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Draft, not yet in effect.

Lotly Consumer Health Data Policy

This policy is about one kind of information: the food allergens you choose to watch in Lotly. Some laws, including Washington’s My Health My Data Act and Nevada’s consumer health data law, treat information about allergies as “consumer health data”. Our full Privacy Policy covers everything else: https://lotly.pages.dev/privacy/.

Lotly is operated by Willis Yang. Contact: lotlysupport@gmail.com.

What we collect, and how we use it

  • What: the food allergens you select to watch. There are nine: peanuts, tree nuts, milk, egg, wheat, soy, sesame, fish and crustacean shellfish. They may be your own, or those of anyone you shop or cook for. With them we keep your decision about allergen alerts and when you made it. We do not collect symptoms, diagnoses, or any other health information.
  • Where it comes from: only you, when you select allergens in the app.
  • How it is used: on your iPhone, your allergens show which recalls may matter to you. Only if you consent does the app send them to Lotly’s server, where they are stored and used for one purpose: deciding which recall alerts to send you.
  • How you consent: when you choose allergens, the app asks whether Lotly may use them for recall alerts. You can answer “Enable allergen alerts” or “Continue without allergen alerts”; the full explanation offers “Use for alerts” or “Keep on this iPhone only”.
  • If you do not consent: the app does not send your allergens, and Lotly’s server stores none. (Allergens sent by versions of Lotly from before this choice existed are removed the next time the app sends your choices without your consent.) Lotly still uses them on your iPhone. Recall alerts are then not based on allergens.
  • What we never do: use them for advertising, sell them, or use them to track you across other apps or websites. Lotly does not use location services and does not set up any virtual boundary (“geofence”) around any place.

Who receives it

We share consumer health data only with the service providers that process it for us, under our instructions, to provide the service you asked for, and only with your consent:

  • Supabase (database hosting, Northern California, USA) stores your allergens and your consent decision with a random installation identifier.
  • Expo and Apple deliver recall alerts if you turn them on. The alert text contains only public recall facts. Because an alert is sent to you because of your choices, its delivery could indicate an allergen you watch.
  • Google (Gmail) hosts our support mailbox. It holds consumer health data only if you email us and include it.

RevenueCat, which checks subscriptions, receives none of it.

We do not sell consumer health data, and we do not share it with any other third party or affiliate. No third party collects it over time and across different websites or apps through Lotly.

Your rights and choices

  • Withdraw consent at any time. Use Profile → Privacy & Data Controls → Allergens and alerts → “Stop using allergens for alerts”, or clear your allergens. The change takes effect on your iPhone at once. The copy on our server is removed as soon as your iPhone is online; if it is offline, the app shows that removal will finish when your iPhone is back online.
  • Delete. “Reset app and delete my data” (Profile → Privacy & Data Controls) deletes everything our server holds for this installation, immediately. Supabase makes daily database backups. Its documented retention period for our plan is seven days. Deleted records may remain in those backups until the backups expire. If you stop using Lotly, our server deletes your data automatically after 12 months without use.
  • Access. “Show what Lotly’s server holds”, in Privacy & Data Controls, shows the allergens and consent decision stored for your installation and the list of service providers, and “Share as file” saves a copy.
  • Requests by email. In the app, tap “Get a request code” (Privacy & Data Controls), choose “Email me a copy of my data” or “Delete my data”, then email the code to lotlysupport@gmail.com.
    • Why a code. Lotly has no accounts, so the code is how we confirm the request comes from your installation.
    • What the code can do. It works once, expires after 14 days, and only lets us find your installation for the request you chose. We never ask for your installation identifier, and you should never send it.
    • If you no longer have the app, or your subscription has ended. Reinstalling Lotly on the same iPhone usually brings your installation back from the phone’s secure storage, and subscribing again or restoring a purchase reopens the in-app options.
    • If that isn’t possible (a new or erased phone), we cannot confirm which data is yours. We will reply in writing, explain why, and tell you how to appeal. Our server’s copy is still deleted automatically 12 months after the app was last used.
  • Deadlines. Lotly answers within 45 days of receiving your request, and deletes within 30 days of checking your code (usually the same day); a deletion is never extended. If another request needs more time, Lotly can extend it once, by up to 45 more days, and tells you why within the first 45 days.
  • Appeal. If we decline your request, reply to our answer with the word “Appeal”. We will answer in writing within 45 days. If we deny your appeal, we will tell you how to contact your state attorney general.
  • No charge. We do not charge for requests, and we never treat you differently for using these rights.

Changes to this policy

If we want to collect a new kind of consumer health data, or use it for a new purpose, we will ask for your consent first. For other material changes, we will post the new version on this page at least 30 days before it takes effect, tell you in the app, and update the effective date above.

Contact

Willis Yang: lotlysupport@gmail.com