Phoenix Probability
9 Courcy Road
LONDON
N8 0QH
UK
The Diable Companion App and its associated website and online services directly collect customer names, email addresses, and subscription status/expiry date.
All personal data collected is freely provided by the user. The app can be run in free mode without providing this or any data, but in order to enable its full capabilities, all of this data is required.
Neither the app nor the website uses cookies. Session tracking is by means of local storage, and cleared after each session, except that Companion notes, locally, the last used email address for easier sign-in next time.
No third party data is collected. There is no in-app or website advertising. The app and website do not require any access to device data or permissions other than those required for an internet connection.
Phoenix Probability takes appropriate measures to ensure the security of the data. Data processing is carried out using computers and automated computer tools, following procedures and modes strictly limited to the purposes indicated. Data is stored on a cloud server, where it is encrypted and not available to the cloud service provider, and transmitted only to the extent strictly necessary and in encrypted form.
Data is expected to be stored in the United Kingdom, and subject to UK law, but may be transferred to other countries depending on the cloud service provider's internal procedures.
Data will be processed and stored for as long as required for the purpose indicated. However, users may on request close their account, in which case all data related to them will be promptly deleted, unless, and only for as long as, Phoenix Probability is permitted or required by law to retain it.
User data is collected and processed for the primary purpose of identifying and validating accounts at sign-in, whether through the Companion app or the Blackjack Federation website. (The same sign-in details are used for both.)
Additionally, Phoenix Probability may use the data in order to review and respond to emails; send email notifications of updates to the app, the website, or associated policies (including this one); provide customer and technical support; and maintain system logs (see below).
Subscriptions are collected by payment services, such as PayPal, who are responsible as Data Processors for any data they may collect during the payment process and otherwise. Pages which are part of the payment process will be clearly identified as such, and Phoenix Probability has no control over any data collected there. These payment services may make additional data visible to Phoenix Probability in their transaction reports. Phoenix Probability does not make any use of this additional data, using such reports only to the extent strictly necessary to manage subscription payments.
The User's Personal Data may be used for legal purposes by Phoenix Probability in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that Phoenix Probability may be required to reveal personal data upon request of public authorities.
The app and associated servers may collect files that record the User's interaction with the app and website (system logs), or use other personal data (such as the IP Address) for this purpose.
These logs may be used to help analyse usage of the app and website, maintain them and diagnose technical issues, and identify and prevent misuse.
More details concerning the collection or processing of Personal Data may be requested from Phoenix Probability at any time. Please see the contact information at the beginning of this document.
Phoenix Probability reserves the right to make changes to this privacy policy at any time. We will notify Users of any such change by email and by updating this page. It is recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should such changes affect processing activities performed on the basis of the User's consent, they shall not take effect without new consent from the User, where required.
Updated January 6, 2026