Privacy Policy for Pooling Numbers
Effective Date: January 25, 2025
Pooling Numbers ("we," "us," or "our") values your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our platform, including our website, mobile applications, and services (collectively, the "Services"). By accessing or using our Services, you agree to this Privacy Policy. If you do not agree, please do not use our Services.
Definitions
For the purposes of this Privacy Policy:
"Personal Information": Information that directly or indirectly identifies, relates to, describes, or can reasonably be linked to an individual, such as name, email address, phone number, or payment details.
"Processing": Any action performed on personal information, including collecting, storing, using, disclosing, or deleting data.
"Cookies": Small data files stored on a user’s device by a website or mobile application to enhance user experience or track activities.
"Aggregated Data": Data derived from individual information that is combined with other user data to produce summaries or statistics that cannot identify individuals.
"Geolocation Data": Information that identifies the physical location of a user’s device, collected to verify residency or ensure compliance with state-specific requirements.
"Service Providers": Third-party entities that perform functions on behalf of Pooling Numbers, such as payment processing, identity verification, or data analysis.
Section 1: Information We Collect
We collect information about you to provide and improve our Services, comply with legal requirements, and ensure a safe and enjoyable user experience. The information we collect includes:
1.1 Personal Information
When you register for an account, make a purchase, or interact with our Services, we may collect:
Identity Information: Full name, date of birth, government-issued ID details.
Contact Information: Email address, phone number, and mailing address.
Financial Information: Payment details, including credit/debit card information and transaction history.
1.2 Non-Personal Information
We also collect information that does not directly identify you, such as:
Usage Data: Information about your interactions with our Services, including features used, pages viewed, and time spent on the platform.
Device Information: Details about the device you use to access our Services, such as IP address, browser type, operating system, and unique device identifiers.
1.3 Cookies and Tracking Technologies
We use cookies, web beacons, and similar tracking technologies to:
Enhance user experience by remembering your preferences.
Collect analytical data to understand how users interact with our platform.
Facilitate targeted advertising and promotional activities.
You can manage your cookie preferences through your browser settings, but some features of our Services may not function properly if cookies are disabled.
Cookies Policy in Detail
We use various types of cookies and tracking technologies to improve your experience on our platform. These include:
1. Essential Cookies
These cookies are necessary for the operation of our Services. They enable core functionalities such as security, network management, and accessibility. Without these cookies, certain features of our platform may not work as intended.
2. Performance Cookies
These cookies help us understand how users interact with our platform by collecting data on usage patterns, such as page views and navigation paths. The information collected is anonymized and used solely for performance monitoring and optimization.
3. Functionality Cookies
These cookies enable enhanced functionality and personalization, such as remembering your preferences and login details. They help provide a more tailored experience.
4. Advertising Cookies
We use these cookies to deliver relevant advertisements to you based on your interests. They also help us measure the effectiveness of our marketing campaigns. Third-party service providers may use these cookies to show you targeted ads on other platforms.
5. Analytics Cookies
Analytics cookies help us analyze user behavior on our platform to improve features and overall usability. Data collected is anonymized and used to generate reports and insights.
Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to:
View cookies stored on your device and delete them individually.
Block cookies from specific sites.
Block third-party cookies.
Clear all cookies when you close your browser.
Please note that disabling cookies may impact the functionality of our Services and your overall user experience.
Section 2: How We Use Your Information
We use the information we collect to operate, maintain, and enhance our Services, as well as to ensure legal compliance and safeguard our users. Specific uses include:
2.1 Providing and Improving Services
To process your transactions and fulfill your orders.
To provide access to your account and manage user settings.
To enhance and personalize your experience on our platform.
2.2 Communication
To send account-related updates, such as confirmations, invoices, and notices.
To respond to your inquiries and provide customer support.
To deliver promotional content, special offers, and service announcements (you may opt-out of promotional communications at any time).
2.3 Compliance and Security
To verify your identity and prevent unauthorized access to accounts.
To detect, investigate, and mitigate fraudulent or illegal activities.
To comply with legal obligations, including tax and regulatory requirements.
2.4 Analytics and Research
To analyze user behavior and preferences for internal business purposes.
To improve the functionality, quality, and performance of our Services.
2.5 Advertising and Marketing
To provide personalized advertising based on your interests and activities.
To measure the effectiveness of our marketing campaigns.
Section 3: How We Share Your Information
We share your information only as necessary to provide our Services, comply with legal obligations, or protect our rights. Specific sharing practices include:
3.1 Service Providers
We may share your information with trusted third-party service providers that perform functions on our behalf, such as:
Payment processing and financial transactions.
Identity verification and fraud prevention.
Hosting, data storage, and analytics services.
These providers are contractually obligated to handle your information securely and use it only for the specified purposes.
3.2 Legal Compliance
We may disclose your information to:
Comply with legal obligations, such as responding to subpoenas or court orders.
Protect the safety, rights, or property of our users, the public, or Pooling Numbers.
3.3 Business Transactions
In the event of a merger, acquisition, or sale of our assets, your information may be transferred as part of the transaction. We will notify you of any such changes and outline your rights.
3.4 Aggregated or Anonymized Data
We may share non-identifiable information, such as aggregated usage statistics, for research, marketing, or analytical purposes.
Section 4: More Robust Disclosures
Pooling Numbers is committed to transparency regarding how your data is shared and used. We provide detailed disclosures about data-sharing practices, including:
4.1 Third-Party Marketing
We may share your information with trusted partners who use it to provide personalized marketing and promotional offers. These partners are contractually bound to protect your data and may not use it for unauthorized purposes.
4.2 Research and Development
Aggregated and anonymized data may be shared with researchers or institutions to analyze trends, improve our Services, and contribute to industry advancements.
4.3 Partnerships and Affiliates
Pooling Numbers may share data with affiliated companies or business partners for joint ventures or co-branded offerings. Such disclosures are made in strict compliance with applicable privacy laws.
4.4 Legal Obligations
We disclose data when required by law or to respond to legal processes, such as subpoenas or court orders, ensuring full compliance with regulatory requirements.
4.5 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction. Any such transfer will comply with this Privacy Policy.
Section 5: How We Protect Your Information
We implement a range of security measures to safeguard your information from unauthorized access, disclosure, alteration, or destruction. These measures include:
5.1 Data Encryption
All sensitive information transmitted between your device and our Services is encrypted using Secure Socket Layer (SSL) technology.
Stored data is encrypted to protect it from unauthorized access.
5.2 Access Controls
Access to your personal information is restricted to authorized personnel only.
Employees and contractors with access are bound by confidentiality obligations and undergo regular security training.
5.3 Monitoring and Testing
Regular monitoring of our systems for vulnerabilities and breaches.
Routine security testing to identify and address potential threats.
5.4 Third-Party Security
Service providers are required to comply with stringent data protection standards.
Periodic audits of third-party vendors to ensure compliance with our security policies.
5.5 User Responsibility
We encourage you to use strong, unique passwords for your account and to keep your login credentials confidential.
Notify us immediately if you suspect unauthorized access to your account.
While we strive to protect your information, no security system is completely foolproof. By using our Services, you acknowledge and accept these risks.
Section 6: Your Rights and Choices
We respect your privacy and provide you with options to manage your information. These rights include:
6.1 Access and Correction
You can access and update your personal information through your account settings.
If you believe any information is inaccurate or incomplete, please contact us to request corrections.
6.2 Data Portability
You may request a copy of your personal information in a portable format.
6.3 Deletion of Information
You can request the deletion of your personal information, subject to our legal obligations to retain certain data.
Upon your request, we will anonymize or securely delete your information from our systems.
6.4 Opt-Out of Communications
You may opt-out of receiving promotional emails by following the unsubscribe instructions included in each email.
Note that you will still receive essential account-related communications.
6.5 Restriction of Processing
You can request that we limit the processing of your information in certain circumstances, such as when the accuracy of the data is contested.
6.6 Withdrawal of Consent
If you have provided consent for any data processing activity, you can withdraw it at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact our support team at [email protected]. We may need to verify your identity before fulfilling your request.
Section 7: Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including:
7.1 Legal and Regulatory Compliance
To comply with legal, tax, and regulatory obligations.
7.2 Service Continuity
To provide ongoing access to your account and maintain service history.
7.3 Dispute Resolution
To resolve disputes, enforce our terms, and protect our legal rights.
7.4 Operational Needs
To maintain accurate business records and support internal operations.
When your information is no longer needed for these purposes, we will securely delete or anonymize it. In cases where anonymization is not possible, we will store your data in a manner that prevents further use.
Section 8: Jurisdiction-Specific Information
Pooling Numbers complies with all relevant federal and state laws, including the Texas Business and Commerce Code and data privacy regulations applicable to lottery-related operations. As part of our compliance, we ensure:
Geolocation Verification:
Our Services utilize advanced geofencing technologies to confirm that users are physically located within the state of Texas when participating in lottery activities.
Users must provide valid proof of being physically present within Texas during check out, such as geolocation data or a government-issued ID, to comply with state requirements.
State-Specific Lottery Data Protection:
Personal and financial data collected for lottery participation is processed and stored in compliance with Texas statutes governing data security and fraud prevention, such as the Texas Identity Theft Enforcement and Protection Act.
All information is retained within secure systems located in the United States, ensuring adherence to domestic jurisdictional requirements.
Transparency in Compliance:
Pooling Numbers operates as a lottery courier service and not as a lottery retailer. We strictly adhere to the Texas Lottery Commission guidelines, ensuring that all transactions align with the Texas State Lottery Act.
Section 9- Dispute Resolution and No Class Actions
By using our Services, you agree to resolve any disputes with Pooling Numbers through individual arbitration, rather than in court. This section explains our dispute resolution process:
9.1. Arbitration Agreement
All disputes arising from or relating to this Privacy Policy or your use of the Services shall be resolved through binding arbitration conducted by a neutral arbitrator in accordance with the rules of the American Arbitration Association (AAA).
9.2 No Class Actions
You agree to resolve disputes with us on an individual basis and waive any right to participate in a class action lawsuit or class-wide arbitration. This means:
No claims may be combined with those of other users.
You may not bring a dispute as a representative or member of a class.
9.3 Exceptions
This arbitration agreement does not apply to claims for injunctive relief or other equitable remedies that may be pursued in a court of law.
9.4 Arbitration Procedures
The arbitrator’s decision will be final and binding, and judgment on the award may be entered in any court with proper jurisdiction. Each party will bear its own arbitration costs, except as required by law.
9.5 Opt-Out
You have the right to opt out of this arbitration agreement within 30 days of first agreeing to this Privacy Policy by providing written notice to [email protected].
Section 10: Updates to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:
10.1 Notify You
Post the updated Privacy Policy on our website and indicate the "Effective Date" at the top.
Notify you through email or other appropriate means if the changes significantly affect your rights or obligations.
10.2 Your Continued Use
By continuing to use our Services after updates are made, you agree to the revised Privacy Policy. If you do not agree with the changes, you must stop using our Services and may request the deletion of your account.
We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.
Contact Us
If you have any questions, concerns, or feedback about this Privacy Policy or our data practices, please contact us using the details below:
Pooling Numbers Privacy Team
Email: [email protected]
We will respond to your inquiries as soon as possible and are committed to resolving any issues to your satisfaction.