LottoSmart Analytics ("we", "us", "our") provides an analytical and entertainment tool for planning lottery number combinations, backtesting them against historical draw results, tracking a personal playing budget and managing a syndicate. We are not a lottery operator, we do not sell tickets and we are not affiliated with any national lottery.
This policy explains which personal data we collect when you use our app, why we collect it, who we share it with and the rights you have over it. By creating an account or using the app you confirm that you have read this policy.
1. Data we collect
We only collect the data we need to run the app. Depending on how you use it, that is:
- Account data — your email address and, if you provide it, your display name. If you sign in with Google we receive your email address and basic profile details from Google; we never receive your Google password.
- Content you enter — the numbers and systems you generate, the systems you save, the simulations you run, budget limits and ticket expenses, draw reminders, and the syndicate names, member names, contributions and notes you add.
- Subscription and payment data — subscriptions are handled by PayPal. We receive your subscription status, plan, renewal date and a PayPal subscription identifier. Card numbers and bank details are entered directly with PayPal and are never visible to us or stored on our servers.
- Usage and technical data — the pages and features you use, your language preference, your browser and device type, and an approximate location derived from your IP address. This is collected by our hosting and analytics providers so we can keep the app working and understand which features are used.
- Local storage on your device — small pieces of data saved in your browser, such as your selected language and interface preferences. Clearing your browser storage removes them.
We do not ask for special categories of data (for example health, religious or political data), and we do not ask for your postal address, telephone number or identity documents.
2. How we use your data
We use your data to:
- create and secure your account and keep you signed in;
- generate systems, run simulations and store the content you save;
- manage your subscription and give you access to premium features;
- show you your own statistics, budget and syndicate overviews;
- keep the app secure, prevent abuse and fix technical problems;
- understand which features are used so we can improve them;
- answer your questions and send you essential service messages, for example about your subscription.
We do not use your data to make automated decisions that have a legal effect on you, and we do not use your lottery activity for advertising.
3. Legal bases for processing
Where the EU or UK General Data Protection Regulation applies, we rely on the following legal bases:
- Performance of a contract — providing the app and the features you use, including processing your subscription.
- Legitimate interests — keeping the app secure, preventing abuse and improving the service, balanced against your rights.
- Consent — where you have opted in to optional communications or non-essential storage. You can withdraw your consent at any time.
- Legal obligation — where we must keep records or respond to lawful requests.
5. International transfers
Some of our providers are located outside the European Economic Area, including in the United States. Where data is transferred outside the EEA we rely on appropriate safeguards, such as the European Commission's standard contractual clauses or an adequacy decision.
6. How long we keep your data
- Account and content data — for as long as your account exists. If you delete your account we remove your personal data within 30 days, except where we must keep records for tax or accounting purposes.
- Subscription and billing records — for as long as the law requires, usually up to 7 years.
- Usage and technical logs — for a limited period, typically no longer than 12 months.
- Local storage — until you clear it in your browser or device settings.
7. How we protect your data
Data is sent over encrypted connections (HTTPS) and stored on access-controlled infrastructure. Payment data is handled entirely by PayPal, our payment provider, so card details never reach our systems. No method of transmission or storage is completely secure, but we take reasonable technical and organisational measures to protect your data and we limit access to those who need it.
8. Your rights
Depending on where you live, you may have the right to:
- access the personal data we hold about you;
- correct data that is inaccurate or incomplete;
- delete your data, also known as the right to be forgotten;
- restrict or object to certain processing;
- receive your data in a portable, machine-readable format;
- withdraw consent where processing is based on consent.
You can also delete the content you have saved inside the app at any time. To exercise a right, contact us using the details at the end of this policy; we respond within 30 days. If you are in the EU or UK you may also lodge a complaint with your national data protection authority, which in the Netherlands is the Autoriteit Persoonsgegevens.
10. Age requirement
LottoSmart Analytics is intended for adults. You must be at least 18 years old to create an account or use the app. The app is not directed at children and we do not knowingly collect personal data from anyone under 18. If we learn that we have collected such data, we will delete it. If you believe a child has provided us with personal data, please contact us so we can remove it.
11. Changes to this policy
We may update this policy as the app develops or as the law changes. The effective date at the top of this page always shows the current version. If a change is significant, we will tell you in the app or by email before it takes effect.
12. Contact us
Questions about this policy or about your personal data? Contact us at the address below. We are the data controller for the personal data described in this policy.
