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Bulwark Black LLC

Cyber Security | Software Development | Consulting Services

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Bulwark Black LLC

Cyber Security | Software Development | Consulting Services

VA Disability Calc & Track Privacy Policy

Privacy Policy for VADisabilityCalculator

Last updated: July 14, 2025

Our Commitment to Your Privacy

Bulwark Black LLC (“we,” “our,” or “us”) operates the VADisabilityCalculator mobile application (the “App”). We understand that you are trusting us with potentially sensitive information related to your military service and disability status.

We want to be absolutely clear: we do NOT collect, store, transmit, or have any access to your personal disability information, calculations, or documents.

This privacy policy explains in detail what limited information we do collect (only for advertising and purchase processing purposes) and, more importantly, what we explicitly do NOT collect.

What We DO NOT Collect

We DO NOT collect, store, or have access to:

1. Your Disability Information

  • ❌ Disability ratings or percentages you enter
  • ❌ Types of disabilities or conditions
  • ❌ Extremity information (upper/lower, left/right)
  • ❌ Any medical conditions or symptoms
  • ❌ VA disability codes you search or save

2. Your Calculations

  • ❌ Combined disability rating calculations
  • ❌ Payment calculations
  • ❌ Dependent information
  • ❌ Any calculation history or results

3. Your Documents

  • ❌ Any documents you scan or store
  • ❌ PDF files or annotations
  • ❌ Photos or images you upload
  • ❌ Any files stored in the app

4. Your Personal Information

  • ❌ Your name or identification
  • ❌ Your email address
  • ❌ Your location (beyond general region for ads)
  • ❌ Your military service information
  • ❌ Your contact information
  • ❌ Your VA claim information

5. Your App Usage Details

  • ❌ Which features you use
  • ❌ Your saved profiles or calculations
  • ❌ Your notes or reminders
  • ❌ Sites you visit within the app
  • ❌ Your search queries for disability codes

How We Ensure Your Privacy

All your data stays on YOUR device:

  • ✅ Calculations are performed locally on your device
  • ✅ Saved profiles are stored only on your device
  • ✅ Documents remain only on your device
  • ✅ Notes and reminders stay on your device
  • ✅ Your PIN/biometric security is device-only

We have ZERO servers that store your data:

  • We do not operate any servers that collect user data
  • We do not use any analytics that track your calculations
  • We do not have any database of user information
  • We cannot see, access, or retrieve your data even if we wanted to

What We DO Collect

1. Advertising Data (Only for Advertising)

Advertising Identifier (IDFA) – Only if you grant permission via iOS App Tracking Transparency:

  • Used solely by Google AdMob to show relevant ads
  • You can deny this permission with no impact on app functionality
  • You can change this permission anytime in iOS Settings

Basic Device Information for Ad Delivery – Collected by Google AdMob, not by us:

  • Device type (e.g., iPhone 14)
  • iOS version (e.g., iOS 17.0)
  • Screen size and orientation
  • Language and time zone
  • General geographic region (country/state level)

Ad Interaction Data – Handled entirely by Google AdMob:

  • Whether an ad was shown
  • Whether an ad was clicked
  • Ad performance metrics

2. Purchase Data (RevenueCat)

For processing in-app purchases and managing your ad-free status, RevenueCat collects:

  • Anonymous User ID: A random identifier created by RevenueCat (not linked to your Apple ID or personal information)
  • Purchase Receipt: Apple’s purchase receipt to verify and restore your purchases
  • Purchase Events: When you purchase or restore the ad-free version
  • Device Information: Basic device model and OS version for purchase compatibility

Important about RevenueCat:

  • RevenueCat does NOT receive any of your disability data
  • RevenueCat does NOT receive your name or email
  • RevenueCat only knows you purchased “Remove Ads” – nothing else
  • Your Apple ID remains private – RevenueCat uses anonymous identifiers
  • All payment processing is handled by Apple – RevenueCat only verifies receipts

Third-Party Services

Google AdMob

We use Google AdMob solely to display advertisements. Google AdMob may collect device information as described above.

What AdMob DOES Collect:

Device & Usage Data:

  • Device identifiers (IDFA if allowed)
  • IP address and general location
  • App usage patterns (session length, ad interactions)
  • Device type, OS version, app version
  • Network type and carrier

Ad Performance Metrics:

  • Ad impressions and clicks
  • Ad revenue data
  • User interactions with ads

What AdMob DOES NOT Collect:

Your App’s Content Data:

  • User’s VA disability calculations
  • Saved profiles and ratings
  • Document contents (your encrypted files)
  • Personal notes or medical information
  • Any data stored in UserDefaults or Core Data

User-Entered Information:

  • Text from text fields
  • Selected conditions or percentages
  • Document tags or notes

Why Your Data is Safe:

  • Sandboxing: AdMob SDK runs in a sandboxed environment and cannot access your app’s private data storage
  • No Content Scanning: AdMob doesn’t scan or analyze the content within your app’s views or stored data
  • Your Encryption: Your document encryption (AES-256 GCM) ensures even if someone could access the files, they couldn’t read them

Learn more about Google’s data practices:

You can opt out of personalized ads:

  • iOS: Settings → Privacy & Security → Tracking → Disable “Allow Apps to Request to Track”
  • Or purchase our ad-free version to remove all advertisements permanently

RevenueCat

We use RevenueCat to process in-app purchases and manage purchase status. RevenueCat’s practices:

  • RevenueCat Privacy Policy: https://www.revenuecat.com/privacy
  • RevenueCat only processes purchase-related data
  • No personal or disability information is shared with RevenueCat
  • Purchase data is linked to anonymous identifiers, not your personal information

Apple Technologies

We use standard Apple frameworks (Core Data, CloudKit if enabled) that keep your data on your device or in your personal iCloud account. We have no access to data stored via Apple’s frameworks.

In-App Purchases

When you purchase the ad-free version:

  • The transaction is handled entirely by Apple
  • RevenueCat receives only a receipt for verification
  • We do not receive any payment information
  • The purchase status is stored locally on your device and verified by RevenueCat
  • Your purchase can be restored on any device using the same Apple ID

Data Security

Your Data’s Security

Since all your personal and disability data remains on your device:

  • It’s protected by your device’s security (Face ID, Touch ID, PIN)
  • It’s encrypted by iOS when your device is locked
  • It’s included in your encrypted iCloud backups (if enabled)
  • It cannot be accessed by us, RevenueCat, or any other third party

App Security Features

  • Optional PIN/biometric lock for app access
  • Automatic lock when app goes to background
  • No network transmission of personal data
  • Purchase verification happens without sharing personal info

Your Rights and Choices

You have complete control:

1. Advertising Choices

  • Deny tracking permission (iOS 14.5+)
  • Purchase ad-free version
  • Use Limit Ad Tracking in iOS settings

2. Data Deletion

  • Delete any saved profile within the app
  • Clear all notes through the app interface
  • Uninstall the app to remove ALL local data permanently
  • RevenueCat data: Contact privacy@revenuecat.com for deletion requests

3. Data Portability

  • Export your calculations via the share feature
  • Save documents to your device’s Files app
  • All your data is already portable since it’s on your device

4. Purchase Management

  • Restore purchases on any device with your Apple ID
  • Cancel subscriptions through Apple (though we only offer one-time purchases)
  • Request refunds through Apple’s standard process

Special Commitments for Veterans

We recognize that our users are veterans dealing with sensitive disability information. We make these additional commitments:

  • No Data Mining: We will never analyze or mine disability data
  • No Selling Data: We will never sell any information to third parties
  • No Sharing: We will never share data with insurance companies, employers, or any other entity
  • No Profiling: We will never create profiles based on disability information
  • No Marketing: We will never use disability information for marketing
  • Anonymous Purchases: Even our purchase processor (RevenueCat) doesn’t know who you are

Children’s Privacy

Our App is not intended for children under 13. We do not knowingly collect any information from children under 13. The app is designed for adult veterans managing their VA benefits.

Changes to This Policy

We may update this privacy policy to reflect changes in our practices or for legal reasons. We will notify you of any material changes by:

  • Updating the “Last updated” date
  • Showing an in-app notification after update
  • Posting a prominent notice in the app

Legal Compliance

CCPA (California Consumer Privacy Act)

California residents have additional rights. However, since we don’t collect personal information beyond basic ad delivery data via AdMob and anonymous purchase data via RevenueCat, most CCPA rights related to data deletion and access are limited. You can still:

  • Opt-out of ad personalization
  • Request information about our privacy practices
  • Request deletion of RevenueCat anonymous purchase data

GDPR (General Data Protection Regulation)

For users in the European Economic Area:

  • Legal basis for ad data: Consent (via ATT prompt)
  • Legal basis for purchase data: Contract performance
  • Data controller for ads: Google AdMob
  • Data processor for purchases: RevenueCat
  • Your rights: Access, rectification, erasure, and portability (though we store no personal data)

Open Source Commitment

We are committed to transparency. The complete source code for data handling in our app shows that:

  • All calculations happen locally
  • No network calls transmit personal data
  • Storage is exclusively local
  • Only purchase verification uses network calls (no personal data transmitted)

Contact Us

If you have any questions or concerns about this privacy policy or our practices:

Bulwark Black LLC

  • Email: bulwark-black@bulwarkblack.com
  • Website: www.bulwarkblack.com
  • Mailing Address: 522 W RIVERSIDE AVE, STE N, Spokane, WA 99201, United States

For urgent privacy concerns:

  • Response time: Within 48 hours

For RevenueCat-specific privacy requests:

Summary in Plain English

What we do:

  • Show ads (if you haven’t purchased ad-free version)
  • Process purchases through RevenueCat (anonymous IDs only)

What we don’t do:

  • Collect, store, see, or access ANY of your disability information, calculations, documents, or personal data

Your data location:

Only on YOUR device

Our access to your data:

ZERO

Third-party data:

  • AdMob: Basic device info for ads (if you allow)
  • RevenueCat: Anonymous purchase verification only

How to remove all data:

Delete the app

How to stop ads:

Purchase ad-free version or deny tracking

Privacy Policy Version: 4.0