Privacy Policy
At Lotando, we care deeply about privacy.
We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Lotando.
This policy explains our privacy practices for Lotando.com (which we’ll refer to as the "Site"), Lotando’s mobile applications (the "App"), ("Lotando," together with "we," "us," and "our"). We'll refer to the Site and the App as the "Services." This policy does not apply to the practices of third parties (including other members who sell using the Services) who may also collect or receive data in connection with your use of the Services.
Our Privacy Policy
Information Collected or Received
Messages from Lotando
Information Uses, Sharing, & Disclosure
Transfers
Security
Retention
Your Rights & Choices
Your Responsibilities
Privacy Policy Changes
Contact
1. Our Privacy Policy
We process your personal information to run our business and provide our users with the Services. By accepting our Terms of Use (and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of third-party websites and App.
Lotando’s Terms of Use require all account owners to be at least 18 years of age.
By using the Services, you acknowledge that Lotando will use your information in any country where Lotando operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the "Transfers" Section of this policy.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our Sellers and suppliers that help provide Lotando services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. Lotando uses the personal information it receives and collects in accordance with the purposes described in this policy.
You may choose to link your bank account to pay for purchases (or receive payment in the case of Sellers) through a third-party service available through the Site or App. Lotando does not have a direct partner relationship with these third parties and their processing of information is subject to their own privacy policies. You should understand the privacy and security practices of any third party before you share information with them.
Registration, Account Setup, Service Usage: In order to use the Services, you will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as a shop name, billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. For example, we need a physical postal address if you are buying something on the Site for delivery. As an Lotando Seller, in order to process payments, Lotando requires your full name, identification ID or tax ID, date of birth, bank account information, photograph, credit card information, and/or other proof of identification in order to verify your identity, provide this service to you, and comply with applicable law. For both buyers and Sellers, Lotando requires this information from you in order to provide you with the Services (including, to verify ownership of an account, to mitigate fraud and abuse, to comply with regulatory obligations, or to complete a transaction as a buyer or Seller). We may store credit card information and other information provided to us during checkout, for billing and payment purposes, and to process your transaction. Members in certain countries can elect to save their credit card information to facilitate checkout for future purchases. If you're an Lotando buyer in the EU, Norway, Iceland, Liechtenstein or the United Kingdom, you may be asked to authenticate your payment method when you place your order. To authenticate a payment, you will need to respond to a prompt from your card issuer and provide additional information, such as a correct response to a question, a password, or a passcode. Lotando may contact individual Sellers confidentially to request more information about their shops or items listed through the Services, or may request information from buyers to ensure compliance with our policies and applicable law. In order to use certain products or services on Lotando, you may be required to complete an application; information that you submit through the application process will not be displayed publicly and will only be used internally by Lotando and its service providers, unless otherwise specified.
Profile: You may provide your name and other personal information (such as birthday, gender, location) in connection with your account and activity. You can edit or remove this information through your account settings. The name associated with your account (which you may modify in your account settings) is connected to your Lotando activity. For Sellers, we may collect and use information about you in order to feature you in marketing and advocacy materials, and to feature you and your shop on and off the platform, as provided for in Lotando’s Terms of Use or as otherwise legally required.
Automated Information: Lotando automatically receives and records information from your browser or your mobile device when you visit the Site, use the App, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Lotando may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.
Data from Lotando Sellers: We also receive information from our Sellers about you. This information can include customer service interactions, payments information, shipping information.
Data from Advertising and Marketing Partners: As described below, Lotando receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to Lotando comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.
Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the App, you can choose to share your geolocation details with Lotando in order to use functions.
We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for Lotando’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and using approximate location information, such as a city or country, for marketing and personalizing and tailoring our Services to you. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the App or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also choose to enable the App to access your mobile device’s camera to upload photographs to Lotando.
Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the App, what happens within the App, aggregated usage, performance data, app errors and debugging information, and where the App were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see Lotando's Cookies and Similar Technologies Policy and Disclosures.
Information from Third Parties: Some members or visitors may choose to connect to Lotando or register a Lotando account using an external third-party application, such as Facebook. Connecting your Lotando account to third-party applications or services is optional. If you choose to connect your account to a third-party application, it is subject to your agreements with that third party (like their Terms of Use and privacy notices), and Lotando can receive information from that application. We may also collect public information in order to connect with you, such as when we communicate with you over social media. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on Lotando on certain social media networks which are connected to your Lotando account, and you can revoke your permission anytime in your account settings. Certain third-party applications that you use to create or sign in to your account may provide you with the option to discontinue receiving messages from us or allows you to forward those messages to another email address. If we are unable to send you critical messages about your account, we may suspend or terminate your account.
Non-Member Information: Lotando receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered Lotando member (a “non-member”) in connection with certain Lotando features, such as when a non-member chooses to subscribe to an Lotando newsletter, a member invites a non-member to visit the Site, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to Lotando, for purposes necessary to the functioning of Lotando's Services or where Lotando has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorized by a member or the non-member.
3. Messages from Lotando
On occasion, Lotando will need to contact you. Primarily, these messages are delivered by email, Lotando Messages, or by push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Messages in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Lotando may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, Lotando may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, for security purposes when you enable two factor authentication in your account, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.
Some messages from Lotando are service-related and necessary for members and Guest Checkout users. You understand and agree that Lotando can send you non-marketing emails, Lotando Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Messages with buyers, and correspondence with Lotando’s Support team (including by chat interface or the other methods of communication as described above).
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in such emails, advocacy emails or messages. Members can also control which marketing emails or messages they receive from Lotando through their account settings. Please note that some changes to your account settings may take a few days to take effect.
4. Information Uses, Sharing, & Disclosure
We respect your privacy. Lotando will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.
Legal Bases
When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
You have consented to the processing, which you can revoke at any time;
Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
You have expressly made the information public;
Necessary in the public interest, such as to prevent crime; and
Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).
We principally rely on consent (which can be withdrawn at any time) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our Sellers may advertise our Services or our Sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy. These partners have their own privacy policies and consent mechanisms for their customers, in addition to Lotando’s controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them, in our Cookies and Similar Technology Disclosures.
Lotando may also use first party data (e.g. your prior shopping and browsing patterns on our Site), and may combine it with other data collected from you or received from our advertising and marketing partners, such as your location, or publicly available information, to permit us to create targeted audiences based on your known or inferred demographic and/or interests to provide you with more relevant and useful advertising on our Site or App (including personalizing and tailoring our Services to you), in our direct marketing channels (like email), or with our off site marketing partners, like Google and Facebook, subject to their terms and privacy notice you agreed to with such partners.
Our Legitimate Interests
Where we process your information on the basis of legitimate interests, we do so as follow:
Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help Sellers find the best ways to market and sell their products on Lotando.
Providing Marketing Communications:
We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for Lotando's advertising programs (including Lotando’s on-site advertising and marketing).
Keeping our Services Safe and Secure:
We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Lotando’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, fraud and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with Lotando or other members.
Buying and Selling:
As part of the buying and selling process, Lotando will facilitate the sharing of information between the two members involved in the transaction, such as the other Lotando member's shipping address, email address, and payment status. This can also involve us sharing your information with some of our third party partners such as our shipping and payment partners to enable us to provide the Service to you. Such partners will process your personal information in accordance with their own privacy policies. In some instances, while they are subject to Lotando’s privacy and security requirements for Sellers, these partners, not Lotando, are responsible for the protection of personal information under their control. By making a sale or a purchase on Lotando, you are directing us to share your information in this way. Since this is an important part of the Services we provide, we need to do this in order to perform our obligations under our Terms of Use. We may partner with third parties to enable you to make a purchase from an Lotando Seller on that third party’s website or mobile app. The third parties' terms of service, privacy policy, and other policies may apply, in addition to Lotando’s own policies, and they will collect information directly from you in connection with your purchase. The third party partner will share information collected from you with Lotando for purposes of fulfilling the order and for any other purpose disclosed to you at the time you provide your information. As a Seller, we expect you to respect the privacy of the member whose information you have received. As described in Lotando's Terms of Use, you, as a Seller, have a limited license to use that information only for Lotando-related communications or for Lotando-facilitated transactions. Lotando has not granted a license to you to use the information for unauthorized transactions or sending unsolicited commercial messages in violation of any applicable laws, including any consent requirements of the jurisdiction of the recipient. You should only store a member’s personal information in accordance with applicable laws, including any consent requirements that apply in that member's jurisdiction.
Site Customization:
We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site or App and use such information to suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help Sellers find the best ways to market and sell their products on Lotando.
Legal and Safety:
Lotando may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies (including our Intellectual Property Policy); to comply with a subpoena, court order, legal process, regulation, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of Lotando's Terms of Use. For example, if permitted due to the forgoing circumstances, your information may be shared with tax authorities or other governmental agencies. In the cases set out above, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims or to facilitate the collection of taxes and prevention of tax fraud. It may also be necessary in the public interest (such as to prevent crime or fraud) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).
If Lotando receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Lotando may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details.
Affiliated Businesses:
Lotando is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. These businesses may sell items or services to you through the Services or, with your consent, offer promotions (including email promotions) to you. Lotando also provides services or sells products jointly with affiliated businesses, including providing you with the opportunity to sign up with such partners and allow them to more effectively market to you. When an affiliated business assists in facilitating your transaction, we may need to share information related to the transaction with that affiliated business in order to facilitate your transaction, and this forms part of the Services we provide in accordance with our Terms of Use. We rely on consent (which can be withdrawn at any time) to send marketing messages and for third-party sharing relating to advertising. As part of this, we may work with advertising partners such as Facebook or Google, and we may use analytics aggregated from usage information including, for example, search keywords, favorites, browsing history, and purchase history.
Aggregated Information:
Lotando may share demographic information with business partners, but unless otherwise stated, it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers:
Lotando also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Lotando not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
Business Reorganization:
In some cases, Lotando may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of Lotando’s assets), member information is typically one of the business assets that is transferred. If Lotando intends to transfer information about you, Lotando will notify you by email or by putting a prominent notice on the Site and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.
Third Parties:
Third-party plug-ins also collect information about your use of the Site. For example, when you load a page on Lotando that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. Lotando chooses and manages these third-party technologies placed on its Sites and App. However, these are third-party technologies, and they are subject to that third party's privacy policy. For more information, see our Cookies & Similar Technologies Policy. We rely on your consent to drop and read these cookies when not technically necessary or when not required based on another purpose such as legitimate interest.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services) that Lotando does not own or control or individuals that Lotando does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Lotando requires these third parties to follow Lotando’s privacy and security requirements, Lotando does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Lotando is not responsible for the privacy or security practices of these Sellers or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these Sellers and third party providers are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
5. Transfers
Lotando operates a global service. By using our Services, you understand that Lotando may share some of the information it gathers with Lotando.com and / or the App or other Lotando affiliates for purposes described in this privacy policy, including for ID verification, transaction reviews, and payment processing.
The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.
To the extent that Lotando is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:
Model Clauses
The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe.
Necessary for the Performance of the Contract between Lotando and its Members
Lotando provides a voluntary service; you can choose whether or not to use the Services. As we operate in countries worldwide and use technical infrastructure worldwide to deliver the Services to you, in accordance with the contract between us (our Terms of Use), we need to transfer your personal information worldwide as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.
6. Security
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. Lotando offers advanced security features and settings for members, such as two-factor authentication for signing in.
7. Retention
Lotando will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Lotando member account), or as needed to provide the Services to you. If you no longer want Lotando to use your information to provide the Services to you, you may close your account. Lotando will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Lotando Sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
8. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Lotando gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Lotando account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
Right to Access & Portability:
You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. See this Help Center article for more information.
Right to Correction:
You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
Right to Restrict Processing:
In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
Right to Deletion:
In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Lotando.
Right to Object:
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
Right to Withdraw Consent:
Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
The CCPA provides California residents with the following additional rights:
Right to Know:
California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
Right to Opt-Out:
To the extent that Lotando “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can do so via your Lotando account settings. Alternatively, you can exercise any of the rights above by contacting us by submitting a message through our contact form available in our Site or App, chat support, or through any other channels available via our Ste or App. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
Email & Messages
You may also control the receipt of certain types of communications from Lotando in your account settings. Lotando may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from Lotando” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
Cookies
We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies.
Additional Disclosures for California Residents
Notice of Collection
In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:
Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
Commercial information, including purchases and engagement with the Services.
Internet activity, including your interactions with our Services and what led you to our Services.
Sensory visual data, such as pictures posted on our Service.
Geolocation data provided through location enabled services such as WiFi and GPS.
Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.
Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
Lotando does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to Sellers on Lotando (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of Lotando, or unless you request us to or consent to it, Lotando does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below.
9. Your Responsibilities
If you sell using our Services, you may receive and determine what to do with certain personal information. Your privacy responsibilities, including when you act as an independent data controller (someone who decides what personal data to collect and the purpose you use the data for) are laid out in the Lotando Seller Policy and the Lotando Terms of Use.
10. Privacy Policy Changes
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the App’ platform. We encourage you to check back regularly and review any updates.
11. Contact
If you have any questions:
Contact Lotando’s Support team via our form “Contact us” in the footer of the Site or the App.
We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by Lotando.
This policy explains our privacy practices for Lotando.com (which we’ll refer to as the "Site"), Lotando’s mobile applications (the "App"), ("Lotando," together with "we," "us," and "our"). We'll refer to the Site and the App as the "Services." This policy does not apply to the practices of third parties (including other members who sell using the Services) who may also collect or receive data in connection with your use of the Services.
Our Privacy Policy
Information Collected or Received
Messages from Lotando
Information Uses, Sharing, & Disclosure
Transfers
Security
Retention
Your Rights & Choices
Your Responsibilities
Privacy Policy Changes
Contact
1. Our Privacy Policy
We process your personal information to run our business and provide our users with the Services. By accepting our Terms of Use (and in some jurisdictions, by acknowledging this policy), you confirm that you have read and understand this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of third-party websites and App.
Lotando’s Terms of Use require all account owners to be at least 18 years of age.
By using the Services, you acknowledge that Lotando will use your information in any country where Lotando operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information as more fully described in the "Transfers" Section of this policy.
2. Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. We obtain the categories of personal information listed below from the following sources: directly from you, for example, from forms you complete or during registration; indirectly from you based on your activity and interaction with our Services, or from the device or browser you use to access the Services; from our Sellers and suppliers that help provide Lotando services you may interact with (such as, for example, for payments or customer support), and from our third party advertising and marketing partners. Often, you choose what information to provide, but sometimes we require certain information to provide you the Services. Lotando uses the personal information it receives and collects in accordance with the purposes described in this policy.
You may choose to link your bank account to pay for purchases (or receive payment in the case of Sellers) through a third-party service available through the Site or App. Lotando does not have a direct partner relationship with these third parties and their processing of information is subject to their own privacy policies. You should understand the privacy and security practices of any third party before you share information with them.
Registration, Account Setup, Service Usage: In order to use the Services, you will need to submit a valid email address. If you register, you will need to submit a name associated with your account. You may modify that name through your account settings. You need to provide this information to enable us to provide you with the Services. Additional information, such as a shop name, billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address, may be necessary in order for us to provide a particular service. For example, we need a physical postal address if you are buying something on the Site for delivery. As an Lotando Seller, in order to process payments, Lotando requires your full name, identification ID or tax ID, date of birth, bank account information, photograph, credit card information, and/or other proof of identification in order to verify your identity, provide this service to you, and comply with applicable law. For both buyers and Sellers, Lotando requires this information from you in order to provide you with the Services (including, to verify ownership of an account, to mitigate fraud and abuse, to comply with regulatory obligations, or to complete a transaction as a buyer or Seller). We may store credit card information and other information provided to us during checkout, for billing and payment purposes, and to process your transaction. Members in certain countries can elect to save their credit card information to facilitate checkout for future purchases. If you're an Lotando buyer in the EU, Norway, Iceland, Liechtenstein or the United Kingdom, you may be asked to authenticate your payment method when you place your order. To authenticate a payment, you will need to respond to a prompt from your card issuer and provide additional information, such as a correct response to a question, a password, or a passcode. Lotando may contact individual Sellers confidentially to request more information about their shops or items listed through the Services, or may request information from buyers to ensure compliance with our policies and applicable law. In order to use certain products or services on Lotando, you may be required to complete an application; information that you submit through the application process will not be displayed publicly and will only be used internally by Lotando and its service providers, unless otherwise specified.
Profile: You may provide your name and other personal information (such as birthday, gender, location) in connection with your account and activity. You can edit or remove this information through your account settings. The name associated with your account (which you may modify in your account settings) is connected to your Lotando activity. For Sellers, we may collect and use information about you in order to feature you in marketing and advocacy materials, and to feature you and your shop on and off the platform, as provided for in Lotando’s Terms of Use or as otherwise legally required.
Automated Information: Lotando automatically receives and records information from your browser or your mobile device when you visit the Site, use the App, or use certain features of the Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. Lotando may also receive similar information (like, for example, IP addresses and actions taken on the device) provided by a connected Internet of Things device such as a voice-activated assistant or Smart TV. We may combine this information from your browser or your mobile device with other information that we or our advertising or marketing partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for members and visitors, and to provide advertising, including across your devices, and a more personalized experience for members and visitors.
We also automatically collect device-specific information when you install, access, or use our Services. This information can include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing, & Disclosure” Section below.
Data from Lotando Sellers: We also receive information from our Sellers about you. This information can include customer service interactions, payments information, shipping information.
Data from Advertising and Marketing Partners: As described below, Lotando receives information from our advertising and marketing partners about you. This information can include attribution information via cookies and UTM tags in URLs to determine where a visit to Lotando comes from, responses to marketing emails and advertisements, responses to offers, and audience information from partners who you have given consent to share that information with us.
Location Information: We collect information about your use of the Services for advertising, for analytics, to serve content, and to protect the Services. This can include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the App, you can choose to share your geolocation details with Lotando in order to use functions.
We obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We use and store information about your location to provide features and to improve and customize the Services, for example, for Lotando’s internal analytics and performance monitoring; localization, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and using approximate location information, such as a city or country, for marketing and personalizing and tailoring our Services to you. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the App or on your mobile device. Certain non-precise location services, such as for security and localized policies based on your IP address or submitted address, are critical for the Site to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also choose to enable the App to access your mobile device’s camera to upload photographs to Lotando.
Analytics Information: We use data analytics software to ensure Site and App functionality and to improve the Services. This software records information such as how often you use the App, what happens within the App, aggregated usage, performance data, app errors and debugging information, and where the App were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application. For more information, see Lotando's Cookies and Similar Technologies Policy and Disclosures.
Information from Third Parties: Some members or visitors may choose to connect to Lotando or register a Lotando account using an external third-party application, such as Facebook. Connecting your Lotando account to third-party applications or services is optional. If you choose to connect your account to a third-party application, it is subject to your agreements with that third party (like their Terms of Use and privacy notices), and Lotando can receive information from that application. We may also collect public information in order to connect with you, such as when we communicate with you over social media. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on Lotando on certain social media networks which are connected to your Lotando account, and you can revoke your permission anytime in your account settings. Certain third-party applications that you use to create or sign in to your account may provide you with the option to discontinue receiving messages from us or allows you to forward those messages to another email address. If we are unable to send you critical messages about your account, we may suspend or terminate your account.
Non-Member Information: Lotando receives or obtains information (for example, an email address or IP address) about a person who is not yet a registered Lotando member (a “non-member”) in connection with certain Lotando features, such as when a non-member chooses to subscribe to an Lotando newsletter, a member invites a non-member to visit the Site, a member uploads non-member information using the contact uploader feature, a non-member engages in a transaction, a member sends a gift card code to a non-member, or a non-member uses Guest Checkout to make a purchase. Non-member information is used only for the purposes disclosed when it was submitted to Lotando, for purposes necessary to the functioning of Lotando's Services or where Lotando has a legitimate interest, as disclosed in the “Information Uses, Sharing, & Disclosure” Section below, or to facilitate action authorized by a member or the non-member.
3. Messages from Lotando
On occasion, Lotando will need to contact you. Primarily, these messages are delivered by email, Lotando Messages, or by push notifications for a variety of reasons, including marketing, transactions, advocacy, and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email or Messages in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. Lotando may also contact you by telephone to provide member support or for transaction-related purposes if you request that we call you. Additionally, and with your consent where required by applicable law, Lotando may send you an SMS (or similar) message, or reach out to you by telephone, in order to provide you with customer support, for research or feedback, for security purposes when you enable two factor authentication in your account, or to provide you with information about products and features that you may find of interest. You can update your contact preferences in your account settings.
Some messages from Lotando are service-related and necessary for members and Guest Checkout users. You understand and agree that Lotando can send you non-marketing emails, Lotando Messages, or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Messages with buyers, and correspondence with Lotando’s Support team (including by chat interface or the other methods of communication as described above).
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number such as for a Guest Checkout purchase, you receive notice of and agree (in some jurisdictions and situations, by an additional unambiguous consent) to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails or messages through the opt-out link included in such emails, advocacy emails or messages. Members can also control which marketing emails or messages they receive from Lotando through their account settings. Please note that some changes to your account settings may take a few days to take effect.
4. Information Uses, Sharing, & Disclosure
We respect your privacy. Lotando will not disclose your name, email address, or other personal information to third parties without your consent, except as specified in this policy.
Legal Bases
When you access or use the Services, we collect, use, share, and otherwise process your personal information for the purposes described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
Necessary to perform the contractual obligations in our Terms of Use and in order to provide the Services to you;
You have consented to the processing, which you can revoke at any time;
Necessary to comply with a legal or regulatory obligation, a court order, or to exercise or defend any impending or asserted legal claims;
Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners (described in more detail below);
You have expressly made the information public;
Necessary in the public interest, such as to prevent crime; and
Occasionally necessary to protect your vital interests or those of others (in rare cases where we may need to share information to prevent loss of life or personal injury).
We principally rely on consent (which can be withdrawn at any time) (i) to send marketing messages, (ii) for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes.
We rely on consent for targeted online and offline marketing including through tools like Facebook Custom Audience and Google Customer Match. We or our Sellers may advertise our Services or our Sellers’ products through a variety of different mediums and rely on your consent to do so off-site. As part of this, we may work with advertising partners such as Facebook, Google, and other partners disclosed in our Cookies and Similar Technology Policy. These partners have their own privacy policies and consent mechanisms for their customers, in addition to Lotando’s controls. You may see the privacy policies and privacy choices for these partners, and the information you share with them, in our Cookies and Similar Technology Disclosures.
Lotando may also use first party data (e.g. your prior shopping and browsing patterns on our Site), and may combine it with other data collected from you or received from our advertising and marketing partners, such as your location, or publicly available information, to permit us to create targeted audiences based on your known or inferred demographic and/or interests to provide you with more relevant and useful advertising on our Site or App (including personalizing and tailoring our Services to you), in our direct marketing channels (like email), or with our off site marketing partners, like Google and Facebook, subject to their terms and privacy notice you agreed to with such partners.
Our Legitimate Interests
Where we process your information on the basis of legitimate interests, we do so as follow:
Providing and Improving our Services: We use your information to improve and customize our Services, including sharing your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help Sellers find the best ways to market and sell their products on Lotando.
Providing Marketing Communications:
We rely on our legitimate interest to send you marketing messages (where permitted independent of consent) and for Lotando's advertising programs (including Lotando’s on-site advertising and marketing).
Keeping our Services Safe and Secure:
We use your information for safety and security purposes, which can include sharing your information for such purposes, and we do so because it is necessary to pursue our legitimate interests or those of a third party in ensuring the security of our Services, preventing harm to individuals or property, or crime, enforcing or defending legal rights, or preventing damage to Lotando’s systems, or those of our users or our partners. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, fraud and security risks of all kinds. We use your information to provide and improve the Services, for billing and payments, for identification and authentication, and for general research and aggregate reporting. For example, in accordance with our existing case resolution process, we may use information you provide to resolve disputes with Lotando or other members.
Buying and Selling:
As part of the buying and selling process, Lotando will facilitate the sharing of information between the two members involved in the transaction, such as the other Lotando member's shipping address, email address, and payment status. This can also involve us sharing your information with some of our third party partners such as our shipping and payment partners to enable us to provide the Service to you. Such partners will process your personal information in accordance with their own privacy policies. In some instances, while they are subject to Lotando’s privacy and security requirements for Sellers, these partners, not Lotando, are responsible for the protection of personal information under their control. By making a sale or a purchase on Lotando, you are directing us to share your information in this way. Since this is an important part of the Services we provide, we need to do this in order to perform our obligations under our Terms of Use. We may partner with third parties to enable you to make a purchase from an Lotando Seller on that third party’s website or mobile app. The third parties' terms of service, privacy policy, and other policies may apply, in addition to Lotando’s own policies, and they will collect information directly from you in connection with your purchase. The third party partner will share information collected from you with Lotando for purposes of fulfilling the order and for any other purpose disclosed to you at the time you provide your information. As a Seller, we expect you to respect the privacy of the member whose information you have received. As described in Lotando's Terms of Use, you, as a Seller, have a limited license to use that information only for Lotando-related communications or for Lotando-facilitated transactions. Lotando has not granted a license to you to use the information for unauthorized transactions or sending unsolicited commercial messages in violation of any applicable laws, including any consent requirements of the jurisdiction of the recipient. You should only store a member’s personal information in accordance with applicable laws, including any consent requirements that apply in that member's jurisdiction.
Site Customization:
We may learn about the types of products that you’re interested in from your browsing and purchasing behavior on (and off) the Site or App and use such information to suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customizing your on-site experience to help you search for and discover relevant items and recommended purchases, including using this information to help Sellers find the best ways to market and sell their products on Lotando.
Legal and Safety:
Lotando may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against impending or asserted legal claims, including to collect a debt, or a material violation of our policies (including our Intellectual Property Policy); to comply with a subpoena, court order, legal process, regulation, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our rights or property, or violations of Lotando's Terms of Use. For example, if permitted due to the forgoing circumstances, your information may be shared with tax authorities or other governmental agencies. In the cases set out above, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims or to facilitate the collection of taxes and prevention of tax fraud. It may also be necessary in the public interest (such as to prevent crime or fraud) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).
If Lotando receives a lawful, verified request for a member’s records or information in one of the limited circumstances described in the previous paragraph, Lotando may disclose personal information, which may include, but may not be limited to, a member’s name, address, phone number, email address, company/trading name and, where appropriate, bank account and transaction details.
Affiliated Businesses:
Lotando is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. These businesses may sell items or services to you through the Services or, with your consent, offer promotions (including email promotions) to you. Lotando also provides services or sells products jointly with affiliated businesses, including providing you with the opportunity to sign up with such partners and allow them to more effectively market to you. When an affiliated business assists in facilitating your transaction, we may need to share information related to the transaction with that affiliated business in order to facilitate your transaction, and this forms part of the Services we provide in accordance with our Terms of Use. We rely on consent (which can be withdrawn at any time) to send marketing messages and for third-party sharing relating to advertising. As part of this, we may work with advertising partners such as Facebook or Google, and we may use analytics aggregated from usage information including, for example, search keywords, favorites, browsing history, and purchase history.
Aggregated Information:
Lotando may share demographic information with business partners, but unless otherwise stated, it will be aggregated and de-personalized so that personal information is not revealed.
Service Providers:
Lotando also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Lotando not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide the Services to you, particularly where such companies play important roles like helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
Business Reorganization:
In some cases, Lotando may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of Lotando’s assets), member information is typically one of the business assets that is transferred. If Lotando intends to transfer information about you, Lotando will notify you by email or by putting a prominent notice on the Site and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.
Third Parties:
Third-party plug-ins also collect information about your use of the Site. For example, when you load a page on Lotando that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. Lotando chooses and manages these third-party technologies placed on its Sites and App. However, these are third-party technologies, and they are subject to that third party's privacy policy. For more information, see our Cookies & Similar Technologies Policy. We rely on your consent to drop and read these cookies when not technically necessary or when not required based on another purpose such as legitimate interest.
This policy does not apply to the practices of third parties (such as other members who sell using the Services, certain third-party providers on whom we rely to provide certain services) that Lotando does not own or control or individuals that Lotando does not employ or manage, except as otherwise provided for in the Terms or as required by law. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While Lotando requires these third parties to follow Lotando’s privacy and security requirements, Lotando does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, Lotando is not responsible for the privacy or security practices of these Sellers or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these Sellers and third party providers are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
5. Transfers
Lotando operates a global service. By using our Services, you understand that Lotando may share some of the information it gathers with Lotando.com and / or the App or other Lotando affiliates for purposes described in this privacy policy, including for ID verification, transaction reviews, and payment processing.
The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law.
To the extent that Lotando is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:
Model Clauses
The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of Europe. We often use these Model Clauses when transferring personal information outside of Europe.
Necessary for the Performance of the Contract between Lotando and its Members
Lotando provides a voluntary service; you can choose whether or not to use the Services. As we operate in countries worldwide and use technical infrastructure worldwide to deliver the Services to you, in accordance with the contract between us (our Terms of Use), we need to transfer your personal information worldwide as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.
6. Security
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received, for example encryption is used for certain information (such as credit card numbers) using TLS (transport layer security). Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.
Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. Lotando offers advanced security features and settings for members, such as two-factor authentication for signing in.
7. Retention
Lotando will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Lotando member account), or as needed to provide the Services to you. If you no longer want Lotando to use your information to provide the Services to you, you may close your account. Lotando will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Lotando Sellers may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
8. Your Rights & Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Lotando gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Lotando account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
Right to Access & Portability:
You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used. See this Help Center article for more information.
Right to Correction:
You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
Right to Restrict Processing:
In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
Right to Deletion:
In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Lotando.
Right to Object:
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
Right to Withdraw Consent:
Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
The CCPA provides California residents with the following additional rights:
Right to Know:
California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
Right to Opt-Out:
To the extent that Lotando “sells” personal information(as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can do so via your Lotando account settings. Alternatively, you can exercise any of the rights above by contacting us by submitting a message through our contact form available in our Site or App, chat support, or through any other channels available via our Ste or App. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
Email & Messages
You may also control the receipt of certain types of communications from Lotando in your account settings. Lotando may send you messages about the Services or your activity. Some of these messages are required, service-related messages for members (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from Lotando” Section of this policy. If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
Cookies
We use both technically necessary (for the functioning and security of the Services) and non-technically necessary cookies and similar technologies.
Additional Disclosures for California Residents
Notice of Collection
In addition to the Rights & Choices described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the “Information Collected or Received Section above, the categories of personal information that we have collected – as described by the CCPA – are:
Identifiers, including name, email address, shop name, IP address, and an ID or number assigned to your account.
Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code 1798.80(e)), and overlaps with other categories listed here.
Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
Commercial information, including purchases and engagement with the Services.
Internet activity, including your interactions with our Services and what led you to our Services.
Sensory visual data, such as pictures posted on our Service.
Geolocation data provided through location enabled services such as WiFi and GPS.
Inferences, including information about your interests, preferences and favorites.
The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “Information Uses, Sharing and Disclosure” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.
Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
Lotando does not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses described in the “Information Uses, Sharing and Disclosure” Section above, we will comply with applicable law as to those activities.
Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Other than to Sellers on Lotando (see “Buying and Selling” under the “Information Uses, Sharing and Disclosure” Section above), who must obtain your separate consent for their own marketing off of Lotando, or unless you request us to or consent to it, Lotando does not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below.
9. Your Responsibilities
If you sell using our Services, you may receive and determine what to do with certain personal information. Your privacy responsibilities, including when you act as an independent data controller (someone who decides what personal data to collect and the purpose you use the data for) are laid out in the Lotando Seller Policy and the Lotando Terms of Use.
10. Privacy Policy Changes
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the App’ platform. We encourage you to check back regularly and review any updates.
11. Contact
If you have any questions:
Contact Lotando’s Support team via our form “Contact us” in the footer of the Site or the App.