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Privacy Policy

Effective date: 24 June 2026

1. Introduction

This Privacy Policy explains how Luckytwril (“Luckytwril”, “we”, “us” or “our”) collects, uses, stores and protects your personal data when you use the Luckytwril mobile application on iOS and Android (the “App”). Luckytwril is a scratch-to-win rewards app: you can buy an entry pass or enter for free (no purchase necessary), scratch cards to reveal prizes, and redeem your winnings for rewards and offers. Luckytwril is a sweepstakes with a free alternative method of entry — it is not gambling. The App is intended for adults aged 18 and over and is operated in Sri Lanka. By using the App you agree to the practices described in this policy.

2. Information We Collect

We only collect the data we need to operate the App. Specifically, we collect:

  • Account information — your email address and/or mobile phone number, used to sign you in and secure your account.
  • Identifiers — your account user ID, device identifiers, and an advertising identifier.
  • Purchase history — records of in-app purchases (entry passes). Payments are processed by the Apple App Store and Google Play; we do not collect or store your card or banking details.
  • Push notification token — used to send you notifications (for example, about wins, draws and account activity).
  • Usage & device data for ads — collected by Google AdMob to show ads, including device type, operating system version, ad interactions, and an approximate region derived from your IP address.
  • Reward & redemption activity — your scratch results, winnings, and redemptions, stored in your account.

We do not collect your precise GPS location.

3. Why We Collect It & Our Legal Basis

We process your data under the following purposes and legal bases (in line with applicable data protection law in Sri Lanka, including the Personal Data Protection Act No. 9 of 2022):

  • To create and secure your account (email/phone, user ID, device identifiers) — necessary to provide the service you request (performance of a contract).
  • To run entries, scratching and prizes (purchase history, reward & redemption activity) — necessary to deliver the sweepstakes and fulfil prizes you win (performance of a contract).
  • To send notifications (push token) — based on your consent, which you can withdraw at any time in your device settings.
  • To show ads that keep the App free (advertising identifier and usage/device data via AdMob) — based on your consent and our legitimate interest in funding the service.
  • To prevent fraud and abuse and to meet legal obligations (identifiers, purchase records) — based on our legitimate interests and legal compliance.

We do not sell your personal data.

4. Third-Party Services We Use

We rely on the following third-party providers to operate the App. Their handling of data is governed by their own privacy policies:

5. How Your Data Is Stored & Secured

Your data is stored securely using Google Firebase on Google Cloud infrastructure, which provides encryption in transit and at rest and access controls. We restrict access to personal data to those who need it to operate the App. While no method of transmission or storage is completely secure, we take reasonable technical and organisational measures to protect your information.

6. Data Retention

We retain your personal data for as long as your account is active or as needed to provide the App, fulfil prizes, comply with our legal obligations, resolve disputes and prevent fraud. When you delete your account, we delete or anonymise your personal data within a reasonable period, except where we are required to retain certain records (such as purchase and tax records) by law.

7. Your Rights & Choices

You have the right to:

  • Access the personal data we hold about you.
  • Correct inaccurate or incomplete data.
  • Delete your account and associated data. You can delete your account directly in the App (in-app account deletion), or contact us at luckytwrillhelp@gmail.com and we will action your request.
  • Opt out of personalised ads. You can reset or limit your advertising identifier and turn off ad personalisation in your device settings (iOS: Settings → Privacy & Security → Tracking / Apple Advertising; Android: Settings → Google → Ads), and manage Google ad settings at adssettings.google.com.
  • Withdraw consent (for example, disable push notifications) at any time in your device settings.

To exercise any of these rights, contact us at luckytwrillhelp@gmail.com.

8. Children’s Privacy

Luckytwril is intended only for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected data from a minor, we will delete it promptly. If you believe a minor has provided us with personal data, please contact us at luckytwrillhelp@gmail.com.

9. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the “Effective date” at the top of this page and, where the changes are significant, notify you within the App or by push notification. Your continued use of the App after an update takes effect means you accept the revised policy.

10. Governing Law

This Privacy Policy is governed by the laws of Sri Lanka, and any disputes relating to it are subject to the jurisdiction of the courts of Sri Lanka.

11. Contact Us

For any privacy questions, data requests, or to delete your account and data, contact us at luckytwrillhelp@gmail.com. You can also visit our Support page.