🎲 Privacy Policy - MyLotto

Last updated: January 4, 2026

📱 MyLotto respects your privacy. We do not collect personally identifiable information. The app operates in completely anonymous mode. This policy explains what technical information is processed for the app to function.

1. 👤 Data Controller

Carlo Di Giuseppe
Email: info@appjuice.it
Tax Code: DGSCRL76L19H501L
Italy

2. 📊 Data Collected

2.1 Data NOT Collected

MyLotto DOES NOT collect:

❌ Name, surname, or personal information
❌ Email or phone number
❌ GPS location or geolocation
❌ Payment data or credit cards
❌ Browsing history
❌ Behavioral analytics
❌ Identifiable crash reports

2.2 Data Processed Locally (on your device)

The following data is saved only on your iPhone/iPad and is never transmitted to external servers:

✅ Saved tickets: numbers played, selected wheels, type of bet
✅ App preferences: color theme, local notification settings
✅ Draw cache: history of consulted draws (for offline functionality only)

🔒 This data is completely private and accessible only to you. You can delete it at any time by uninstalling the app or going to Settings → Delete all data.

3. ☁️ iCloud Sync (Optional)

3.1 Apple CloudKit

If you have a MyLotto PRO subscription and have enabled iCloud on your device, your tickets are automatically synced across all your Apple devices via CloudKit (Apple service).

Synced data:

Saved tickets (numbers, wheels, bet type)
App preferences

How it works:

Data is end-to-end encrypted by Apple
Accessible only with your Apple ID
MyLotto CANNOT read your iCloud data
Governed by Apple's Privacy Policy: apple.com/legal/privacy

Disable: You can disable iCloud sync in iOS Settings → iCloud → MyLotto (turn off).

4. 🌐 Third-Party Services

4.1 Supabase (Backend Database)

What it does: Provides Italian Lotto draws in real-time via PostgreSQL database.

Data shared with Supabase:

Anonymous API requests (e.g., "give me last 10 draws")
Technical IP address (required for standard internet connection)

No personal data is sent to Supabase. Requests are completely anonymous.

Supabase Privacy Policy: supabase.com/privacy

4.2 Google AdMob (Advertising - FREE version only)

What it does: Displays ads within the app (only for users with free version).

Data collected by AdMob:

📱 Apple Advertising ID (IDFA) - if you gave consent in iOS
🌐 IP address (for approximate geolocation)
📊 Ad interactions (clicks, impressions)
📲 Device type and iOS version

How to manage:

Disable IDFA: iOS Settings → Privacy → Advertising → Limit Ad Tracking
Remove ads: Upgrade to MyLotto PRO (no ads)

Google AdMob Privacy Policy: policies.google.com/privacy

4.3 Apple App Store & In-App Purchases

What it does: Manages in-app purchases (MyLotto PRO subscription).

Data managed by Apple:

💳 Payment data (exclusively managed by Apple, NOT by MyLotto)
🧾 Purchase receipts (for subscription validation)

MyLotto does NOT have access to your payment data or credit card. Everything is managed by Apple.

Apple Privacy Policy: apple.com/legal/privacy

5. 🎯 Purpose of Processing

Data is processed exclusively for:

App functionality: display draws, save tickets, check winnings
iCloud sync: automatic ticket backup (only for PRO users with iCloud enabled)
Personalized advertising: show relevant ads (FREE version only, via Google AdMob)
Subscription management: validate PRO subscription via Apple

6. 🔐 Data Security

Security measures implemented:

✅ HTTPS encryption: all server communications are encrypted (TLS 1.3)
✅ Encrypted local cache: data saved on iOS protected by system encryption
✅ No proprietary server: zero risk of data breach (using only Apple and Supabase certified services)
✅ Secure source code: app developed following Apple Security Guidelines

7. ⏱️ Data Retention

Data Type	Retention Period
Saved tickets (local)	Until you manually delete them
Draw cache (local)	Maximum 30 days (then automatically deleted)
iCloud data (tickets)	Until you disable iCloud or delete the app
AdMob logs (IP, IDFA)	Maximum 18 months (managed by Google)

8. ⚖️ Your Rights (GDPR)

In accordance with EU Regulation 2016/679 (GDPR), you have the right to:

🔍 Access: know what data is processed (you can write to info@appjuice.it)
✏️ Rectification: correct inaccurate data
🗑️ Erasure: delete all your data (uninstall app + delete from iCloud)
⛔ Objection: object to advertising processing (disable IDFA in iOS)
📦 Portability: export your tickets (Settings → Export Data)
🚫 Restriction: restrict processing

How to exercise rights: Write to info@appjuice.it with subject "GDPR - MyLotto". We will respond within 30 days.

9. 🧒 Children's Privacy

⚠️ MyLotto is for adults only (+18 years).

The app provides information about the Lotto game, which is prohibited for minors in Italy. We do not knowingly collect data from children under 18. If we discover that a minor has provided data, we will delete it immediately.

10. 🌍 International Data Transfers

Some services used may transfer data outside the European Union:

Supabase: EU servers (Frankfurt, Germany) - no extra-EU transfer
Google AdMob: Possible transfer to USA (Google adheres to EU-US Data Privacy Framework)
Apple iCloud: Apple servers with end-to-end encryption (GDPR compliant)

All extra-EU transfers comply with standard contractual clauses approved by the European Commission.

11. 🔄 Changes to Privacy Policy

This Privacy Policy may be updated periodically. In case of substantial changes, we will notify you via:

📢 In-app notification on first launch
📧 Email (if provided for support)
📄 Update of "Last updated" date at the top of this page

We recommend checking this page periodically.

12. 🎰 Responsible Gaming

MyLotto is an informational tool. Gambling can cause addiction. Play responsibly and within your financial means.

Useful resources:

Responsible Gaming Helpline (Italy): 800 558 822
ADM (Italian Customs and Monopolies Agency): adm.gov.it

13. ⚖️ Applicable Law

This Privacy Policy is governed by Italian law and the GDPR (EU Regulation 2016/679).

For any dispute, the competent court is that of the user's residence/domicile (if consumer).

📞 Contact

For questions, requests, or to exercise GDPR rights, contact us:

Email: info@appjuice.it
Developer: Carlo Di Giuseppe
Tax Code: DGSCRL76L19H501L
Country: Italy

Response time: within 30 business days