Privacy Policy

1. Introduction

Amifa e.U. ("we," "our," or "us") operates the Lottoread mobile application (available on iOS and Android) and the website at lottoread.com (collectively, the "Service"). This Privacy Policy explains what information we collect, how we use it, with whom we share it, and the rights you have over your data.

The controller is Amifa e.U., Tullnerbachstraße 66-68/2/4, 3011 Purkersdorf, Austria. You can contact us at support@lottoread.com.

This policy describes our data practices; it does not record consent for optional product analytics. Our Service is intended for users aged 13 and older. If you are under 13, do not use the Service or submit any personal information.

2. Information We Collect

2.1 Information You Provide

• Account information: Email address and display name provided when you sign in with Google or Apple.
• Lottery ticket images: Photos you capture or upload for ticket scanning. Images are transmitted to our servers for AI-powered processing and stored in Google Cloud Storage.
• App preferences: Your preferred lottery games, notification settings, and liked games.

2.2 Information Collected Automatically

• Device information: Device model, operating system version, language, timezone, and a unique device identifier.
• Usage data: Features used, tickets scanned, numbers generated, login history, login streaks, and session activity.
• Push notification token (FCM): A Firebase Cloud Messaging token used to deliver lottery draw notifications to your device.
• Crash and performance data: Automatic crash reports and performance traces collected via Firebase Crashlytics and Firebase Performance Monitoring.
• Product analytics: When enabled, consent-gated PostHog analytics records limited app and website interactions. The event categories and identifiers are described below. Older installed apps and already-open website sessions may still send Firebase Analytics product events.
• Advertising identifiers: On iOS, the IDFA (Identifier for Advertisers) may be collected after you grant permission via the App Tracking Transparency prompt. On Android, the AAID (Android Advertising ID) may be used subject to your consent via Google's User Messaging Platform.
• Subscription status: Your current subscription tier and transaction history, managed through RevenueCat.

2.3 Information From Third Parties

• Google Sign-In / Apple Sign In: Basic profile information (name, email) returned by the authentication provider when you choose to sign in.

3. How We Use Your Information

• Ticket scanning and validation: Ticket images are processed server-side using AI models (OpenAI, Anthropic Claude, xAI/Grok) to detect lottery numbers and validate results.
• Account management: To create and maintain your account, store your scan history, generated plays, and credits.
• Push notifications: To send draw results, jackpot alerts, and other notifications you subscribe to via Firebase Cloud Messaging.
• Subscription management: To process purchases and manage your subscription level through RevenueCat and the App Store / Google Play.
• Advertising: To display ads (rewarded, interstitial, and native) via Google AdMob. Ad serving may use your advertising identifier where permitted.
• Analytics and improvement: To understand how users interact with app and website features and improve the Service. PostHog data can be linked to a Firebase account identifier and must not be described as anonymous or aggregated at collection.
• Security and stability: To detect crashes, diagnose bugs, and monitor app performance via Firebase Crashlytics and Performance Monitoring.
• Remote configuration: To update app behavior (e.g., feature flags, AI model selection) without requiring an app update, via Firebase Remote Config and Firestore.
• Legal compliance: To comply with applicable laws and respond to valid legal requests.

4. Third-Party Services

We integrate the following third-party services. Each operates under its own privacy policy. We encourage you to review them.

For Google's privacy policy, visit policies.google.com/privacy. For RevenueCat, visit revenuecat.com/privacy.

PostHog Product Analytics

When product analytics is enabled after the required privacy review and regional consent checks, PostHog EU Cloud may receive a limited set of events about app opens, scanning and number generation, ticket validation and watch requests, notification interactions, subscription and purchase steps, and website results views and app-store clicks. Event details may include a game category, outcome, duration, feature or purchase category, app version, platform, language, country when known, and a session identifier. We do not intend to include ticket numbers or images, email addresses, push tokens, or text entered by users in these product events.

App and server events use the Firebase account identifier, including for an anonymous Firebase account, so they can be linked to a person. The native PostHog SDK also creates an installation or anonymous identifier, which its identify step can link to that account identifier. The website uses a separate pseudonymous browser identifier after the required consent. When you allow website analytics and an event is sent, PostHog creates a pseudonymous profile for that identifier. We do not send a name or email address with it; the website identifier is not linked to the Firebase account identifier. Website capture requires a working browser consent mechanism; without one it stays off. Product analytics is separate from advertising and crash reporting. Where consent is required, refusing it prevents new capture. Recording a withdrawal stops future capture. Mobile and web SDKs attempt to cancel queued or in-flight sends, but an event already transmitting may still reach PostHog. A backend event already past its final consent check may also arrive. For app analytics linked to an account, a recorded withdrawal starts an asynchronous request to delete the associated PostHog profile and earlier events. Completion is not immediate. Website withdrawal stops future capture; it does not itself delete events already sent under the separate browser identifier. You can request their deletion. Use an applicable in-app privacy-choice control when one is available. Where optional website analytics is enabled, you can refuse or withdraw through the applicable website consent control. If Analytics choices appears at the bottom of a public page, reopen it to change your choice or select Withdraw consent. If a consent platform supplies the choice instead, use its privacy controls. If Analytics choices displays a reference for the current tab, save and include it in a deletion request before withdrawing or closing the tab. It may help us find website events; references from earlier consent periods may be unavailable unless saved, and not every earlier event can be guaranteed to be found. Contact us at support@lottoread.com to request access or deletion of data sent before withdrawal.

5. Advertising & Tracking

Lottoread displays ads through Google AdMob, including rewarded, interstitial, and native ad formats.

• iOS: When you launch the app, you will be shown an App Tracking Transparency (ATT) prompt asking whether you consent to tracking via the IDFA. If you decline, the IDFA is not available for tracking. Which ads, if any, are served depends on your applicable consent choices and the ad-request configuration. You can change the ATT setting in Settings > Privacy & Security > Tracking.
• Android: Google's User Messaging Platform displays a consent dialog for ad personalization in line with GDPR and CCPA requirements. You may withdraw or update consent at any time from within the app settings.
• SKAdNetwork (iOS): We use Apple's SKAdNetwork framework for privacy-preserving ad campaign measurement. No individual-level data leaves your device.
• Opt-out: On Android, you can reset or opt out of ad personalization in Settings > Google > Ads. On iOS, turn off personalized ads in Settings > Privacy & Security > Apple Advertising.

6. Data Sharing

We do not sell your personal information. We share data only in the following circumstances:

• Service providers: The third-party services listed in Section 4 receive data only to the extent necessary to perform their functions.
• AI processing: Ticket images and extracted text are sent to OpenAI, Anthropic, and/or xAI servers for processing. We do not use submitted ticket scans for our own model training or improvement.
• Legal obligations: We may disclose information if required by law, court order, or government authority.
• Business transfers: In the event of a merger, acquisition, or sale of assets, user data may be transferred as part of that transaction.

7. Data Retention

• Account, scan, and ticket data: Account data is kept while your account exists. Saved scan and ticket data is kept until you delete the individual item or request account deletion. Account deletion starts asynchronous removal of account and associated ticket data; provider-held data and backups may take longer to remove. To request account deletion, visit our Account Deletion page.
• Ticket images: Stored in Google Cloud Storage to provide ticket processing and history. Deletion requests are processed asynchronously and may be affected by storage recovery settings.
• Crash and performance data: Firebase Crashlytics keeps crash data and associated identifiers for 90 days before starting removal from live and backup systems. Firebase Performance Monitoring keeps IP-associated events for 30 days, and installation-associated and de-identified data for 60 days, before starting removal from live and backup systems. See Firebase's privacy reference.
• Product analytics: Firebase Analytics events from older installed apps or already-open website sessions may still be sent, and previously collected data may remain under the provider's settings. At our last check on 29 September 2026, PostHog reported no plan-defined limit on how far back product events in our EU Cloud project remain queryable. This describes queryability, not a fixed deletion period. We keep PostHog app event history and its associated profile for product analytics while the account exists and an analytics grant remains recorded. A recorded withdrawal or account-deletion request queues provider erasure; completion is asynchronous. Website event history and its separate pseudonymous browser profile have no configured age-based deletion period. We handle deletion of matched website data through a separate request identifying the relevant browser ID; earlier IDs may be unavailable. Website withdrawal alone stops future capture. We have no confirmed fixed completion time for individual deletion or backup removal.

8. Your Privacy Rights

8.1 EEA, UK & Switzerland (GDPR)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights under the GDPR:

• Right of access — obtain a copy of your personal data
• Right to rectification — correct inaccurate data
• Right to erasure — request deletion of your data
• Right to restriction — limit how we process your data
• Right to data portability — receive your data in a machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time

Our legal bases for processing include: performance of a contract (providing the Service), legitimate interests (security), consent where required for product analytics, advertising identifiers and push notifications, and legal obligation. The basis for crash reporting is assessed separately from advertising and product analytics.

8.2 California Residents (CCPA/CPRA)

California residents have the right to:

• Know what personal information is collected and how it is used
• Request deletion of your personal information
• Opt out of the "sale" or "sharing" of personal information — we do not sell personal information. Advertising identifiers shared with AdMob for ad personalization may qualify as "sharing" under CPRA; you may opt out as described in Section 5
• Non-discrimination for exercising your privacy rights

8.3 Exercising Your Rights

To submit a privacy request, email us at support@lottoread.com. We will respond within 30 days (or sooner as required by applicable law). We may ask you to verify your identity before processing your request.

9. Children's Privacy (COPPA)

The Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@lottoread.com and we will promptly delete such information.

10. Data Security

We implement technical and organizational measures to protect your information, including:

• TLS encryption for all data in transit
• Firebase App Check to prevent unauthorized API access
• Firebase Authentication tokens for secure session management
• Role-based access controls on our backend systems and Google Cloud Storage

No system is completely secure. If you discover a security vulnerability, please report it to support@lottoread.com.

11. International Data Transfers

Our service providers may process or store information in the EEA, the United States, and other countries where they operate. For PostHog product analytics, we use its EU Cloud data center for storage. PostHog and its subprocessors may also process that data outside the EEA, including in the United States, to provide the service. PostHog's data processing agreement sets out its own participation in the EU-US Data Privacy Framework and a Standard Contractual Clauses framework for relevant transfers. See PostHog's data processing agreement and subprocessor list.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date at the top of this page. For material changes, we will notify you via in-app notice or email. Where consent is required for product analytics, we ask for a separate choice; continued use of the Service does not grant that consent.

13. Contact Us

If you have questions, requests, or complaints about this Privacy Policy or our privacy practices, please contact us:

If you are located in the EEA and are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.