Privacy Policy

Last updated: September 26, 2026

This Privacy Policy explains what information Gaming Data Solutions LLC ("we," "us," or "our") collects when you use SmartScratcher, why we collect it, who we share it with, and the choices you have. It covers:

• the SmartScratcher mobile app for iPhone and Android (the "App");
• our website at smartscratcherapp.com (the "Website"); and
• any emails, push notifications, or in-app messages we send you.

Together we call these the "Services." If you don't agree with this policy, please don't use the Services. Questions? Email us any time at support@gamingdatasolutions.com.

Contents

1. Information we collect
2. How we use information
3. Advertising and analytics partners
4. When we share information
5. Cookies, local storage, and tracking signals
6. How long we keep information
7. How we protect information
8. Age requirements
9. Your choices
10. Your privacy rights under U.S. state laws
11. Data accuracy and responsible play
12. Changes to this policy
13. How to contact us

1. Information we collect

Information you give us

• Your state. You choose which state's lottery games to see. We store that choice on your device and send it with your requests so we can return the right games and, if you allow notifications, send you state-specific alerts.
• Promo codes. If you enter a promo or VIP code, we record the code, whether it worked, and your install ID, IP address, and device type at the time, so the code can't be abused.
• Messages you send us. If you email us, we receive your email address and whatever you include in the message. We use it only to respond and to improve the Services.

Information collected automatically by the App

• Install ID. When you first open the App it generates a random identifier and stores it on your device. This ID is sent with your requests so we can count how many people use the App, recognize a returning install, and honor promo codes. It is not your name, email, phone number, or Apple or Google account.
• Device and app information. Device model, operating system and version, App version and build, language, and time zone.
• IP address. Your device's IP address reaches our servers with every request. It is recorded in our usage records and in our standard server logs. Section 6 explains how long each is kept.
• Approximate location. When a request arrives we derive a coarse location (country, region, and city) from it so we can understand where our users are. We do not ask for or use your device's GPS or location permission.
• Usage information. Which screens and games you view, which filters and sorts you use, when you open the App, and how long sessions last.
• Push token. If you allow notifications, Apple or Google gives the App a device token that we store, together with your install ID and chosen state, so we can send you notifications.
• Purchase and subscription information. Whether you have an active subscription or trial, and subscription events (start, renewal, cancellation, refund) that Apple or Google report to us. Payments are handled entirely by Apple and Google. We never see your card number or billing details.
• Diagnostics. Crash reports and performance data made available to us by Apple and Google through their developer tools.

Information collected by third-party software in the App

The App includes software development kits ("SDKs") from the companies below. Each SDK collects some information directly from your device and sends it to that company. Section 3 explains the advertising ones in more detail.

• Google Firebase Analytics — app events (such as first open, screen views, and purchases), device information, an app-instance identifier, IP-derived coarse location, and the user properties we set (your chosen state and whether you subscribe).
• Meta (Facebook) SDK — app events (such as install, app open, and purchase), device information, and, only if you allow tracking, your device's advertising identifier.
• Superwall — the paywall screens in the App. Superwall receives your install ID, device information, which paywall you saw, and your purchase events so it can show the right offer and report conversions.

Advertising identifier. On iPhone, the App asks for permission through Apple's App Tracking Transparency prompt before Meta or Google may access your Identifier for Advertisers (IDFA). If you decline, the identifier is not shared. On Android, the Meta and Google SDKs may access the Android Advertising ID unless you have deleted or reset it in your device settings.

Information collected on the Website

• The Website is a set of static pages. It sets no cookies and includes no analytics or advertising code.
• The Website is hosted on GitHub Pages and loads fonts from Google Fonts. Like any web host or content network, those services receive your IP address and standard browser information when your browser requests a page or font. We do not receive or keep Website visitor logs.
• Links from the Website to the App Store carry a campaign tag (for example, which page you clicked from) so Apple can tell us how many installs came from the Website. The tag contains no information about you.

What we don't collect

We do not collect your name, email address (unless you email us), phone number, postal address, payment card details, precise GPS location, contacts, photos, or any sensitive category of information such as health, race, religion, sexual orientation, or government ID numbers. We do not buy information about you from data brokers or other third parties.

2. How we use information

• To run the App — return the games for your state, show your subscription status, honor promo codes, and deliver notifications you asked for.
• To understand and improve the Services — see which features and states are popular, count active users, measure retention, and find and fix bugs.
• To measure our advertising — learn whether people who saw one of our ads on Meta or Google went on to install or subscribe, so we spend our ad budget sensibly (see Section 3).
• To communicate with you — respond to your emails, and send in-app messages or push notifications about new games, new states, features, and offers. You can turn notifications off at any time.
• To keep the Services safe — detect abuse of promo codes, automated scraping, and other misuse.
• To meet legal obligations — respond to lawful requests and enforce our Terms of Service.

3. Advertising and analytics partners

We advertise SmartScratcher on Meta platforms (Facebook and Instagram) and on Google. To know whether those ads work, the App reports events such as "app installed" and "subscription purchased" back to Meta and Google through their SDKs. Meta and Google combine those events with the information they already hold about you to attribute installs to ads and to build audiences of people who might be interested in the App.

We do not show ads inside the App, and we do not receive money or other value from Meta or Google for this information. Under some state privacy laws, however, disclosing device identifiers and app events to an ad platform for these purposes is treated as "sharing" for cross-context behavioral advertising, or as "targeted advertising." We treat it that way too, and you can opt out:

• iPhone: choose "Ask App Not to Track" when the App asks, or later turn tracking off for SmartScratcher under Settings → Privacy & Security → Tracking. This stops the advertising identifier from being shared. You can also turn off "Allow Apps to Request to Track" for every app.
• Android: go to Settings → Google → Ads (or Settings → Privacy → Ads) and choose "Delete advertising ID."
• Email us at support@gamingdatasolutions.com and we will opt your install out of our ad-measurement reporting.

You can also manage how Meta and Google use information for ads across all apps in your Meta ad preferences and Google My Ad Center. Their own privacy policies describe what they do with the information they receive: Meta Privacy Policy and Google Privacy Policy.

4. When we share information

We share information only in these situations:

• Service providers. Companies that help us run the Services and that may process information on our behalf: Apple and Google (app distribution, payments, push notifications, crash reporting), Google Firebase (analytics), Meta (ad measurement), Superwall (paywalls), DigitalOcean (server hosting), GitHub (Website hosting), and Google Fonts (fonts). Each is allowed to use the information only to provide its service to us, except that Meta and Google use ad-measurement data as described in Section 3.
• Legal reasons. If we believe disclosure is required by law, a court order, or a valid government request, or is necessary to protect the rights, safety, or property of our users, the public, or us.
• Business transfers. If we are involved in a merger, acquisition, financing, or sale of some or all of our assets, information may be transferred as part of that deal. We will require the new owner to honor this policy or tell you before your information becomes subject to a different one.
• With your direction. Any other time you ask us to.

We do not sell personal information in exchange for money, and we never have.

5. Cookies, local storage, and tracking signals

• The App stores your preferences (chosen state, appearance, onboarding progress, install ID, and similar settings) in local storage on your device. Deleting the App removes them.
• The Website sets no cookies of its own and has no consent banner because there is nothing to consent to.
• Do Not Track and Global Privacy Control. Because the Website does no tracking, there is nothing for these browser signals to switch off. In the App, the opt-out mechanisms in Section 3 are how you control ad tracking.

6. How long we keep information

• Usage records tied to your install ID (sessions, chosen state, coarse location, and App version) are kept for as long as we need them for analytics and troubleshooting, then deleted or aggregated so they no longer identify an install. The IP address in these records is removed after 48 hours; the coarse location derived from it stays.
• Promo-code records (the code entered, whether it worked, your install ID, IP address, and device type) are kept for as long as the code program runs so we can spot sharing and abuse.
• Server logs. Like almost every online service, our web server and API record each request, including its IP address, in standard log files. Web server logs are kept for 14 days. API process logs are kept until the server's log space fills and older entries roll off, which at current volumes is several months. We use these logs only for security and troubleshooting.
• Push tokens are kept until Apple or Google tells us the token is no longer valid, you turn notifications off and reinstall, or you ask us to remove it.
• Subscription events reported by Apple or Google are kept for as long as needed for accounting, tax, and to understand subscription trends.
• Emails you send us are kept for as long as needed to help you and improve the Services.

Information held by our service providers is kept according to their own retention rules. Where we can, we set those to the minimum they allow.

7. How we protect information

Traffic between the App or Website and our servers is encrypted in transit. Access to our servers and databases is limited to the people who need it and is protected by keys and passwords. We designed the App so that it never collects your name, contact details, or payment information in the first place, which is the best protection of all. That said, no system is perfectly secure, and we cannot promise that unauthorized parties will never defeat our safeguards.

8. Age requirements

The Services are about lottery tickets, so they are for adults only. You must be at least 18 years old, or older if your state requires a higher age to buy lottery tickets. We do not knowingly collect information from anyone under 18. If you believe someone under 18 has used the App, email us and we will delete the associated information.

9. Your choices

• Notifications. Turn them on or off at any time in your device's notification settings for SmartScratcher.
• Ad tracking. Use the steps in Section 3.
• Start fresh. Deleting the App removes your install ID and preferences from your device. A new install gets a brand-new ID that is not linked to the old one.
• Subscriptions. Manage or cancel through your Apple ID or Google Play subscriptions page. Our Terms of Service explain how.
• Ask us. Email support@gamingdatasolutions.com to access, correct, or delete the information tied to your install, or to opt out of ad measurement.

10. Your privacy rights under U.S. state laws

If you live in a state with a comprehensive consumer privacy law (including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, among others), you may have some or all of these rights:

• to know whether we process your personal information and to access it;
• to correct inaccurate personal information;
• to delete your personal information;
• to obtain a portable copy of the personal information you provided to us;
• to opt out of the "sale" of personal information, of "sharing" or targeted advertising, and of profiling that produces legal or similarly significant effects;
• to obtain a list of the categories (or, in some states, the specific) third parties we have disclosed personal information to;
• to not be discriminated against for exercising these rights; and
• to appeal if we decline your request.

We honor these rights for everyone in the United States, whatever state you live in.

How to exercise your rights

Email support@gamingdatasolutions.com with the subject line "Privacy request" and tell us what you would like us to do. We operate exclusively online and have no other channel for requests. We will respond within 45 days, and will tell you if we need up to 45 more.

Verifying your request. Because we don't collect names, emails, or account logins, the only thing that links information to you is the random install ID on your device. To find your records we will ask you for details we can match against them, such as your device type, the state you chose, your approximate location, roughly when you installed the App, and whether you subscribe. If we cannot reasonably verify that a record is yours, we will tell you and explain why.

Authorized agents. You may have someone make a request for you. We will ask for proof that you authorized them, and may still ask you to confirm your identity directly.

Appeals. If we decline your request, you may appeal by replying to our response with "Appeal" in the subject line. We will answer in writing within 45 days and explain our reasons. If you are still unhappy you may contact your state attorney general.

California notice at collection

In the past 12 months we collected the following categories of personal information as defined by the California Consumer Privacy Act, from the sources and for the purposes described in Sections 1 and 2:

Category	Examples we collect	Disclosed to service providers	"Shared" for cross-context behavioral advertising
Identifiers	Install ID, IP address, push token, advertising identifier (with permission), app-instance IDs	Yes	Yes — advertising identifier and app-instance IDs with Meta and Google
Commercial information	Subscription and trial status, purchase events, promo codes used	Yes	Yes — purchase events with Meta and Google
Internet or other electronic network activity	Screens and games viewed, filters used, session times, device and App version	Yes	Yes — app events with Meta and Google
Geolocation data (approximate only)	Country, region, and city derived from IP address	Yes	No

We do not collect the other CCPA categories (such as personal records under the California Customer Records statute, protected classifications, biometric information, audio or visual information, professional or education information, or inferences used to build a profile), and we do not collect or process sensitive personal information. We do not sell personal information for money, and we have no actual knowledge of selling or sharing the personal information of anyone under 16. Retention for each category is described in Section 6. To opt out of sharing, use the steps in Section 3. California's "Shine the Light" law (Civil Code §1798.83) lets you ask which third parties we disclosed personal information to for their own direct marketing; we do not do that, so the answer is none.

11. Data accuracy and responsible play

SmartScratcher analyzes information that state lotteries publish, combined with our own calculations. We work hard to keep it accurate and current, but lotteries update their figures on their own schedules and mistakes happen. Always confirm details with the official lottery before making decisions, and see our Terms of Service for the full disclaimer.

SmartScratcher is an information tool. It does not sell tickets, guarantee winnings, or influence any lottery's results, and it does not encourage anyone to gamble. If the lottery stops being fun, the National Problem Gambling Helpline is 1-800-GAMBLER.

12. Changes to this policy

We may update this policy as the Services change or the law requires. The date at the top tells you when it was last revised. If we make a material change, we will tell you in the App or on the Website before it takes effect.

13. How to contact us

Gaming Data Solutions LLC
Edmond, Oklahoma, United States
support@gamingdatasolutions.com

We are a small company that operates online only, so email is the fastest way to reach us, and we read every message.