Privacy Policy

Version 1.0.0 · Last updated 18 April 2026

1. Who we are

This Privacy Policy describes how the developers of Auto Lotto Savers Club (“we”, “us”) handles personal data in connection with the Auto Lotto Savers Club interface (the “Service”). For the purposes of the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018, we act as the data controller for the limited personal data we collect directly.

2. Data we collect

We collect only the minimum information needed to operate the Service:

  • Email address — collected by Coinbase Developer Platform when you sign in. We do not store your email on our own servers.
  • Wallet address — the public Ethereum-style address assigned to your account. We use this to look up your on-chain activity and to record your acceptance of our legal documents.
  • Acceptance records — when you accept these documents at sign-up we store your wallet address, the document versions accepted, the timestamp, and your IP address.
  • Contact form submissions — if you contact us via our contact form, we store your name, email, subject, message, IP address and submission time so we can respond.
  • Technical logs — our hosting and API providers automatically record IP addresses and request metadata for security, abuse prevention and rate-limiting purposes. These logs are retained for a short period and are not used to build user profiles.
  • On-chain activity — deposits, withdrawals, prizes and other transactions are recorded permanently on the public Optimism blockchain by you. We read this public data to display it back to you, but we do not control or own it.

3. What we do not collect

We do not collect your real name, postal address, government ID, financial account details, or private keys. We do not run analytics or tracking pixels, and we do not sell or rent any personal data.

4. Legal bases (GDPR)

  • Performance of a contract (Article 6(1)(b)) — to provide the Service you have requested.
  • Legal obligation (Article 6(1)(c)) — to keep records of your acceptance of our terms.
  • Legitimate interests (Article 6(1)(f)) — to secure the Service against abuse, prevent fraud, and respond to your support enquiries.

5. Third parties

The Service depends on third-party providers that may process your personal data under their own privacy policies, including:

  • Coinbase Developer Platform (authentication and wallets)
  • Replit (hosting)
  • Moralis (on-chain data indexing)
  • CoinGecko (price data)
  • Public Optimism RPC providers
  • The PoolTogether V5 protocol (smart contracts)

We do not share your contact form details or acceptance records with any third party other than as required to operate the Service (for example, our database host) or where required by law.

6. Cookies and storage

The Service uses only essential browser storage (cookies, localStorage, IndexedDB) needed to keep you signed in and to remember your wallet preference. We do not set advertising or analytics cookies. You can clear this storage at any time from your browser settings.

7. Retention

Acceptance records are retained for as long as we operate the Service and for a reasonable period afterwards in case of a dispute. Contact form submissions are retained for up to 24 months after the last related correspondence. Technical logs are retained for a short rolling window (typically less than 30 days).

8. Your rights

Subject to GDPR, you have the right to access, rectify, erase, restrict or object to our processing of your personal data, and the right to data portability. You may exercise these rights by contacting us via the contact form. Please note we cannot delete or modify data recorded on the Optimism blockchain — that data is public and immutable by design.

You have the right to lodge a complaint with the Irish Data Protection Commission (dataprotection.ie) if you believe we have mishandled your personal data.

9. International transfers

Some of our service providers are located outside the European Economic Area. Where this is the case, we rely on appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.

10. Changes to this Policy

We may update this Policy from time to time. The version number and “Last updated” date above will reflect the latest version. Material changes will be communicated through the Service.

11. Contact

For privacy enquiries, please use our contact form.