LAST UPDATED ON 20 July 20
Golden Lotus Labs Limited is committed to protecting our customer's privacy. Please take the time to read this Privacy Policy which explains what information we collect about you, how we use it, and your rights. Golden Lotus Labs Limited (“we” or “us”) is the data controller of the personal data collected via or in connection with our Guess Lucky Application (“Application”) and the Guess Lucky Website (the “Site” and collectively both the Application and the Site hereinafter referred to as the “Platform”).
We collect personal data from you when you provide it to us directly and through your use of the Site. This information may include:
Depending on how you use our Site, your interactions with us, and the permissions you give us, the purposes for which we use your personal data include:
We rely on the following legal basis, under data protection law, to process your personal data:
Depending upon your marketing preferences, we may use your personal data to send you marketing messages by email, phone or post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you.
If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by contacting us (details below), clicking on the ‘unsubscribe’ link in any email, or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time (e.g. order and delivery confirmations, and information about your legal rights).
You may also see ads for our Platform on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Site). Where you see an ad on social media, this may because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.
We share customers’ personal data with third parties in the following circumstances:
If we sell any business assets, the personal data of our customers may be disclosed to a potential buyer. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy. Otherwise where we have your consent or are otherwise legally permitted to do so.
We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us.. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your information, we will delete it. Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
Our Application uses Google Firebase technology (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, “Google”). Firebase is part of Google Cloud Platform and offers many services to developers. A list can be found here: https://firebase.google.com/terms/ . Some Firebase services process personal information. In most cases, the personal data is limited to so-called “instance IDs”, which are provided with a time stamp. Firebase’s instance IDs are unique and thus allow the linking of different events or processes. These data are neither personally identifiable information nor do we make any effort to personalise it afterwards. We process this aggregated data to analyse and optimise usage behaviour and app functionality.
In addition to the “Instance ID” described above, Google also uses the advertising ID of the device for Firebase Analytics. In the device settings of your mobile device you can restrict the use of the advertising ID.
For Android: Settings > Google > Ads > Reset Advertising ID
For iOS: Settings > Privacy > Advertising > No Ad Tracking
We do not use Firebase services that use personally identifiable information, such as IP addresses, email addresses, telephone numbers or passwords. For more information about Firebase’s privacy and security, please visit https://firebase.google.com/support/privacy/ . If possible, we use servers with a location within the EU. However, it can not be ruled out that data may also be transferred to the USA. Google has joined the EU-US Privacy Shield, a data protection agreement between the EU and the US. For more information on Google Firebase and privacy, visit https://www.google.com/policies/privacy/ and https://firebase.google.com/.
We may also transfer your Data to third-party advertising and technology companies to serve advertising and/or provide aggregated data to assist in serving advertising when you use our Platform. To achieve this, we may transfer your Usage Data e.g. IP address, country/city of User, IDFV, IDFA (for iOS) or ADID (for Android) to a third party such as Appodeal (“Appodeal Inc.”, 575 Market St, 7th Floor, San Francisco, CA 94109, USA) – ad mediation platform. We cooperate with Appodeal to provide all forms of advertisement inside our Platform. For more details look at: https://www.appodeal.com/home/privacy-policy/.
Third party technology companies help us collecting data about you in order to build a profile of your preferences based on your activities when you visit or use our apps. We also use these companies to automatically collect data from you when you use our apps in order to help us identify the advertising that are served to you and what you do after seeing those advertising.
On this Platform, the controller has integrated the component of Google Analytics (with the anonymiser function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our Platform. Google uses the collected data and information, among other things, to evaluate the use of our Platform and to provide online reports, which show the activities on our Platform, and to provide other services concerning the use of our Website for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our Platform. With each call-up to one of the individual pages of this Website, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our Platform by the data subject. With each visit to our Platform, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our Platform at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this Platform, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript that any data and information about the visits of Platform may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html . Google Analytics is further explained under the following Link https://www.google.com/analytics/.
This Platform ensures that data is encrypted when leaving the Platform. This process involves the converting of information or data into a code to prevent unauthorised access. We use SSL Encryption to protect customer data when in transit to and from this Platform over a secure communications channel.
Whilst we do everything within our power to ensure that personal data is protected at all times from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.
Our Platform is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18.
Our Site uses cookies and similar technologies to provide certain functionality to the Site, to understand and measure its performance, and to deliver targeted advertising.
If you are in the EU, You have certain rights in respect of your personal data, including the right to access, portability, correct, and request the erasure of your personal data.
You also have the right to object to your personal data being used for certain purposes, including to send you marketing. See ‘Marketing’ above, for more details of how to opt-out of marketing.
We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal data, or if you have any questions or concerns regarding your personal data, you should contact us using the details below. You are also entitled to contact your local supervisory authority for data protection.
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
If you have any queries on any aspect of our Privacy Policy, please contact our Data Protection Officer on the details below:
DPO: Manojan Panchlingam
Email: [email protected]