligations and claims: keep records the law requires and respond to lawful requests.

Information about gambling can be sensitive. We avoid collecting it on our servers: it stays on your device, and the only part that ever leaves is what you choose to send Pip.

For Türkiye, processing relies on the conditions in Law No. 6698 (KVKK): necessity for the performance of a contract, legitimate interests that do not harm your fundamental rights, legal obligations, the establishment or protection of a right, and explicit consent where required.

4. Pip chat and AI

Pip’s chat is optional and starts only after you agree to it on a consent screen. Each message goes to our server at Cloudflare, which asks an AI model (Cloudflare Workers AI, or Google’s Gemini API if we switch to it) for Pip’s reply. We do not store your messages and we do not use them to train models. Our server keeps only a count of messages per device per day, deleted after two days.

If a message mentions being in danger, Pip shows crisis lines straight away without sending it to the model. Pip is a companion, not a counsellor, and never gives betting tips. Please leave out names, addresses and bank details.

5. Service providers and international transfers

We share only what a feature needs, with these providers:

These providers may process data outside your country, including in the United States and the European Economic Area. Where required, transfers rely on adequacy decisions, standard contractual clauses or another lawful mechanism.

We do not sell or rent personal data, and we never share anything about your betting or recovery with advertisers.

6. Retention and deletion

Delete my data erases everything on the device and asks our server to delete every event sent from it. To have your purchase record removed too, email us from the address you’d like us to reply to; we may keep what the law requires.

7. Your choices and legal rights

Privacy Choices lists the practical steps. You can:

Send requests to back2app@fluagency.com. Because there is no account, include the ID shown under Settings → About if you can, so we can find your records. We will reply within the time the law requires.

8. Security and age

We use encrypted connections, App Check to keep other software away from our servers, verification of Apple’s signed receipts, least-privilege credentials and access controls on our admin tools. No system is perfectly secure; tell us if you suspect misuse.

Back to Even is for adults aged 18 and over. We do not knowingly collect data from children and will delete it if we learn we have.

9. Changes and contact

We will update this policy when features, providers or laws change. Material changes will be shown in the app or on this site before they take effect where required. The date at the top marks the current version.

Privacy contact: back2app@fluagency.com