Grolotto Privacy Policy

Grolotto ("Grolotto," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you provide when using our websites, applications, platforms, lottery-related services, digital wallets, gift cards, vendor services, and other products and services we provide (collectively, the "Services").

This Privacy Policy explains what information we collect, how we use and protect it, when we may share it, how long we may retain it, and certain rights you may have regarding your information.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our privacy practices, please do not use the Services.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through:

• •Grolotto websites and web applications;
• •Grolotto player accounts;
• •Grolotto vendor accounts and vendor portals;
• •Grolotto administrative systems;
• •Lottery ticket and play-related services;
• •Grolotto digital wallets and account balances;
• •Gift card purchasing and redemption services;
• •Customer support and communications;
• •Promotions, marketing, and other Grolotto services that link to this Privacy Policy.

This Privacy Policy does not necessarily apply to websites, applications, payment services, or other services operated by third parties. Those services may have their own privacy policies, and we encourage you to review them before providing information directly to those providers.

2. Information We Collect

The information we collect depends on how you use Grolotto.

A. Information You Provide Directly

When you create an account, purchase a product, play a lottery game, become a vendor, contact customer support, or otherwise use our Services, we may collect information such as:

• •Full name;
• •Date of birth;
• •Email address;
• •Telephone or mobile phone number;
• •Username and account information;
• •Password or authentication information;
• •Mailing or billing address where applicable;
• •Preferred language;
• •Preferred currency;
• •Account and wallet information;
• •Lottery ticket and play information;
• •Transaction history;
• •Gift card purchases, redemptions, and related information;
• •Payment-related information;
• •Customer service communications;
• •Information submitted through forms or support requests.

B. Identity Verification and Vendor Information

To comply with applicable legal, regulatory, security, fraud-prevention, or business requirements, Grolotto may request additional information from certain users.

For Players, this may include information necessary to verify age or identity where required.

For Vendors, this may include:

• •Government-issued identification;
• •Business identification information;
• •Business licenses;
• •Business address;
• •Vendor contact information;
• •Documents required for verification or onboarding;
• •Information relating to the vendor's Grolotto account and transactions.

We may use third-party identity verification or compliance providers to assist with verification.

You should only submit documents and information that are requested through official Grolotto channels.

C. Payment Information

When you purchase gift cards, add funds to an account, make payments, or otherwise conduct financial transactions through the Services, we may collect information relating to the transaction, including:

• •Payment method;
• •Transaction amount;
• •Currency;
• •Transaction date and time;
• •Transaction or payment reference numbers;
• •Payment status;
• •Billing information where applicable.

Payment card information may be collected and processed by third-party payment processors on our behalf. Depending on the payment method and provider, Grolotto may not receive or store the complete payment card number.

We encourage users to review the privacy policies of the payment providers they use.

D. Information Collected Automatically

When you use our Services, we may automatically collect certain technical and usage information, such as:

• •IP address;
• •Device type;
• •Operating system;
• •Browser type;
• •Application or website version;
• •Device identifiers;
• •Date and time of access;
• •Pages or features accessed;
• •General usage activity;
• •Security and diagnostic information;
• •Approximate location information derived from technical information, where permitted.

We may use this information to operate, secure, troubleshoot, analyze, and improve our Services.

E. Cookies and Similar Technologies

Grolotto may use cookies, local storage, pixels, analytics tools, and similar technologies to:

• •Keep users signed in;
• •Maintain account sessions;
• •Remember preferences;
• •Improve website functionality;
• •Understand how users interact with our Services;
• •Detect fraud or suspicious activity;
• •Improve security;
• •Measure the effectiveness of communications or promotions, where applicable.

You may be able to control cookies through your browser or device settings. Disabling certain cookies may affect the functionality of some Services.

3. How We Use Your Information

Grolotto may use personal information for legitimate business, contractual, security, legal, and operational purposes, including to:

• •Create and manage user accounts;
• •Verify identity and eligibility;
• •Verify vendor information;
• •Provide lottery and related Services;
• •Process lottery tickets and transactions;
• •Maintain wallet balances and account records;
• •Process gift card purchases and redemptions;
• •Process or facilitate payments;
• •Provide customer support;
• •Communicate with users about their accounts and transactions;
• •Send important service notifications;
• •Detect and prevent fraud, abuse, unauthorized transactions, and other security threats;
• •Protect the integrity and security of the Services;
• •Monitor and investigate suspicious activity;
• •Comply with applicable laws, regulations, legal processes, and governmental requests;
• •Maintain business and financial records;
• •Resolve disputes;
• •Enforce our Terms and Conditions;
• •Improve our websites, applications, and Services;
• •Conduct analytics and operational research;
• •Develop new features and Services;
• •Manage promotions and marketing communications where permitted;
• •Protect the rights, property, safety, and security of Grolotto, our users, vendors, service providers, and others.

We will not use personal information for purposes that are materially inconsistent with this Privacy Policy unless permitted or required by applicable law or otherwise disclosed to you.

4. Lottery, Ticket, and Play Information

When you use Grolotto to purchase or participate in lottery-related Services, we may collect and retain information associated with your activity.

This may include:

• •Lottery game selected;
• •Numbers or selections entered;
• •Ticket information;
• •Draw/state information;
• •Ticket purchase date and time;
• •Ticket amount;
• •Currency;
• •Vendor associated with a transaction;
• •Transaction status;
• •Winning or non-winning status;
• •Prize or payout information where applicable;
• •Related account and transaction records.

This information may be necessary to provide the Services, maintain accurate records, resolve disputes, prevent fraud, and comply with applicable legal or regulatory requirements.

5. Digital Wallets and Account Balances

If Grolotto provides a digital wallet or account balance feature, we may collect and maintain information relating to:

• •Deposits;
• •Purchases;
• •Redemptions;
• •Credits;
• •Debits;
• •Adjustments;
• •Transfers or other permitted wallet activity;
• •Transaction history;
• •Applicable fees;
• •Currency and exchange information.

Wallet and transaction records may be retained for accounting, security, dispute resolution, fraud prevention, customer service, and legal or regulatory purposes.

6. Gift Cards

If you purchase, receive, sell, or redeem a Grolotto gift card, we may collect information relating to:

• •Gift card denomination;
• •Gift card transaction;
• •Purchase date;
• •Redemption date;
• •Transaction status;
• •Recipient information where provided;
• •Email address or telephone number;
• •Payment information or payment reference;
• •Gift card or redemption information.

Gift card information may be retained to prevent fraud, investigate disputes, maintain transaction records, and comply with applicable requirements.

7. Vendors

Grolotto may collect additional information from individuals and businesses that register as Vendors.

Vendor information may include:

• •Personal identification information;
• •Business information;
• •Contact information;
• •Business license information;
• •Identity verification documents;
• •Vendor account information;
• •Vendor wallet and transaction information;
• •Lottery sales and ticket information;
• •Payment and funding information;
• •Communications with Grolotto;
• •Information relating to vendor compliance.

Vendor information may be used to evaluate applications, verify eligibility, administer vendor accounts, process transactions, prevent fraud, maintain records, and comply with applicable requirements.

8. How We Share Information

Grolotto does not sell personal information simply because you use our Services.

We may share personal information with appropriate third parties when necessary to provide, protect, operate, or improve the Services. These parties may include:

Payment Providers — We may share information with payment processors and financial service providers to process payments, refunds, gift card purchases, wallet funding, or other transactions.

Identity Verification and Compliance Providers — We may use specialized providers to verify identity, age, business information, or other information required for compliance, security, fraud prevention, or account verification.

Technology and Hosting Providers — We may use third-party companies for services such as:

• •Cloud hosting;
• •Databases;
• •Website infrastructure;
• •Software development;
• •Security;
• •Data storage;
• •Analytics;
• •Email delivery;
• •Customer support;
• •Authentication;
• •Communications.

These providers may process personal information on our behalf and are expected to use appropriate safeguards consistent with their contractual obligations and applicable law.

Communication Providers — If you communicate with Grolotto through email, text messaging, WhatsApp, or other communication channels, information may be processed by the provider operating that communication service.

Legal and Government Authorities — We may disclose information when reasonably necessary to:

• •Comply with applicable law;
• •Respond to valid legal processes;
• •Respond to governmental requests;
• •Protect our rights or property;
• •Investigate fraud or unlawful activity;
• •Protect users or the public;
• •Prevent or address security threats;
• •Enforce our agreements.

Business Transfers — If Grolotto is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

9. We Do Not Sell Your Information for Money

Grolotto does not sell your personal information for monetary consideration as a business practice.

If our data practices change in a way that would constitute a sale, targeted advertising, or another regulated form of data sharing under applicable law, we will provide any disclosures, notices, and choices required by applicable law.

10. Data Security

Grolotto takes reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

Depending on the nature of the information and our technology environment, security measures may include:

• •Access controls;
• •Authentication mechanisms;
• •Role-based access;
• •Secure transmission technologies;
• •Monitoring and logging;
• •Security procedures;
• •Vendor and service-provider controls;
• •Data minimization;
• •Backup and recovery procedures;
• •Security testing and maintenance.

However, no internet transmission, electronic storage system, or security measure can be guaranteed to be completely secure.

You are responsible for protecting your account credentials and should immediately notify Grolotto if you believe your account has been compromised.

11. Employee and Vendor Access

Access to personal information within Grolotto should be limited to individuals who need the information to perform authorized business, operational, support, security, compliance, or administrative functions.

We seek to limit access to sensitive information according to legitimate business needs.

12. Data Retention

Grolotto retains personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy.

The retention period may depend on:

• •The type of information;
• •The purpose for which it was collected;
• •The user's relationship with Grolotto;
• •Account and transaction requirements;
• •Fraud-prevention and security needs;
• •Dispute resolution;
• •Legal or regulatory obligations;
• •Financial and accounting requirements.

Certain information, including transaction, ticket, payment, identity verification, and vendor records, may need to be retained after an account is closed because of legal, regulatory, accounting, security, fraud-prevention, or dispute-resolution requirements.

When information is no longer reasonably required, we may delete, anonymize, or securely dispose of it in accordance with our internal procedures and applicable law.

13. Your Privacy Rights

Depending on where you live and the laws that apply to you, you may have certain rights regarding your personal information. These may include the right to:

• •Request confirmation of whether we process your personal information;
• •Request access to personal information we maintain about you;
• •Request correction of inaccurate information;
• •Request deletion of personal information, subject to applicable exceptions;
• •Request a copy of certain personal information in a portable format;
• •Object to or restrict certain processing;
• •Opt out of certain targeted advertising, sale, or profiling activities where applicable;
• •Withdraw consent where processing is based on consent;
• •Appeal certain decisions concerning a privacy request where required by applicable law.

These rights are not absolute and may be subject to legal exceptions. For example, Grolotto may need to retain certain information to comply with law, protect the Services, prevent fraud, maintain financial records, resolve disputes, or satisfy regulatory requirements.

14. How to Submit a Privacy Request

To submit a privacy request, contact us using the information provided in the Contact Us section below.

Your request should identify:

• •Your name;
• •The email address or phone number associated with your account;
• •The type of request you are making;
• •Any additional information reasonably necessary to verify your identity.

We may need to verify your identity before completing certain requests. This is intended to protect your account and personal information from unauthorized requests.

We will process verified requests within the time required by applicable law.

15. Appeals

Where applicable law provides a right to appeal a decision concerning a privacy request, you may contact us using the contact information below and identify the original request and the reason you believe the decision should be reconsidered.

We will review appeals in accordance with applicable law.

16. Children's Privacy and Age Requirements

Grolotto's lottery-related Services are not intended for individuals who are below the minimum age required by applicable law.

We do not knowingly collect personal information from children in violation of applicable privacy laws.

If we learn that we have collected personal information from a child in circumstances where collection is not permitted, we may take reasonable steps to delete that information.

Because age and eligibility requirements may vary by jurisdiction and by Service, users are responsible for meeting all applicable age and eligibility requirements before using Grolotto.

17. Location Information

Certain technical information, including IP addresses and device information, may provide an approximate indication of a user's location.

Where permitted and necessary for a particular Service, Grolotto may use location-related information for security, fraud prevention, eligibility, compliance, functionality, or other legitimate purposes.

Grolotto will not claim to collect precise location information unless the applicable Service actually does so and the appropriate notice and permissions are provided.

18. Third-Party Websites and Services

Our Services may contain links to third-party websites, payment services, social media platforms, or other external services.

Grolotto is not responsible for the privacy practices of third parties that operate independently from Grolotto.

When you leave Grolotto or interact directly with a third-party service, that provider's privacy policy may apply.

We encourage you to review the privacy policies of third-party services before providing personal information.

19. International Data Processing

Grolotto and its service providers may process or store information in countries other than the country in which you live.

Privacy and data protection laws may differ between countries.

Where required by applicable law, Grolotto will take appropriate steps concerning international transfers of personal information.

20. Marketing Communications

Where permitted by law, Grolotto may send promotional or marketing communications regarding products, services, promotions, features, or other opportunities.

You may opt out of certain promotional communications by following the unsubscribe instructions included in the communication or by contacting us.

Even if you opt out of marketing communications, we may continue to send necessary service-related communications, such as:

• •Account notifications;
• •Security alerts;
• •Transaction confirmations;
• •Payment notifications;
• •Password or authentication messages;
• •Important legal or policy notices;
• •Customer service communications.

21. Fraud Prevention and Security Monitoring

Grolotto may monitor account activity, transactions, devices, and other information for security and fraud-prevention purposes.

We may use automated tools and manual review to identify:

• •Suspicious transactions;
• •Unauthorized access;
• •Account abuse;
• •Fraud;
• •Attempts to circumvent security controls;
• •Multiple or fraudulent accounts;
• •Other activity that may threaten the integrity of the Services.

Where permitted by law, we may suspend, restrict, investigate, or terminate accounts associated with suspected fraudulent or unlawful activity.

22. Legal and Regulatory Compliance

Grolotto may collect, use, retain, and disclose personal information as necessary to comply with applicable laws, regulations, licensing requirements, lottery requirements, financial requirements, identity verification obligations, tax requirements, court orders, governmental requests, and other legal obligations.

Certain records may therefore be retained even after you request deletion of your account or personal information where applicable law permits or requires us to retain them.

23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

When we make changes, we may update the "Effective Date" and "Last Updated" dates at the beginning of this Privacy Policy.

If we make material changes, we may provide additional notice where required by applicable law, such as posting a notice on our website, sending an account notification, or requesting acknowledgment.

We encourage you to periodically review this Privacy Policy.

24. Contact Us

If you have questions about this Privacy Policy, want to exercise a privacy right, or have concerns about how your information is handled, please contact Grolotto:

Privacy Contact: support@grolotto.com

Business Email: support@grolotto.com

WhatsApp: +509 35 50 0556

Address: [Insert Business Address]

Website: www.grolotto.com

For privacy requests, please include "Privacy Request" in the subject line of your communication.

25. Additional Notice

This Privacy Policy is intended to explain Grolotto's general privacy and data-handling practices. It does not create contractual rights beyond those provided by applicable law.

Grolotto may maintain additional notices or disclosures for particular products, services, jurisdictions, or categories of information where required.

Where another Grolotto privacy notice specifically applies to a particular service, that notice will supplement this Privacy Policy.