Privacy Policy for Lotto Ledger (iOS)

Effective Date: March 24, 2026
Version: 1.2 (iOS)
Developer: Clutch City AppWorks LLC

1. Overview

Lotto Ledger is an iOS lottery companion app that helps you generate lottery tickets using structured randomness, track drawings, compare results, and analyze performance history. We are committed to protecting your privacy and being transparent about how user data is collected and used.

Lotto Ledger uses Google AdMob to display in‑app advertisements in the free tier of the app. This policy explains how information is collected and used in connection with the app and those ads, and your privacy rights.

If there is any conflict between this Privacy Policy and the Terms of Service for Lotto Ledger, the Terms of Service shall apply to the extent of the conflict, except where required otherwise by applicable law or platform terms (e.g., Apple Media Services Terms).

2. What Lotto Ledger Does

Lotto Ledger helps you:

• Generate lottery tickets using various distribution strategies.
• Store and manage tickets locally.
• Record drawing results.
• Compare tickets to drawings automatically.
• View statistics and performance reports.
• Understand lottery odds and probabilities.

The app is designed to keep as much data as possible on your device and does not require an account or login to use.

3. Data Collection

To operate the app and serve ads, we or our third‑party partners may collect certain information, as described below.

App‑Level Data Collected

• Device identifiers: Technical identifiers such as the Identifier for Advertisers (IDFA) or other temporary device identifiers may be accessed by the Google Mobile Ads SDK for ad‑related purposes.
• Advertising and usage data: When AdMob is used, Google may collect data such as your interactions with ads, approximate device location, and general usage patterns for advertising and analytics.
• Crash, performance, and diagnostics data: The Google Mobile Ads SDK may collect limited technical data (e.g., crash logs, performance metrics) to help improve ad delivery and stability.

What is NOT Collected

We do not collect or request:

• Names, email addresses, or other personally identifiable contact information.
• Financial information (such as payment or banking details).
• Social media profiles or login credentials.
• Health, biometric, or highly sensitive personal data.

4. Data Use

The information collected by Lotto Ledger and the Google AdMob SDK is used for the following purposes:

• Displaying in‑app advertisements: To show ads within the free tier of the app, including personalized or non‑personalized ads depending on your choices and applicable laws.
• Improving ad performance and reliability: To optimize ad delivery, fill rate, and technical performance of the advertising SDK.
• App and device analytics (limited): To understand how ads are shown and interacted with, and to monitor general app stability and performance.
• Compliance with legal and platform requirements: To comply with Apple's App Store privacy disclosures, Google's AdMob policies, and applicable privacy laws such as GDPR, CCPA, TDPSA, and others.

We do not use collected data for purposes unrelated to running the app and serving ads (for example, we do not merge or combine this data with external profiles or use it for unrelated marketing campaigns).

5. Data Sharing and Third‑Party Services

Other Services

Other than Google AdMob, Lotto Ledger does not integrate with or use:

• Analytics services (no separate Google Analytics or Firebase analytics).
• Social media platforms.
• Cloud storage or cloud‑synchronization services.
• Payment processors within the app (other than standard App Store in‑app‑purchase plumbing, if any).
• Additional third‑party SDKs beyond what is required by the operating system or AdMob.

6. App Store Privacy Labels and Apple's Requirements

When publishing Lotto Ledger on the App Store, we disclose data collection and use in the App Store Connect "App Privacy" section, including:

• Data types collected (such as device identifiers, product interaction, and diagnostics).
• Purposes for which data is used (e.g., Third‑Party Advertising, Analytics, Product Personalization).
• Whether data is linked to identifiers and whether it is used for tracking, as defined by Apple.

The information in this privacy policy is intended to align with those disclosures so that App Store privacy labels accurately reflect Lotto Ledger's data practices.

7. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal data under privacy laws such as:

• California (CCPA/CPRA)
• European Union (GDPR)
• Texas (TDPSA)
• Colorado, Virginia, and other U.S. states

These rights may include:

• The right to know and access the categories of personal data collected.
• The right to request deletion of your personal data.
• The right to opt out of targeted advertising or the sale/sharing of personal data (where applicable).
• The right to data portability and, in some cases, the right to rectify inaccurate data.

Because Lotto Ledger's data processing is primarily delegated to Google AdMob and governed by its own policies and notices, requests involving ad‑related data are typically handled by Google or via your device‑level choices (for example, resetting your advertising identifier, disabling ad‑personalization, or using Google's ad‑choices tools).

To exercise your rights with respect to Lotto Ledger:

• Use your device's privacy and ad‑related settings (e.g., "Limit Ad Tracking," "Opt‑out of Interest‑based Ads," or similar).
• If you have questions specific to how Lotto Ledger handles your data or to send a data-subject-request, you can contact us as described in Section 9.

We will respond to verified requests within the time frame required by applicable law and may ask for information necessary to confirm your identity and residency.

8. Children's Privacy

Lotto Ledger is not directed to children under the age of 13, and we do not knowingly collect or process personal data from children under 13.

Where required by law (for example, under the COPPA framework), we do not allow the use of data‑intensive or personalized advertising features for users whose age or context indicates that they may be children. If you believe a child under 13 is using the app in a way that may involve data collection, you may contact us so we can investigate.

9. Contact and Support

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Effective Date" at the top of this page and, where practicable, provide notice within the app or on the App Store description.

Your continued use of Lotto Ledger after any changes become effective means you accept the updated Privacy Policy.

11. Summary