Privacy Policy

1. About This Policy

This Privacy Policy explains how Fastlotoapp ("Fastlotoapp", "we", "us" or "our") collects, uses, shares and retains personal data when you visit fastlotoapp.com, contact us through the forms on this website, or message us on our WhatsApp Business support channel.

It applies to every channel we operate: the website, the WhatsApp Business number, e-mail and Telegram. By using any of these channels you confirm that you have read and understood this policy.

2. Who We Are

Fastlotoapp is a software and game engineering consulting business operating from Kyiv, Ukraine, and serving clients globally. For the purposes of the EU General Data Protection Regulation (GDPR) and the Law of Ukraine "On Personal Data Protection", Fastlotoapp acts as the data controller for the personal data described in this policy.

• Business name: Fastlotoapp
• Address: Mikhaila Hrushevskoho St, Kyiv, Ukraine, 01008
• Privacy contact: info@fastlotoapp.com

3. Data We Collect

3.1 Information you give us on the website

• Contact form: your name, e-mail address, subject and the content of your message.
• Any additional details you voluntarily include in that message (for example, your company name or project description).

3.2 Information you give us on WhatsApp

• Your WhatsApp phone number and WhatsApp profile name.
• The content of the messages you send us, including text, images, documents, audio and other media attachments.
• Message metadata such as timestamps and delivery/read status supplied by the WhatsApp Business Platform.

3.3 Technical data collected automatically

• IP address (and the country inferred from it), browser type and version, operating system, device type, language settings and screen resolution.
• Referrer URL, requested page, response status and the date and time of the request, recorded in standard server and CDN access logs by our hosting and network providers.

3.4 What we never ask for

We do not request payment card numbers, passwords, identity documents or banking credentials through the website or through WhatsApp. Please do not send such information to us. If you send it anyway, we will delete it as soon as we notice it.

We do not knowingly collect special categories of personal data (health, biometric, political, religious or similar data) and we ask you not to include them in your messages.

4. WhatsApp Business Messaging

Our WhatsApp support channel runs on the WhatsApp Business Platform provided by Meta. We handle those conversations in Chatwoot, a customer-messaging application that we operate as our support desk. Messages you send to our WhatsApp number are delivered through Meta's infrastructure and then stored in our Chatwoot workspace so that our team can read and answer them.

4.1 Opt-in

We only message you on WhatsApp after you have opted in — that is, after you start a conversation with us, click a "Chat on WhatsApp" link, or give us your explicit permission to contact you at that number. We do not buy phone-number lists and we do not send unsolicited marketing messages.

4.2 Opting out

You can stop receiving WhatsApp messages from us at any time by replying STOP in the conversation, by blocking our number in WhatsApp, or by e-mailing info@fastlotoapp.com. We will stop sending you messages promptly, and in any case within 48 hours of your request.

4.3 What Meta does with your data

Meta Platforms processes your messages in order to deliver them and operates WhatsApp under its own terms. Meta's handling of your data is described in the WhatsApp Privacy Policy, which applies in addition to this policy. We comply with the WhatsApp Business Messaging Policy and the Meta Platform Terms when we use this channel.

5. AI-Assisted Replies

To answer common questions faster, some support conversations may be assisted by an AI assistant built on the Anthropic Claude API. Where this is used:

• The content of your message may be sent to Anthropic in order to generate a suggested or automatic reply.
• We minimise what is sent: we do not deliberately transmit payment data, identity documents or other sensitive information to the AI provider.
• Under Anthropic's commercial API terms, data submitted through the API is not used to train its models.
• A human member of our team remains available at all times — you can always ask to speak to a person.

6. How We Use Your Data

We use the personal data described above to:

• answer your questions and provide the support or consulting information you asked for;
• keep the history of a conversation so that you do not have to repeat yourself;
• prepare quotations and communicate about projects, contracts and invoices;
• detect and prevent spam, abuse, fraud and attacks against our systems;
• diagnose technical faults and keep the website secure and available;
• comply with legal, accounting and tax obligations.

We do not build advertising profiles, we do not run behavioural advertising, and we do not sell or rent your personal data to anyone.

7. Legal Basis for Processing

8. Third Parties We Share Data With

We share personal data only with the service providers that make our website and support channel work, and only to the extent they need it. Each of them is bound by a data-processing agreement or equivalent contractual terms.

Apart from the recipients listed above, we do not transfer your personal data to any third party.

9. International Data Transfers

Some of the providers listed above are located outside Ukraine and outside the European Economic Area, mainly in the United States and the European Union. Where personal data is transferred internationally, the transfer is protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision, together with technical measures such as encryption in transit.

10. Retention Periods

When a retention period expires, the data is deleted or irreversibly anonymised.

11. Cookies and Local Storage

This website is a static site and uses no advertising cookies, no tracking pixels and no third-party analytics profiling. Only strictly necessary technical storage may be used to keep the site working correctly (for example, remembering your language choice in your browser's local storage). You can clear this at any time through your browser settings without losing access to the site.

12. Your Rights

Subject to applicable law, you have the right to:

• Access — ask what personal data we hold about you and receive a copy;
• Rectification — ask us to correct inaccurate or incomplete data;
• Erasure — ask us to delete your data ("right to be forgotten");
• Restriction — ask us to limit how we process your data;
• Objection — object to processing based on our legitimate interests;
• Portability — receive your data in a structured, machine-readable format;
• Withdraw consent — at any time, without affecting processing that already took place;
• Complain — lodge a complaint with your local data protection authority or with the Ukrainian Parliament Commissioner for Human Rights.

To exercise any of these rights, write to info@fastlotoapp.com or send us a message on our WhatsApp support line. We respond within 30 days. We may ask you to confirm the phone number or e-mail address the request relates to, so that we do not disclose data to the wrong person.

13. Data Deletion

You can ask us to delete your data at any time. Full step-by-step instructions are on our Data Deletion page. In short: send an e-mail titled "Data Deletion Request" to info@fastlotoapp.com, or reply DELETE in our WhatsApp conversation. We complete verified deletion requests within 30 days.

14. Security

• All traffic to and from this website is encrypted with HTTPS/TLS, and HSTS is enforced.
• Access to our support desk is limited to authorised team members and protected by individual accounts and strong authentication.
• WhatsApp messages are protected by Meta's encryption while in transit.
• We apply the principle of least privilege and review access rights regularly.

No method of transmission or storage is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the competent supervisory authority and, where required, the affected individuals without undue delay.

15. Age Restriction

Our services and support channels are intended for individuals aged 18 and over. We do not knowingly collect personal data from children. If we learn that we have collected data from a person under 18, we delete it immediately.

16. Policy Updates

We may update this policy from time to time — for example, when we add a new service provider or a new support channel. The "Last updated" date at the top of this page always reflects the current version. If a change is material, we will publish a notice on the website before it takes effect.

17. Contact Us