Supplemental Privacy Disclosures

Last updated: June 18, 2024

Supplemental Privacy Notice for Residents of Specific States

This Supplemental Privacy Notice for Residents of Certain States (“State Privacy Notice”) supplements and incorporates by reference the information contained in Lotlinx’s Privacy Policy and applies solely to visitors, users and others who reside in the following states and who are covered under the following laws (collectively, the “applicable laws”).

Any terms used in this State Privacy Notice shall have the same meaning as those terms are defined by applicable law. Please refer to our Privacy Policy for additional information and for definitions of terms used in this State Privacy Notice.

Summary of Information We Collect

Throughout our Privacy Policy, we describe the specific pieces of Personal Information and sensitive Personal Information we collect, the sources of that information, and how we share it. Under the applicable law, we also have to provide you with the “categories” of Personal Information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are as summarized in the following table:

We collect the above categories of Personal Information from the following sources as specified in Personal Information We Collect From You section of the Privacy Policy.

Sale or Sharing of Personal Information

We or our service providers may collect and disclose the above categories of information for the purposes described in the How We Use the Collected Information section of our Privacy Policy. In the preceding twelve months, we have disclosed the following categories of Personal Information, as identified above, for a business or commercial purpose to the following service providers or other third parties:

In the preceding twelve months, we have not sold or shared any consumer’s Personal Information for monetary consideration. However, our use of cookies and other online tracking technologies for analytics and targeted advertising purposes may be considered a sale or sharing of Personal Information under applicable law. Categories of Personal Information that we have sold or shared under applicable law in the preceding twelve months and that we have disclosed to third parties for analytics and targeted advertising purposes include:

• Identifiers (e.g., name, email address, IP addresses);
• Commercial information (e.g., purchase history);
• Internet or other similar network activity; and
• Geolocation data.

Categories of third parties to whom Personal Information is provided include:

• Data analytics providers; and
• Advertising and marketing providers.

You can opt out of our tracking technologies for analytics and advertising service providers by clicking the “Do Not Sell or Share My Personal Information” link here or by broadcasting the Global Privacy Control (“GPC”) signal during your browsing session. Please note that your use of our Website will still be tracked by Lotlinx and our service providers.

Your Rights and Choices

Applicable laws provide consumers with specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights. Please note that applicable laws may contain certain limitations and exceptions may apply.

1. Right to Know Categorial and Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The categories of your Personal Information we disclosed to a recipient for a business purpose and the categories of recipients to whom it was disclosed.
• The specific pieces of Personal Information we collected about you.

2. Right to Correct Inaccurate Personal Information

If we maintain inaccurate Personal Information about you, you have the right to request that we correct these inaccuracies. After receiving notice of these inaccuracies, we will make reasonable efforts to correct your Personal Information throughout our systems and networks.

3. Deletion Request Right

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Deletion of your Personal Information means you are no longer a Lotlinx customer and no longer able to receive any Services.

4. Right to Opt-Out of the Sale of Personal Information, Targeted Advertising, and Profiling

California consumers have the right to opt-out of the sale and sharing of your Personal Information as those terms are defined under the CCPA. Nevada consumers have the right to opt out of the sale of your Personal Information. Virginia, Colorado, and Connecticut consumers have the right to opt out of the processing of Personal Information for purposes of targeting advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer as those terms are defined under applicable law.

We do not sell your Personal Information for monetary consideration. However, our use of tracking technologies may be considered a “sale” or “sharing” of Personal Information under applicable law and are used for purposes of targeting advertising to you. You can opt out of being tracked by these third parties and targeted advertising by clicking the “Do Not Sell or Share My Personal Information” link here or by broadcasting the GPC signal.

Lotlinx honors and responds to the GPC signal. Please note that when your browser broadcasts the GPC signal, we will limit the functionality of our website and prevent the website from transmitting your Personal Information to third parties. We will also treat this signal as a verified request to stop selling your Personal Information and stop processing your information for purposes of targeted advertising. However, the GPC signal does not fully identify you by name or email address. Therefore, we may not be able to honor this request for other interactions you may have or have had with Lotlinx. You may also submit a Opt Out privacy request with your email, phone number and other Personal Information for us to complete the opt-out process.

If you visit our website from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this website to opt-out or rebroadcast the GPC signal.

Exercising Rights

To exercise the data access, correction, deletion and opt-out rights described above, please submit a verifiable consumer request to us by:

• Completing the webform at our Website page here; or
• Emailing us at hello@lotlinx.com

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing. All communications regarding your request will be by email.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Limit Use and Disclosure of Sensitive Personal Information

Lotlinx processes a limited amount of sensitive Personal Information, as that term is defined under applicable law, with your consent. For example, Lotlinx collects your username and password when you affirmatively create an account on our website. Creating an account on our website is not mandatory and you consent to our collection of this information in order to maintain your account.

Lotlinx does not use or disclose your sensitive Personal Information for any purpose other than those specified in California Code of Regulations § 7027(m).

Exercising Appeal Rights (Virginia Residents Only)

If Lotlinx denies your request, you may appeal our decision by submitting an appeal request. Please refer to the communication you received from Lotlinx denying your request for additional information you may need to provide in making your appeal request. Within sixty (60) days of receipt of an appeal, Lotlinx will inform you in writing of any action taken or not taken in response to your appeal. If the appeal is denied, you may contact the Virginia Attorney General (by email: mailoag@oag.state.va.us, or phone: 804-786-2071) to submit a complaint.

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not:

• Deny you goods or services
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level or quality of goods or services
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Other Privacy Rights (California Residents Only)

Shine the Light Law (California Civil Code § 1798.83, available here. Under this law, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information (if any) which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom we have shared such information during the immediately preceding calendar year. You also have the right to request that we revise your Personal Information on record. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the law’s requirements and only information on covered sharing will be included in our response.

Online Privacy Protection Act (“CalOPPA”); Calif. Bus. & Prof. Code § 22575-22578, available here. Visitors can visit our Website anonymously by adjusting the settings in your browser. California law (CalOPPA) requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.

Supplemental Privacy Notice for Residents of Europe (including Switzerland and UK)

Lotlinx does not offer products or services to citizens of the EU.

This section applies to individuals located in the EEA, the UK or in Switzerland and outlines additional information about a person’s rights and choices regarding our processing of their personal data under the GDPR or equivalent laws in Switzerland and UK.

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

To exercise your rights, or if you have any other questions about our use of your personal data, please send a request at the contact details specified in the [How to Contact Us] section of the Privacy Policy. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

Depending on the specific personal data concerned and the factual context, when Lotlinx processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Lotlinx General Services and Adserving Services, manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services, including the General Services and Adserving Services;
• As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
• To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
• As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication; (iv) send marketing communications, advertising, and promotions related to the Products; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.