Privacy Policy

Appluminati Labs Ltd (“Appluminati”, “we”, “us”) publishes consumer apps and websites, including Freqly. This Privacy Policy describes how we handle information when you use www.freqly.site, the Freqly apps for iOS and Android, and related applications (the “Services”).

We do not sell personal information.

1. Who is responsible

Appluminati Labs Ltd is the organization responsible for the Services. Our location is Toronto, Canada. Privacy Officer, Appluminati Labs Ltd. — privacy@appluminati.com.

2. Information we collect

Information you provide

Depending on the product, you may create an account with an email address and password, and accept the Terms of Service, this Privacy Policy, and (where required) consent for electronic messages. A Freqly account may also include a name, if you provide one, and a record that you confirmed you are 19 or older, and when you confirmed it. We may store a hashed password, acceptance timestamps, consent wording, and the IP address recorded at signup. You may enter lottery numbers so we can show how they did in past draws; that input is sent to our API to look up historical draws. We do not ask for your date of birth, and we do not ask for payment card details or government ID solely to browse this corporate website.

If you use our contact form, we collect your name, email, subject, and message so we can reply.

Freqly launch list

Freqly launch list. If you sign up at www.freqly.site/notify, we collect your name, email address, the confirmation that you are 19 or older given by signing up, your consent record, language preference, IP address, the page you signed up from, and any campaign parameters in its link. We use them only to send Freqly launch emails. We don't sell or share this list, and we don't use it for third-party offers. The advertising pixels described below do not receive this list, and we never send your email address or name to them.

Service providers. We keep the Freqly launch list only in MailerLite (MailerLite Limited / UAB "MailerLite"), our email service provider, which sends the launch notice and Freqly updates. We use Resend (Resend, Inc.) only to send the confirmation email. These providers store information outside Canada, including in the United States [and the European Union], where it may be accessible to courts, law enforcement and national security authorities under local law. If we change email provider, we will update this notice.

Retention. We keep your details until you unsubscribe, or until we remove inactive contacts. If you haven't opened or clicked our emails for 12 months, we'll ask you to confirm, or remove you. If you don't confirm within 7 days, the confirmation link expires. We don't keep your details anywhere until you confirm; before then they exist only inside the link we email you. After you unsubscribe we keep only your email address and consent record, to make sure we don't email you again and to show we had consent.

Your choices. You can unsubscribe at any time using the link in any email, or by writing to privacy@appluminati.com. We act on unsubscribe requests within 10 business days.

Advertising pixels (Meta and TikTok)

Off unless you say yes. The Freqly launch page (www.freqly.site/notify) and the confirmation page can use advertising pixels from Meta Platforms (Facebook and Instagram) and TikTok. They are off by default. They load only if you choose Accept for advertising in our privacy choices. If you choose Reject, or don’t choose, they don’t load and nothing is sent to Meta or TikTok. Rejecting does not affect your ability to sign up for launch emails.

What the pixels collect. If you accept, Meta and TikTok receive, from your browser: the page you visit and the page you came from (including campaign details in the link, such as an ad-click ID); your IP address; your browser and device type; identifiers stored in cookies or similar technologies set by Meta or TikTok; and the event “page viewed”. On the page that confirms your sign-up, they also receive one event saying a sign-up was confirmed. If you are logged in to Facebook, Instagram or TikTok in the same browser, they may link this to your account.

What we do not send. We do not send your name, email address, phone number or the contents of any form, in plain or scrambled (“hashed”) form. We do not use advanced matching features. We do not upload our launch list to Meta or TikTok. We do not send any information about the lotteries or numbers you look at.

Why. To measure whether our ads led people to the launch page and sign-up, and to make our ads work better. Meta and TikTok may also use the information for their own purposes, such as showing and improving ads and their services, under their own policies. We do not use the pixels to build lists of visitors to show them ads again.

Who receives it. Meta Platforms, Inc. and its affiliates (including Meta Platforms Ireland Limited), and TikTok Pte. Ltd., TikTok Inc. and their affiliates. They may process it outside Quebec and outside Canada, including in the United States, where it may be accessible to courts, law enforcement and national security authorities under local law.

How long. Your privacy choice is stored on your device until you change it or clear your site data, and we ask again after 12 months. We don’t keep a copy of what the pixels send. Meta and TikTok keep what they receive under their own policies.

Your choices and rights. You can change your mind at any time with Privacy choices in the footer of any page; withdrawing stops future sending right away. Data already sent stays with Meta or TikTok and is managed through them:

• Meta: Meta Privacy Policy and your ad preferences in Facebook or Instagram settings.
• TikTok: TikTok Privacy Policy and the ad settings in the TikTok app.
• Industry opt-out tools: Your Ad Choices (Canada) and aboutads.info/choices.

You may also ask us for access to information we hold about you, or ask us to correct or delete it, or withdraw your consent, by writing to privacy@appluminati.com. We respond within 30 days. You can complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.

Who this is for. Freqly is for adults 19 and over. Please choose Reject if you are under 19.

Information collected automatically

• Our servers keep technical logs, including IP addresses, for security and troubleshooting, and delete them on a rolling basis.
• The Freqly app does not collect advertising IDs or device identifiers and contains no analytics or advertising tools.
• Purchase records: purchase tokens and order IDs from Apple or Google.
• If you opt in to marketing emails, we record your opt-in time and IP address as proof of consent and share them with our email provider.
• Security and error diagnostics needed to operate the Services.

We do not currently

• send your email address, name or launch-list details to advertising platforms;
• knowingly collect personal information from children.

We do not collect precise GPS location in our apps or websites.

Help resources and your region. To show the right gambling-help line, the app may use your IP address to estimate your province at the moment you open the help screen. We don't store that estimate. You can also choose a region in Settings; it stays on your device, is used only for help resources and game lists, and doesn't change who can use the app (19 or older everywhere). We don't collect precise GPS location.

Google Analytics. With your consent, this website uses Google Analytics 4, a service provided by Google. It records pages viewed and selected interactions (successful notify-me submissions, store-button clicks, and language changes), along with the referring site’s origin and browser, device, and approximate-location data. Page URLs sent to Google exclude query strings, and referrers exclude paths and query strings. Google may process your IP address and set identifiers in cookies such as _ga. We never put email addresses, names, form contents, notify tokens, or other personal data into analytics events. Analytics is off by default and turns on only if you accept it in our privacy choices. Your choice is stored in local storage on your device. You can withdraw consent or change your choice at any time using “Privacy choices” in the footer; withdrawing stops future analytics collection. Google’s advertising features stay disabled. Advertising by Meta and TikTok is a separate choice, described under Advertising pixels. Google processes this information under its own privacy terms and may process it outside Canada.

3. How we use information

• to provide and improve the Services;
• to create and secure accounts, including activation emails where applicable;
• with your express consent (including Canada’s anti-spam law / CASL where it applies), to send product emails;
• to respond to contact requests;
• to keep the Services secure, reliable, and legally compliant;
• to understand aggregate usage (for example whether a route is failing).

4. Legal bases (where applicable)

Where privacy law requires a legal basis, we rely on: performing the service you request; our legitimate interests in operating a secure business; consent where we ask for it; and compliance with law. In Canada we follow applicable private-sector privacy law, including PIPEDA where it applies.

5. Sharing

We use these service providers, which process personal information on our behalf:

• Railway (app hosting and database) — United States (US West).
• We use a transactional email provider to send account and purchase emails. It may process your email address outside Canada, including in the United States.
• Apple and Google — process in-app purchases; we receive purchase tokens and order IDs to verify your purchase.
• If you opt in to marketing emails, we share your email address, opt-in time and IP address with our email service provider, which may store it outside Canada.
• Meta Platforms and TikTok: only if you accept advertising pixels, as described under Advertising pixels.

We may disclose information if required by law or to protect rights, safety, and security.

6. Retention

We keep information only as long as needed for the purposes above, including legal, accounting, and security requirements. Account data is retained while your account is active. After a confirmed deletion request, we delete the account email, hashed password, name if we hold one, lottery numbers stored with the account, the record that you confirmed you are 19 or older, acceptance timestamps, and the IP address recorded at signup.

We acknowledge your request within 2 business days. To protect your account, we may ask you to confirm the request from the email address on the account. Once confirmed, we delete the items listed above within 30 days. Our hosting provider keeps backups of our database for disaster recovery. Deleted data may stay in backups for a limited time until they are overwritten. We keep purchase and transaction records for up to 6 years after the end of the tax year they relate to, as required for tax and accounting. We keep a record of your marketing-email consent (your email address, when you opted in or out, and the IP address used) for up to 3 years after you unsubscribe or delete your account, so we can show we had your permission if we are asked. We use it for nothing else. Our servers keep technical logs, including IP addresses, for security and troubleshooting, and delete them on a rolling basis. If we can't complete your request within 30 days, we'll tell you why and when we will.

7. Security

We use administrative, technical, and organizational measures appropriate to the risk, including encrypted transport (HTTPS) and hashed passwords where accounts exist. No method of transmission or storage is perfectly secure.

8. Children

Freqly is for adults 19 and over. We do not knowingly open a Freqly account for anyone under 19. This corporate website does not ask you to confirm your age. If you tell us you are under 19, or if you believe someone under 19 has provided personal information, contact freqly@appluminati.com and we will close the account and delete the associated personal information.

9. Your rights

Depending on where you live, you may have rights to access, correct, delete, or export personal information, or to withdraw consent. Contact privacy@appluminati.com. We respond within 30 days. You can also complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information. In Quebec, rights under Law 25 include portability and de-indexation.

To delete a Freqly account, open the app, go to the Account tab, and choose Delete account. You can also request deletion without the app at www.freqly.site/delete-account. That form emails support. It does not delete the account by itself. What we delete and what we may keep is described under Retention and on the deletion page.

Timeline. We acknowledge your request within 2 business days. To protect your account, we may ask you to confirm the request from the email address on the account. Once confirmed, we delete the items listed above within 30 days. Our hosting provider keeps backups of our database for disaster recovery. Deleted data may stay in backups for a limited time until they are overwritten. We keep purchase and transaction records for up to 6 years after the end of the tax year they relate to, as required for tax and accounting. Up to 3 years after deletion or unsubscribe: marketing-consent records are deleted. Our servers keep technical logs, including IP addresses, for security and troubleshooting, and delete them on a rolling basis. If we can't complete your request within 30 days, we'll tell you why and when we will.

10. International transfers

Your information is stored and processed outside your province, including in the United States, where it may be accessible to courts and authorities under local law. We assess and contractually protect these transfers. Meta and TikTok may process information outside Canada, including in the United States and other countries.

11. Cookies

See our Cookie Policy for details on cookies and similar technologies used on our websites.

12. Changes

We may update this Policy. The “Last updated” date will change when we do. For material changes, we notify users in the app or by email before they take effect. Continued use of the Services after an update means you accept the revised Policy where permitted by law.

13. Contact us about privacy

Our Privacy Officer is responsible for how Appluminati Labs Ltd. handles personal information, including requests to access, correct or delete it.

Privacy Officer, Appluminati Labs Ltd.
Email: privacy@appluminati.com

We respond within 30 days.