Privacy Policy
This Privacy Policy describes how information is collected, used, and handled when you use the L6ttery app ("the App"). The App is independently developed and published in the United Kingdom. The developer acts as the data controller for the purposes of UK data protection law.
1. Who This Policy Applies To
This policy applies to all users of the L6ttery iOS app. The App is rated 18+ and is not intended for use by persons under 18 years of age. If you are under 18, please do not use the App.
2. Information Collected
No personally identifiable information — such as names, email addresses, or payment details — is collected.
The App uses Firebase Analytics (provided by Google LLC) to collect anonymous usage data, including:
- App launch and session events
- In-app interactions (e.g. starting or resetting a draw)
- Device type, operating system version, and app version
- Approximate country or region (derived from IP address, not stored)
- Crash and performance diagnostics
This data is collected in aggregate and cannot be used to identify you personally.
3. Legal Basis for Processing
Under UK GDPR, anonymous analytics data is processed on the basis of legitimate interests (Article 6(1)(f)) — specifically, to understand how the App is used and to maintain and improve it. Because the data collected is anonymous and aggregated, the impact on your privacy is minimal.
4. How This Information Is Used
Usage data is used solely to:
- Understand how the App is used and improve it over time
- Identify and fix crashes or performance issues
- Make informed decisions about future features
This data is not used for advertising and is not sold to any third party.
5. Third-Party Services
The App integrates Firebase Analytics, a service operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Analytics data is processed by Google under its own privacy policy, available at policies.google.com/privacy.
Analytics collection can be opted out of at any time via the App's settings, or by enabling "Limit Ad Tracking" / "Allow Apps to Request to Track" in your iPhone's Privacy settings.
6. International Data Transfers
Analytics data is processed by Google on servers that may be located outside the United Kingdom, including in the United States. Google relies on Standard Contractual Clauses and other UK-approved transfer mechanisms to ensure appropriate safeguards are in place for any such transfers.
7. Data Retention
Firebase Analytics retains event-level data for a default period of 14 months. Aggregated reporting data may be retained longer. No analytics data is stored independently of Firebase.
8. Children's Privacy
The App is rated 18+ due to simulated gambling content and is not intended for use by persons under 18. No data is knowingly collected from underage users. It is the responsibility of parents and guardians to ensure the App is not accessed by minors.
9. Your Rights Under UK GDPR
Under UK data protection law, you have the right to:
- Access — request a copy of personal data held about you
- Rectification — request correction of inaccurate data
- Erasure — request deletion of your data
- Restriction — request that processing be restricted
- Object — object to processing based on legitimate interests
- Portability — request a portable copy of your data
Because analytics data is anonymous and cannot be linked back to an individual, some of these rights may not be technically applicable. To exercise any right, get in touch at l6ttery@twinkle.hk.
A complaint may also be lodged with the Information Commissioner's Office (ICO) if data is believed to have been handled unlawfully. Visit ico.org.uk or call 0303 123 1113.
10. Changes to This Policy
This Privacy Policy may be updated from time to time. The updated version will be published at this URL with a revised "last updated" date. Continued use of the App after any changes constitutes acceptance of the updated policy.
11. Contact
For any questions about this Privacy Policy, please get in touch at:
l6ttery@twinkle.hk
12. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of England and Wales.