Privacy Policy
Last Modified: March 19, 2024
Introduction
This Privacy Policy sets forth how personal information is collected and used in connection with online services operated by LottoAppGh (“LottoAppGh,” “we,” or “us”), including the LottoAppGh mobile application (the “App”), and the LottoAppGh website (collectively, the “Services”). By using the Services, you agree to the terms of this Privacy Policy. This Privacy Policy does not govern the data practices of third parties that may interact with our Services. Our Services may include access to third party content that we do not control. We recommend that you consult the applicable privacy policies of third parties whose websites or apps you may be accessing through our Services.
This Privacy Policy should be read in conjunction with our Terms of Service. By using our Services, you are consenting to the information collection and use practices described in this Privacy Policy. If you do not agree with the practices described here, do not use our Services.
Your use of the App and any information you provide through the Services remains subject to the terms of this Privacy Policy and our Terms of Service, as each may be updated from time to time. In the event of conflict between this Policy and the Terms of Service, the Terms of Service will control.
Any questions, comments, or complaints that you might have should be emailed to [email protected].
Information We Collect
We collect personal information you provide to us, or that we receive from third parties, social media platforms, and other publicly available sources. The information we collect includes:
Contact and Profile Data, such as name, email address, phone number, physical address, and date of birth.
Account Data, such as the username and password you provide to set up an account with us. If you choose to login to the Services via a third-party platform or social media network, we may collect information from that platform or network.
Government-issued Identification Numbers, such as a copy of your passport, driver’s license and/or state identification card, including your photo, passport/license/or identification number, and associated information.
Payment Data, such as credit or debit card, mobile money account or bank account number and routing number for the purposes of processing transactions at your request. We do not store your complete mobile money account, banking account number or payment card number.
Financial Data, such as information about your financial accounts which may include the bank you are using, account type (checking or savings), and we may query and/or receive the current balance of each account at any point.
Location Data, including the GPS location associated with your device.
Feedback Data, such as information you provide and content that you upload when you contact us with questions, feedback, upload attachments, or otherwise correspond with us online or otherwise (including on our social media pages).
Automatically Collected Data. We, our service providers, and third-party advertising partners use cookies, web beacons/GIFs, pixel tags, embedded scripts, e-tags/cache browsers and other tracking technologies to automatically log information about you, your computer or mobile device, and your activity over time on the Services and other online services, including:
Device Data, such as your computer or mobile device operating system type and version number, manufacturer and model, unique device identifier, browser type and version, screen resolution, the IP address used to connect your device to the internet, device identifier (such as the Google Advertising ID or Apple ID for Advertising), time zone setting, session time, browser plug-in types and versions, the website you visited before you visited our Services and location information such as city, country or geographic area, the number of times you click a page/screen or use a feature, the date and time you click on a page/screen or use a feature, and the amount of time you spend on a page or use a feature.
Online Activity Data, such as browsing history, search history, and whether you clicked on or opened one of our emails. We also collect information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Services (including date and time), search terms entered, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Please note that LottoAppGh does not respond to web browsers’ “do not track” signals or other opt-out mechanisms that indicate a request to disable online tracking of users who use our Services.
Information we receive from third parties.
We work with third parties to provide you the Services (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. The information we collect from you may be combined with information from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law.
LottoAppGh uses PayStack Ghana Ltd. (“PayStack”) to gather end user data from financial institutions. By using our Services, you grant LottoAppGh and PayStack the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution to our App. You agree to your personal and financial information being transferred, stored, and processed by PayStack in accordance with the PayStack Privacy Policy.
In addition to the above, we may need to verify your identity before we can permit you to use some features of the Services.
For purposes of verification, we may also collect from you other information as may be required to verify your identity and/or location in accordance with applicable laws and regulations. This can include date of birth and address verification.
How We Use and Disclose Your Information
LottoAppGh will not share, without your consent, any of the data it collects from you with third parties for the purposes of marketing or promoting third-party products or services.
We may use the information you provide:
- To provide you with the functionality of the Services.
- To respond to your inquiries.
- To provide you with customer service.
- To provide you with services, products or information, or actions you request.
- To provide to third parties, with your consent.
- To send administrative information to you, such as information regarding the Services and changes to our terms, including through push notifications, email and text messages.
- To send you marketing communications that we believe may be of interest to you, including through push notifications, email and text messages. You may opt-out of receiving these marketing communications by following the opt-out instructions on the communication.
- To verify your identity and account information, and to comply with applicable legal requirements.
- For our business purposes, such as data analysis; audits; fraud monitoring and prevention; to enforce our terms of service; developing new products; enhancing, improving or modifying our products and services; identifying usage trends; determining the effectiveness of our promotional campaigns; operating and expanding our business activities; and protecting the interests of our company, our Services, and our customers.
The information you provide may be disclosed:
To our third-party service providers, to provide services such as payment processing, advertising, website analytics, fraud investigation, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
Where you have consented to disclosure.
Where we have a good-faith belief that access, use, preservation, or disclosures of the information is reasonably necessary to:
- protect against harm to the rights, safety, or property of LottoAppGh, its Services, its users, or the public as required or permitted by law;
- comply with legal and regulatory obligations and government requests (for instance, subpoenas, court orders, and law enforcement inquiries);
- omply with our obligations and commitments to safeguard the privacy and security of your and other customers’ information;
- detect, prevent, or otherwise address fraud, security, or technical issues; and
- enforce our terms of service, including investigation of potential violations
- We may also disclose information about you as otherwise permitted under our Terms of Service or as specifically disclosed when we collect information from you.
Corporate Changes
In the event LottoAppGh, a substantial part of its assets, or all its assets are acquired, customer information (including your personal information) may be one of the transferred assets. Therefore, LottoAppGh may disclose and transfer your personal information and other data to a subsequent owner, co-owner or operator of LottoAppGh or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests or assets, or other corporate change (including in the event of a dissolution or bankruptcy), and in all cases, this may include sharing the information with prospective purchasers, investors, trustees, or other involved parties as part of the due diligence or acquisition or transfer processes, in connection with court proceedings, or in connection with financial transactions that LottoAppGh may be involved in, such as obtaining investors or financing.
Aggregated Data
We may aggregate the information that you and other users of the Services provide. If we do, we may use and disclose such aggregated information for any purpose. Aggregated information does not personally identify you or any other user. We may share non-personal information. This is information that does not contain personal information and can include user statistics.
Social Networks
LottoAppGh is not a social network itself, but we may provide links to social media sites to facilitate sharing with such sites. Your use of such links is your own discretion.
When you interact with our Services through social media sites, plug-ins or other applications, depending upon your privacy settings, you should be aware that this information may become public on the Internet. We cannot prevent or control further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.
Cookies and Tracking Technologies
When you use our Services, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Services, for when you later return to the Services.
Links
Our Services may, from time to time, contain links to and from the websites of others, including our partners, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should check these policies before you submit any personal data to these websites.
Options for Managing Your Personal Data
Access, update or delete information. If you registered for an account with us, you may review and update certain personal information in your account profile by logging into the account. You may also update your personal information, receive a copy of your personal information, or delete your account by contacting us at [email protected].
These rights are not absolute, and we reserve the right to verify your identity upon receiving such a request. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Service, or take other actions permitted by law. If your account is terminated or suspended, we may maintain information to prevent re-registration, or for reasons discussed in this paragraph.
Cookies & browser web storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Opt-out of marketing communications. If at any time you wish to opt-out of future promotional emails and communications, you may click the “unsubscribe” link in the email or otherwise contact us at [email protected]. It may take up to 10 business days before you stop receiving promotional emails. This opt-out does not apply to operational communications, for example, confirmation emails.
International Users
The Services are hosted in Ghana and are intended for and directed to users in Ghana only. If you access the Services from the European Union, Asia, United States or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from Ghana laws, please be advised that through your continued use of the Services, which are governed by Ghana law, this Privacy Policy, and our Terms of Service, you acknowledge that you are transferring your personal information to the Ghana and you consent to that transfer. You further consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Privacy Policy.
- Category of Personal Information/ Personal Data
- Categories we collect
- Category of Source
- Business or commercial purpose(s) for collection and processing
- Business or commercial purpose(s) for disclosure
- Categories of third parties to whom we disclose
- Identifiers
- Contact and Profile Data, Account Data, Government-issued Identification Numbers
- Directly from you or your agents
- From other third parties you choose to interact with
- From our service providers
- To provide Services to you
- To communicate with you
- To verify your identity
- To protect your account
- To prevent fraud or illegal activity
- Marketing activities
- Our service providers, including payment processors, analytics providers, other merchants
- Other third parties that you authorize
- Our business and marketing partners
- Third parties as required by law
- Commercial Information
- Payment Data, Financial Data, Feedback Data
- From other third parties you choose to interact with
- From our service providers
- Our service providers, including payment processors, analytics providers, marketing and advertising partners, other merchants
- Third parties as required by law
- Financial Information
- Payment data, Financial Data
- Account data, Device Data
- Directly from you
- From our service providers
- Maintain reliability, quality or safety of the Services
- Internet or Network Information
- Debug or repair the Services
- Maintain reliability, quality or safety of the Services
- From your mobile provider or ISP
Right of access and to data portability
You can ask us for confirmation whether we are processing your personal data and to access any such personal data. When exercising your right to access your personal data, you also have the right to obtain such personal data in a portable and, to the extent technically feasible and to the extent disclosing such personal data does not disclose any of our trade secrets, readily usable format. You may only exercise this right to data portability two times per calendar year.
Right to correction
You can ask us to correct inaccuracies in your personal data.
Right to deletion
You can ask us to delete your personal data of yours that we have.
The categories of third parties to whom the personal information was sold or disclosed for a business purpose.
Right to request the deletion of personal information
You can ask us to delete the personal information that we have collected from you, subject to certain exceptions. We will also notify any service providers and third parties with whom we have shared your personal information of your request. If you are using PayStack with our Services, and you desire to have your personal information deleted from PayStack, you must contact PayStack directly to make such a request. Please note that due to applicable laws and regulations, you will be unable to use some of our Services if your personal information is deleted, including, but not limited to, ordering lottery tickets. As noted above, your deletion request is subject to certain exceptions which we may rely on where it is necessary for us to:
Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us;
Comply with a legal obligation; or
Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to ask us not to sell your personal information
We do not sell your personal information. However, like many companies, we may use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. You can get more information and opt-out of the use of cookies on our Services for interest-based advertising purposes by setting your preferences on the App or our website. You will need to set your preferences from each device and each web browser from which you wish to opt-out. This feature may use a cookie to remember your preference, so if you clear all cookies from your browser, you may need to re-set your settings.
Children Under the Age of 18
We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on or through our App or our Services. If it is discovered that we have collected or received personal information from a child under 18, this information will be deleted. If you believe we might have any information from or about a child under 18, please contact us at [email protected].
Transactions through our App and our Services are limited to those meeting the age requirements in the applicable jurisdiction.
Information Security
The security of your personal information is extremely important. We maintain commercially reasonable technical, administrative, physical, electronic and procedural safeguards to protect the confidentiality and security of personal information provided to us.
However, no communication over the Internet can be guaranteed to be completely secure. Although we take care to protect your personal information, we cannot guarantee or warrant the security of any information you provide to us, so you do so at your own risk.
The security of your information and account with us is also dependent on you. Please keep any account information, including access to your mobile phone secure. You are responsible for maintaining the confidentiality of your account information. We also recommend that you log out of the App when you are done using our Services, to help prevent another party from accessing your account. If you believe your account has been compromised, you must notify us immediately at [email protected].
Changes and Updates
This Privacy Policy may be periodically revised, and this will be reflected by the “Last update” date at the top. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account and/or we may provide notice to you within the app itself where we may require you to acknowledge such changes. For non-material changes, where your acknowledgement is not required, your continued use of the App and the Services constitutes your acceptance of the Policy as amended. Each time you use the App or the Services, the version of our Privacy Policy then posted will apply to that use, so it is your responsibility to check for updates each time you access the App or the Services.
To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
Contact Us
Please contact LottoAppGh with any questions or comments about this Privacy Policy by emailing: [email protected].