{
  "schemaVersion": 1,
  "documentId": "privacy",
  "locale": "en",
  "revision": "2026-10-27.2",
  "title": "Privacy notice",
  "blocks": [
    {
      "type": "heading",
      "id": "provider",
      "level": 2,
      "text": "Who is responsible"
    },
    {
      "type": "paragraph",
      "text": "Yoofloe Sp. z o.o. provides Lotto Campfire. Our registered address is ul. Księcia Józefa Poniatowskiego 2/6, 50-326 Wrocław, Poland; KRS 0001226002; NIP 8982330825. NIP is a tax identifier, not a statement of VAT registration. Contact support@yoofloe.com or +48 452 528 392 for privacy questions and rights requests."
    },
    {
      "type": "heading",
      "id": "journal",
      "level": 2,
      "text": "Your journal stays on your device"
    },
    {
      "type": "paragraph",
      "text": "The app processes your categories, rule snapshots, numbers, dates, outcomes, spending, prizes, receipts, notes, photo copies, statistics, language and camp choices locally. It has no app account, journal server, automatic synchronization, remote result service, OCR or analytics service. Journal content is not sent to an AI service or used for advertising."
    },
    {
      "type": "paragraph",
      "text": "Fixed/excluded-number preferences and manual number highlights are personal journal data, not purchase authority or official prize confirmation. They are included in the encrypted journal and portable backup. A device locale may suggest a preset order; that does not determine your residence or change recorded currencies."
    },
    {
      "type": "paragraph",
      "text": "Clipboard text is read only after you press Paste numbers. Numbers are checked locally and shown for confirmation before filling a draft. The number board and copying old numbers do not automatically save a purchase or result."
    },
    {
      "type": "heading",
      "id": "photos-backups",
      "level": 2,
      "text": "Photos, encryption and backups"
    },
    {
      "type": "paragraph",
      "text": "The app makes managed photo copies and may resize or re-encode them, correct orientation and create thumbnails. It does not overwrite gallery originals. Viewing, zoom and rotation are supported; cropping and automatic number recognition are not. Your gallery, camera or document provider may have separate cloud settings."
    },
    {
      "type": "paragraph",
      "text": "Records and managed photos use encrypted app storage with a device-protected key. Import/export work can temporarily use app-private cache and memory outside the encrypted database. Cleanup is attempted, but a crash or failed cleanup may leave temporary copies. Encryption is not a guarantee against device compromise, screenshots or every recovery risk."
    },
    {
      "type": "paragraph",
      "text": "You choose the password and destination for an encrypted portable backup. A chosen cloud document provider may upload the file and process its metadata. We do not receive your password, device key or an automatic backup copy. Purchase tokens, purchase authority, widget instances and widget caches are kept outside journal backups. Restore replaces the current journal after a preview and confirmation; it does not merge journals."
    },
    {
      "type": "heading",
      "id": "purchase-widget-data",
      "level": 2,
      "text": "Purchases and launcher widgets"
    },
    {
      "type": "paragraph",
      "text": "Where the optional Fourleaf Pack is offered, Google Play handles checkout. In EEA markets using Google Play billing, the published Play terms identify Google Commerce Limited as the content-purchase contract party. Purchase identifiers, tokens and state are used separately from the journal to recognize, acknowledge and restore access. We do not receive payment-card details. Transaction information made available for support, refunds or required business records may be processed for those purposes. Journal content and number preferences are not purchase payloads."
    },
    {
      "type": "paragraph",
      "text": "Launcher widgets are outside the encrypted app boundary. Amounts and counts default to hidden. Only summaries you enable may appear; individual numbers, photos and notes are not sent to widgets. A launcher can retain an older image. Widget placement and display choices must be set again on another device."
    },
    {
      "type": "heading",
      "id": "website-support",
      "level": 2,
      "text": "This website and support"
    },
    {
      "type": "paragraph",
      "text": "The pages we provide do not set cookies or include advertising, analytics, tracking scripts, upload forms, remote fonts or a journal API. Hosting and access-protection services can still process IP addresses, request information, security logs and any necessary platform security data. Email support processes the address, message and attachments you deliberately send. Do not send passwords, payment-card details, full backups or unrelated ticket records."
    },
    {
      "type": "paragraph",
      "text": "Company-domain email is hosted by Google, and this site uses Vercel’s hosting service. Vercel Inc.’s published Pro data-processing terms distinguish customer-data processing from service-generated data handled under separate roles. Google’s published Workspace entity table lists Google Cloud Poland Sp. z o.o. for Polish customers, but our actual legacy or reseller agreement and any forwarding arrangements still need account-specific confirmation. Providers can process data outside the EEA, including the United States. Applicable contractual safeguards, such as standard contractual clauses, must match the services and roles actually used; this draft does not certify those arrangements. Our retention period is separate from provider deletion cycles. Where Google’s Workspace data-processing addendum applies, deletion of customer data after an irreversible instruction can take up to 180 days, subject to its legal exceptions. Vercel dashboard log visibility does not define retention of every security record or service-generated record. The actual account terms, processing roles and deletion arrangements remain review items."
    },
    {
      "type": "heading",
      "id": "retention",
      "level": 2,
      "text": "Retention and deletion"
    },
    {
      "type": "list",
      "ordered": false,
      "items": [
        "Journal data remains until you delete it, replace the journal, clear app storage or uninstall. Deleting a ticket does not delete separate shared draw results.",
        "Unattached encrypted photo copies and interrupted temporary files can remain; deleting app storage removes app-managed copies. This is not a promise of forensic erasure.",
        "Gallery originals and exported backups remain wherever you or your chosen provider keep them.",
        "PROPOSED routine-support policy, not yet approved or effective: delete routine Lotto Campfire support correspondence 12 months after the case is closed, unless a documented legal duty or an active complaint or claim requires longer retention of necessary records. This proposal is not evidence that mailbox deletion automation is configured. Financial and statutory records follow their applicable duties, not this routine-support period."
      ]
    },
    {
      "type": "heading",
      "id": "rights",
      "level": 2,
      "text": "Purposes and your rights"
    },
    {
      "type": "paragraph",
      "text": "Where the GDPR applies, providing requested functions and contractual support relies on necessity for a contract; identified legal record duties rely on legal obligation; proportionate general support, security and claims handling may rely on legitimate interests after the required assessment. This does not make advertising necessary for the contract. The first public release is planned without ads; any later advertising processing requires a separate notice and applicable choices before it starts."
    },
    {
      "type": "paragraph",
      "text": "Contact support@yoofloe.com about applicable access, correction, deletion, restriction, portability, objection or consent-withdrawal rights. Verification must be proportionate. GDPR requests are normally answered within one month, with any lawful extension explained within that period. You may complain directly to a competent authority, including Poland’s UODO, without contacting us first. We cannot remotely retrieve or erase device-only data we never receive. Mandatory local rights and understandable notices are not waived by a language choice."
    },
    {
      "type": "links",
      "items": [
        {
          "text": "Contact support",
          "href": "/support"
        },
        {
          "text": "Poland’s data-protection authority (UODO)",
          "href": "https://uodo.gov.pl/en"
        },
        {
          "text": "Document versions",
          "href": "/legal/versions"
        },
        {
          "text": "Google privacy information",
          "href": "https://policies.google.com/privacy"
        },
        {
          "text": "Vercel privacy information",
          "href": "https://vercel.com/legal/privacy-policy"
        }
      ]
    }
  ]
}