Bloxks Pay Privacy Policy

Bloxks Pay is operated by Bloxks SAS, a simplified joint-stock company (SAS) registered with the Paris Trade and Companies Register under number 130 543 515, whose registered office is at 47 rue Vivienne, 75002 Paris, France (“Bloxks”, “we”, “us”).

For any question about personal data, or to exercise your rights, write to contact@bloxks.app. Bloxks has not appointed a Data Protection Officer; this address reaches the team responsible for data protection.

Bloxks Pay handles two different kinds of personal data, and our legal role is different for each.

• Developers. You are a Bloxks customer who connects an app to Bloxks Pay and uses its dashboard. For your account and your use of Bloxks Pay, Bloxks is the controller. Sections 3 to 5 apply to you.
• End users. You bought something, or might buy something, inside an app that uses Bloxks Pay. The app’s developer decides why and how your purchase data is used: the developer is the controller and Bloxks processes that data on the developer’s behalf, as a processor. Section 6 applies to you.

Apple, and Google once Google Play is supported, run the app stores where purchases happen. They take payment, decide refunds and handle taxes. They are independent controllers of the data they hold under their own privacy policies, and they are not our sub-processors. Bloxks Pay never receives card details and never handles money.

You sign in to Bloxks Pay with your Bloxks account. Bloxks Pay reads your Bloxks user identifier from your sign-in session and uses your email address only to show it to you. It does not keep its own copy of your email address or password.

Where you use Bloxks Pay for a company rather than as a sole trader, “performance of the contract” means our legitimate interest in performing the contract with that company. This data comes from your Bloxks account and from what you configure. Providing it is necessary to use Bloxks Pay: without it we cannot provide the service.

We do not run analytics or advertising tools on the Bloxks Pay dashboard. Our server logs replace end-user identifiers with a short pseudonymous code, and our hosting provider keeps its own technical request logs for a short period under its retention rules.

Bloxks Pay is free during the beta. If fees are introduced later, billing data will be handled by Bloxks under the Bloxks Privacy Policy, which keeps accounting records for 10 years as French law requires.

To check purchases and receive store events, Bloxks Pay needs access to your own store account. You give it through Bloxks.

• Apple In-App Purchase key. You upload it in Bloxks. It is encrypted with AES-256-GCM, sent to Bloxks Pay over an authenticated server-to-server channel, and stored encrypted again. It is decrypted only in server memory, to sign requests to Apple about your own app: transaction details, subscription statuses, notification history, and answers to Apple’s refund-related consumption requests. It is never shown again, not even to you, and you can replace it at any time.
• App Store Connect API key. It stays on Bloxks, encrypted, as described in the Bloxks Privacy Policy. Bloxks Pay uses it through Bloxks, on your instruction, to create offer codes and to set the address where Apple sends your app’s notifications.
• Google Play, when supported. Access will rely on a Google Cloud service account you control, handled with the same protections. This policy will be updated before Google Play support goes live.
• Your own Supabase project. If you linked one to your Bloxks project, Bloxks can write your Bloxks Pay secret key into it so that your server can use Bloxks Pay.

These keys are used only to provide Bloxks Pay for your apps, never for any other app or any other purpose. Our use of your store accounts is also governed by the terms you accepted with Apple and Google. You can revoke a key at any time in App Store Connect, and ask us at contact@bloxks.app to delete our copy, as set out in the Bloxks Pay Terms.

The Bloxks Pay dashboard uses only cookies that are strictly necessary to provide the service you asked for. Under the rules of the CNIL, the French data protection authority, they do not require consent. We use no analytics, advertising or tracking cookies on Bloxks Pay.

When you open Bloxks Pay at bloxks.app/pay, cookies set by the rest of bloxks.app may also be present. They are listed in the Bloxks Privacy Policy.

Inside apps, the Bloxks Pay SDK stores a few values on the device: the user identifier, a purchase token generated for the install, and a copy of the user’s unlocked access so that paid features keep working for up to 7 days without a connection. This storage is needed for the purchase features the user asked for. The developer remains responsible for describing it in the app’s own privacy policy.

If you bought something in an app that uses Bloxks Pay, the developer of that app is responsible for your data. Their privacy policy tells you how they use it. Bloxks processes your purchase data only on the developer’s instructions, under the DPA. The table below is here to be transparent about what Bloxks Pay holds.

6.1 What Bloxks Pay does not collect

The Bloxks Pay SDK sends only the user identifier, Apple’s signed purchase records and the app’s public key. It does not collect your name, email address, phone number, payment card, precise location, contacts, advertising identifier, device model or browsing activity, and it does not track you across apps or websites. The developer’s app may collect other data on its own; that is covered by the developer’s privacy policy, not by Bloxks Pay.

6.2 Where your purchase data goes

• To the developer, through the Bloxks Pay dashboard and exports, and through the developer’s own server.
• To destinations the developer configures (their own webhook, Slack or Discord). These events may include the product, amount, currency, store country, environment and, when a new buyer appears, the user identifier. These destinations are chosen by the developer and are their responsibility.
• To Apple, on the developer’s instruction. When you ask Apple for a refund, Apple may ask the developer for information. If the developer turned this on and confirmed that their users agreed to it, Bloxks Pay answers with: whether the purchase was delivered, the developer’s refund preference, whether a free trial was offered, and that you consented. Otherwise Bloxks Pay sends nothing. Apple alone decides the refund.
• To our sub-processors listed in section 7, only to run the service.

6.3 Our own limited uses

Bloxks uses data from Bloxks Pay for its own purposes only in the narrow cases listed in section 2 of the DPA, as controller and on the basis of its legitimate interests: protecting Bloxks Pay against abuse and attacks (the hashed IP address above); totalling each app’s revenue to calculate any Bloxks Pay fee owed by the developer, using amounts and not identities; producing anonymised statistics; and complying with the law or defending legal claims. We never use end-user data for advertising, profiling or selling, and we do not combine it across apps to build profiles of people.

6.4 How to exercise your rights as an end user

Contact the developer of the app first: their contact details are on the app’s App Store page and in its privacy policy. They can see, export and ask us to delete your data. Bloxks Pay does not know your name or email address, so we usually cannot identify you without the developer’s help.

You can also write to contact@bloxks.app. We will pass your request to the developer, or tell you how to reach them, and we will help the developer respond. For a refund, use the app’s refund option or contact Apple directly at reportaproblem.apple.com: Bloxks Pay cannot issue refunds.

Inside Bloxks, only the people who need it to run and support Bloxks Pay can access the data, and they are bound by confidentiality. We use the following service providers. They are our processors for developer data, and our sub-processors for end-user data (listed in Annex III of the DPA):

Other recipients, which are not our processors: Apple, and Google once supported, as independent controllers operating their stores; the destinations a developer chooses for their events; and public authorities when the law requires it. Our team receives technical alerts through Telegram; they contain only app names, counts and error messages, never end-user identifiers or purchase records. Exchange rates come from public sources and no personal data is sent to them. If Bloxks is involved in a merger or acquisition, data may be transferred to the new owner under the same commitments.

We will keep this list up to date and inform developers of any new sub-processor in advance, as set out in section 8 of the DPA.

Bloxks Pay data is stored and processed in the European Union, in Ireland. Our hosting providers, Vercel Inc. and Supabase, Inc., are United States companies: any access to the data from outside the European Union relies on the European Commission’s standard contractual clauses included in their data processing agreements and, for Vercel, on its certification under the EU-U.S. Data Privacy Framework. Any new transfer outside the European Union will be covered by the standard contractual clauses or by another safeguard recognised by the GDPR.

Data sent to Apple, or to destinations a developer sets up, travels there on the developer’s instructions and under the developer’s responsibility.

Data may be kept longer only when the law requires it, or for as long as needed to establish or defend a legal claim. Before deleting purchase data at a developer’s request, we remind them that their users may lose access to what they bought, so they can export it first.

• All traffic is encrypted in transit (HTTPS/TLS).
• Database tables are closed to direct public access; only Bloxks Pay’s servers can read and write them.
• Store keys are encrypted at rest with AES-256-GCM and decrypted only in server memory when needed.
• API keys are stored only as one-way hashes and are shown once, when created.
• Every purchase record is checked against Apple’s certificates before being trusted, and each store notification arrives at an address unique to the app.
• Outgoing webhooks are signed so developers can check they come from Bloxks Pay, and they can only be sent to public HTTPS addresses.
• Logs replace end-user identifiers with a pseudonymous code, integration addresses and signing secrets are encrypted at rest, and access inside Bloxks follows the principle of least privilege.

If a breach affects developer data, we notify the CNIL within 72 hours where the law requires it, and inform you when it is likely to put you at high risk. If it affects end-user data, we inform the developers concerned within 48 hours, as set out in section 11 of the DPA, so they can notify the authorities and their users.

Under the GDPR you can ask to access, correct or delete your data, to restrict or object to its use when it is based on our legitimate interests, and to receive it in a portable format. Under French law you can also leave instructions about what happens to your data after your death.

Write to contact@bloxks.app. We answer within one month, and may ask you to confirm your identity. You can also see your apps’ settings and data directly in the dashboard.

If you are not satisfied with our answer, you can complain to the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France (www.cnil.fr), or to the data protection authority of the country where you live or work.

Bloxks does not sell personal data and does not share it for cross-context behavioural advertising or targeted advertising, as those terms are defined by U.S. state privacy laws such as the California Consumer Privacy Act. For end-user data, Bloxks acts as a service provider or processor for the developer. Where your state’s law gives you rights to know, access, correct or delete your data, you can use them as described in sections 6.4 and 11, and we will not treat you differently for doing so. If we refuse a request, you can appeal by replying to our answer.

The Bloxks Pay dashboard is for professional developers and is not meant for children. Apps that use Bloxks Pay may be used by minors; in that case the developer decides how purchase data is handled and must meet the rules that protect children, including Apple’s rules for kids’ apps. Bloxks Pay itself collects no names or contact details and does no advertising or profiling.

Bloxks Pay automatically unlocks what a person has bought, based on the store’s purchase records. It makes no other automated decision that has legal or similarly significant effects on anyone.

We may update this policy, for example when Google Play support or paid plans arrive. The date at the top shows the latest version. We notify developers by email at least 30 days before any substantial change takes effect, as for the Bloxks Pay Terms.

Bloxks SAS, 47 rue Vivienne, 75002 Paris, France. Data protection: contact@bloxks.app. Support: support@bloxks.app.