Privacy Statement

Effective Date: January 1, 2025

Introduction

LottoSpark Inc. ("we," "us," or "our") is committed to protecting your personal information and your right to privacy. This Privacy Statement explains how we collect, use, disclose, and safeguard your information when you visit our website and use our number draw participation services.

This statement applies to all personal information collected through our platform, including through mobile applications, third-party websites, and any related services (collectively, the "Services").

Information We Collect

Personal Information You Provide

We collect personal information that you voluntarily provide when registering for an account, making a purchase, or contacting us. This includes:

• Identity Information: Full name, date of birth, government-issued ID details
• Contact Information: Email address, phone number, mailing address
• Account Credentials: Username, password, security questions and answers
• Financial Information: Payment card details, billing address, transaction history
• Verification Data: Age verification documents, identity verification materials
• Communication Data: Messages, inquiries, and feedback you send to us

Information Automatically Collected

When you access our Services, we automatically collect certain information about your device and usage patterns:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages viewed, time spent on pages, click patterns, navigation paths
• Location Data: General geographic location based on IP address
• Technical Data: Screen resolution, language preferences, time zone settings
• Cookies and Tracking: Information collected through cookies and similar technologies (see our Cookie Policy)

Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment processors and financial institutions
• Identity verification service providers
• Marketing and analytics partners
• Provincial gaming regulatory authorities
• Public databases and government registries

How We Use Your Information

We use your personal information for the following purposes:

Service Delivery

• Create and manage your account
• Process ticket purchases and transactions
• Verify your identity and age
• Deliver tickets and prize notifications
• Provide customer support and respond to inquiries

Legal and Regulatory Compliance

• Comply with provincial gaming regulations and legislation
• Verify eligibility to participate in number draws
• Detect and prevent fraud, money laundering, and illegal activities
• Maintain records for audit and reporting purposes
• Respond to legal requests and enforce our terms

Platform Improvement

• Analyze usage patterns to improve functionality
• Conduct research and testing of new features
• Monitor and maintain platform security
• Optimize performance and user experience

Marketing and Communications

• Send promotional offers and draw information (with your consent)
• Deliver account updates and service notifications
• Provide personalized content and recommendations
• Conduct surveys and gather feedback

How We Share Your Information

We may share your personal information in the following circumstances:

Service Providers

We share information with trusted third-party vendors who perform services on our behalf, including payment processing, identity verification, customer support, marketing, analytics, and security monitoring. These providers are contractually obligated to protect your data and use it only for specified purposes.

Legal Authorities and Regulators

We disclose information to provincial gaming authorities, law enforcement, and other government agencies when required by law or necessary to comply with legal obligations, protect our rights, or ensure platform security.

Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections.

With Your Consent

We may share your information for other purposes with your explicit consent or at your direction.

Data Security

We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• SSL/TLS encryption for data transmission
• Encrypted storage of sensitive information
• Regular security audits and vulnerability assessments
• Access controls and authentication requirements
• Employee training on data protection practices
• Incident response and breach notification procedures

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but maintain ongoing efforts to safeguard your data.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law. Retention periods vary based on:

• The nature of the information and how it is used
• Regulatory requirements imposed by provincial gaming authorities
• Legal obligations, including tax and financial reporting
• Dispute resolution and legal defense needs
• Your preferences regarding marketing communications

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies.

Your Privacy Rights

Under Canadian privacy legislation, including PIPEDA and provincial privacy laws, you have the following rights:

Right to Access

You can request access to the personal information we hold about you and receive a copy of your data.

Right to Correction

You can request that we correct inaccurate or incomplete personal information.

Right to Deletion

You can request deletion of your personal information, subject to legal and regulatory retention requirements.

Right to Withdraw Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time.

Right to Opt-Out

You can opt out of marketing communications at any time by clicking "unsubscribe" in emails or contacting us directly.

To exercise any of these rights, please contact our Privacy Officer using the contact information below. We will respond to your request within the timeframe required by applicable law.

Children's Privacy

Our Services are not intended for individuals under the age of majority in their province or territory (18+ or 19+). We do not knowingly collect personal information from minors. If we become aware that we have collected information from someone under the legal age, we will promptly delete that information.

Parents or guardians who believe we have inadvertently collected information from a minor should contact us immediately.

International Data Transfers

Your personal information may be transferred to and processed in jurisdictions outside of Canada where our service providers are located. When we transfer data internationally, we ensure adequate safeguards are in place to protect your information in accordance with Canadian privacy standards.

Changes to This Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting a notice on our website or sending you an email.

The "Effective Date" at the top of this statement indicates when it was last updated. We encourage you to review this statement periodically to stay informed about how we protect your information.

Contact Us

If you have questions, concerns, or complaints about this Privacy Statement or our privacy practices, please contact our Privacy Officer:

Filing a Complaint

If you believe your privacy rights have been violated, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada: