This Privacy Policy explains how LotterySpy (“LotterySpy,” “we,” “us,” or “our”), operated by Sky Margins Limited, collects, uses, stores, discloses, and protects personal information when you visit or use our website, mobile experience, and related tools and features, together referred to as the “Site.”

This Policy applies to visitors, registered users, subscribers, Forecasters, and other individuals whose personal information we process in connection with the Site.

This Policy should be read together with our Terms & Conditions and other applicable policies referenced throughout the Site. Capitalized terms not defined here have the meaning given in the Terms & Conditions.

By using the Site, you acknowledge that we process personal information as described in this Policy. If you do not agree with this Policy, please do not use the Site.

2.1 Account Registration

When you create an account, we may collect information such as your name, email address, username, password, date of birth or age confirmation, country of residence, and other information reasonably necessary to establish and manage your account.

Passwords are stored using security measures designed to protect them from unauthorized access. We do not expect you to provide your password to us outside the normal account authentication process.

2.2 Payment and Billing Information

When you purchase a subscription, Points, or another paid Product, payment information is processed through the applicable payment service provider. LotterySpy does not intentionally store full payment card numbers on its own servers where the payment provider handles that information directly.

We may retain limited billing information, such as transaction references, amounts, dates, payment status, and masked payment identifiers, where necessary for customer support, reconciliation, accounting, fraud prevention, and legal obligations.

2.3 Forecaster Marketplace Content

If you publish as a Forecaster, we collect the predictions, analysis, commentary, track-record information, profile information, and other content you submit. Some of this information is intentionally made visible to other users as described in Section 8.

2.4 Communications with Us

When you contact customer support, submit a complaint, report an issue, make a privacy request, submit a copyright complaint, or otherwise communicate with us, we may collect the content of that communication and the contact information you provide.

2.5 Surveys and Feedback

If you respond to a survey, participate in research, submit feedback, or otherwise voluntarily provide information to help us improve LotterySpy, we may collect your responses and any contact information you choose to provide.

3.1 Usage Data

We may automatically collect information about how you interact with the Site, including pages and tools viewed, features used, searches performed, links clicked, session activity, and approximate time spent using particular parts of the Site.

3.2 Device and Log Data

We may collect technical information such as your IP address, browser type and version, operating system, device information, referring URLs, timestamps, diagnostic information, and other technical data generated when you interact with the Site.

This information may be used to maintain security, diagnose technical problems, prevent abuse, understand aggregate usage patterns, and improve the performance and reliability of the Site.

3.3 Approximate Location

We may estimate your approximate location, such as country or general geographic area, from information such as your IP address. This may help us with fraud prevention, regional functionality, security, and compliance with applicable legal requirements.

Cookies are small text files stored by your browser. LotterySpy and certain service providers may use cookies, local storage, pixels, and similar technologies for purposes such as:

• Essential cookies — support core functionality such as authentication, security, session management, and other features required for the Site to operate.
• Preference cookies — remember settings and preferences, such as display choices, selected games, or previously selected options.
• Analytics cookies — help us understand how the Site is used so that we can improve functionality, performance, and user experience.
• Advertising technologies — where applicable, may be used by LotterySpy or advertising partners to deliver, personalize, measure, or improve advertising.

Most browsers allow you to refuse, restrict, or delete cookies through their settings. Blocking essential cookies may prevent certain account or Site functionality from working correctly. Blocking non-essential cookies may reduce personalization or affect certain features.

Where applicable law requires consent for non-essential cookies or similar technologies, we will provide an appropriate consent mechanism.

The Site may use third-party advertising, analytics, measurement, or similar services. These providers may use cookies, pixels, web beacons, device information, IP addresses, or similar technologies to provide their services.

Depending on the services actually enabled on the Site, third-party providers may process information about your interaction with LotterySpy for purposes such as measuring traffic, understanding usage, improving services, preventing fraud, or delivering and measuring advertising.

We will identify applicable third-party providers in our privacy or cookie disclosures where required by applicable law and where reasonably necessary to explain how your information is processed.

If Google services are used on the Site, you can review Google's advertising and privacy controls through its official settings and privacy information. Other providers may offer their own privacy and opt-out mechanisms.

When you click an advertisement or leave LotterySpy for a third-party website, your activity on that destination site is governed by the destination site's own privacy policy and terms.

We may use personal information for the following purposes:

• Creating, administering, securing, and authenticating your account.
• Providing the Site, Products, tools, research resources, and other requested services.
• Processing subscription payments, Points purchases, and applicable Forecaster Marketplace transactions.
• Operating, maintaining, securing, and improving the Site’s tools, statistics, analytical features, and AI-assisted features.
• Personalizing aspects of your experience, including remembering selected preferences and settings.
• Responding to customer support requests, complaints, questions, and other communications.
• Sending service-related notices concerning your account, transactions, security, technical changes, and legal updates.
• Sending marketing communications where you have provided the required consent or where otherwise permitted by applicable law.
• Detecting, investigating, and preventing fraud, abuse, unauthorized access, security incidents, and violations of our Terms & Conditions.
• Complying with applicable legal, regulatory, tax, accounting, and reporting obligations.
• Creating aggregated or appropriately de-identified information that does not reasonably identify individual users.
• Understanding how users interact with the Site so that we can improve our products, services, research tools, and overall user experience.

Where applicable law requires us to identify a legal basis for processing personal information, including Ghana’s Data Protection Act, 2012 (Act 843), we may rely on one or more of the following lawful bases:

• Performance of a contract — where processing is necessary to provide the Site, operate your account, deliver requested Products, process payments, or perform our obligations under the Terms & Conditions.
• Consent — where you have provided consent for an optional processing activity, such as certain marketing communications or non-essential cookies. Where applicable, you may withdraw consent at any time.
• Legitimate interests — where processing is reasonably necessary for purposes such as securing the Site, preventing fraud, improving our services, protecting users, and managing our business, provided those interests are not overridden by applicable privacy rights.
• Legal obligation — where we are required to process or retain information to comply with applicable law, regulation, court orders, tax requirements, accounting obligations, or lawful requests.
• Other lawful bases — where applicable law recognizes another lawful basis for processing, we may rely on that basis where appropriate.

If you publish as a Forecaster, certain information may be visible to other users as part of the normal operation of the Forecaster Marketplace. This may include your username, public profile information, published predictions, track record, rankings, verification status, commentary, and other content you intentionally make public.

Do not include personal information in Forecaster content that you do not want other people to see. This includes telephone numbers, private addresses, passwords, financial information, identification numbers, or other sensitive personal information.

Once content is published publicly, it may be viewed, copied, quoted, screenshotted, archived, or shared by other users or third parties beyond our control, even if the original content is later edited or removed from the Site.

Where historical Forecaster performance is required to remain available for transparency and track-record integrity, we may retain relevant records after publication or account closure, subject to applicable law.

When you purchase subscriptions, Points, or other paid Products, your payment may be processed by one or more third-party payment service providers integrated with the Site.

Where payment information is collected directly by the payment provider, that provider processes your payment details under its own privacy policy, security practices, and applicable legal requirements.

LotterySpy may receive and retain limited payment and billing information such as transaction references, payment status, amount, date, currency, masked payment identifiers, and other information necessary to confirm transactions, provide support, reconcile accounts, prevent fraud, and satisfy accounting or legal obligations.

We do not intentionally retain complete payment card numbers on our own servers where those details are handled directly by the applicable payment processor.

We do not sell your personal information. We may share personal information only where reasonably necessary for the purposes described in this Policy, where you have authorized the disclosure, or where applicable law permits or requires it.

10.1 Service Providers

We may share information with trusted service providers that help us operate the Site, including providers of hosting, payment processing, email delivery, customer support, security, analytics, communications, and technical infrastructure.

Where appropriate, these providers are expected to process personal information only for authorized purposes and in accordance with applicable contractual, confidentiality, security, and data-protection requirements.

10.2 Legal Requirements

We may disclose personal information where we reasonably believe disclosure is necessary to comply with applicable law, a valid court order, regulatory requirement, or lawful legal process, or to protect the rights, property, safety, and security of LotterySpy, our users, or others.

10.3 Business Transfers

If LotterySpy or Sky Margins Limited is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

10.4 With Your Consent

We may share personal information for other purposes where you have provided appropriate consent or authorization.

10.5 Aggregated or De-Identified Information

We may create, use, and share aggregated or appropriately de-identified information that cannot reasonably be used to identify you individually, including for research, analytics, reporting, product development, or publication of general platform statistics.

We retain personal information for as long as reasonably necessary to provide the Site, maintain accounts, complete transactions, provide support, preserve security, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

Retention periods vary depending on the type of information, why it was collected, whether an account remains active, applicable legal requirements, and other legitimate operational considerations.

• Account information may be retained while your account remains active and for an additional period where reasonably necessary for security, legal, dispute-resolution, fraud-prevention, or legitimate business purposes.
• Billing and transaction records may be retained for the period required by applicable tax, accounting, financial, and legal requirements.
• Forecaster Marketplace content may be retained where necessary to preserve historical records, track-record integrity, dispute resolution, or other legitimate platform purposes.
• Support communications may be retained for as long as reasonably necessary to resolve requests, maintain service records, address recurring issues, and meet legal obligations.

When personal information is no longer reasonably required, we may delete it, anonymize it, or otherwise securely dispose of it, unless continued retention is required or permitted by applicable law.

LotterySpy implements technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, loss, misuse, or destruction.

Depending on the nature of the information and the risks involved, these measures may include access controls, authentication mechanisms, encryption or secure transmission technologies, monitoring, backups, security procedures, and restrictions on internal access to personal information.

No method of transmitting information over the internet or storing information electronically is completely secure. Accordingly, while we take reasonable steps to protect personal information, we cannot guarantee absolute security.

You also have a role in protecting your information. Use a strong and unique password, keep your account credentials confidential, avoid sharing access to your account, and notify us promptly if you believe your account has been compromised.

If we become aware of a personal-data breach that requires notification under applicable law, we will take the required steps to investigate, contain, and notify affected individuals or regulators where legally required.

Depending on your location and applicable law, you may have some or all of the following rights regarding your personal information:

• Access — request access to personal information we hold about you.
• Correction — request correction of inaccurate or incomplete personal information.
• Deletion — request deletion of personal information, subject to applicable legal and legitimate retention requirements.
• Portability — where applicable, request certain personal information in a structured and commonly used format.
• Restriction or objection — where applicable, request restriction of or object to certain processing activities.
• Withdrawal of consent — where processing is based on consent, withdraw that consent without affecting the lawfulness of processing carried out before withdrawal.
• Marketing choices — unsubscribe from marketing communications using the methods described in Section 14.

To exercise a privacy right, contact us using the information in Section 22. We may need to verify your identity before processing a request. Certain requests may be subject to lawful exceptions, limitations, or retention obligations.

Where applicable law provides a right to complain to a data-protection regulator, you may also contact the relevant supervisory authority in your jurisdiction.

Where you have opted in to receive marketing communications, you may unsubscribe at any time by using the “unsubscribe” link contained in a marketing email or by using available notification controls associated with your account.

Unsubscribing from marketing communications does not prevent us from sending necessary service-related communications, including account notices, security alerts, transaction confirmations, billing information, technical notices, legal updates, or other communications required to operate the Site.

Marketing preferences may take a reasonable amount of time to become effective across all communication systems.

Some browsers provide a “Do Not Track” or similar privacy signal. Because there is no universally accepted technical standard governing how websites must respond to these signals, LotterySpy may not automatically change its processing practices when such a signal is received.

You can still manage available cookie, advertising, marketing, and other privacy choices through the controls and methods described in this Policy and through your browser or device settings.

LotterySpy is operated from Ghana. Depending on the services and providers used to operate the Site, your personal information may be transferred to, stored in, or processed in Ghana or other countries.

Data-protection laws may differ between countries. Where applicable law requires safeguards for international transfers, we will take reasonable steps intended to provide an appropriate level of protection, which may include contractual, technical, organizational, or other legally recognized safeguards.

By using the Site, you acknowledge that your information may be processed in jurisdictions other than the country in which you live, subject to applicable legal requirements.

The Site is intended for individuals who are eighteen (18) years of age or older, consistent with the eligibility requirements in our Terms & Conditions.

We do not knowingly request or intentionally collect personal information from anyone under 18. If we become aware that personal information has been collected from a person under 18, we will take reasonable steps to investigate and delete the information where required by applicable law.

If you believe that someone under 18 has provided personal information to LotterySpy, please contact us using the information in Section 22.

The Site may contain links to third-party websites, including official lottery organizations, payment providers, Forecaster resources, social-media platforms, technology services, and other external websites.

This Privacy Policy does not apply to the privacy practices of those third-party websites. LotterySpy does not control how third parties collect, use, store, disclose, or protect information once you leave our Site.

We encourage you to review the privacy policy and terms of any third-party website before providing personal information or entering into a transaction with that third party.

If you are located in the European Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR may apply to our processing of your personal information, in addition to applicable Ghanaian law.

Where applicable, the legal bases described in Section 7 and the rights described in Section 13 apply to the extent required by the relevant law.

Where we transfer personal information outside the EEA or UK and applicable law requires a transfer mechanism or safeguard, we will use an appropriate legally recognized mechanism where reasonably required.

You may also have the right to lodge a complaint with the relevant data-protection supervisory authority in your country or region.

If you are a California resident, applicable California privacy law may provide additional rights concerning your personal information, including rights to know, access, correct, delete, or obtain certain information, and rights concerning certain forms of sale or sharing as those terms are defined under California law.

LotterySpy does not sell personal information. Where applicable California law treats certain advertising or analytics activities as “sharing” personal information, we will provide the choices and disclosures required by that law.

California residents may submit applicable privacy requests using the contact information provided in Section 22. We may need to verify your identity before completing a request.

We will not unlawfully discriminate against you for exercising a privacy right available to you under applicable California law.

We may update this Privacy Policy from time to time to reflect changes in our services, technology, data-processing practices, security measures, legal requirements, or other relevant circumstances.

When we make changes, the updated version will be published on this page and the “Last updated” date will be revised accordingly.

Where required by applicable law, we will provide additional notice of material changes through appropriate channels.

We encourage you to review this Policy periodically so that you remain informed about how LotterySpy handles personal information.

If you have questions about this Privacy Policy, believe your personal information has been handled incorrectly, or would like to exercise a privacy right available to you, please contact us using the details below:

LotterySpy · Sky Margins Limited
Email: info@lotteryspy.com

When submitting a privacy request, please provide enough information for us to understand your request. We may ask for reasonable information to verify your identity before providing access to or changing personal information.

Where applicable law provides you with the right to complain to a data-protection authority, you may also contact the relevant supervisory authority in your jurisdiction.