Privacy Policy

1. Who We Are and What This Policy Covers

Syntropy AI Global Inc. is a Delaware corporation and a business software company with its principal place of business at 201 Saint Pauls Ave, Apt 1G, Jersey City, NJ 07306, United States. We develop and operate Lottery Management (https://www.lotterymanagements.com) and SyntropyCRM (https://www.syntropycrm.com), provide custom software development services, and publish this corporate website.

This Privacy Policy applies to the following (together, the "Services"):

• Our websites, including the Syntropy AI Global corporate website and the Lottery Management website at lotterymanagements.com.
• The Lottery Management web application (the store dashboard), its in-store display screens, and its display applications for Android TV and Amazon Fire TV devices.
• SyntropyCRM, its web application, and the Syntropy Support desktop app used for remote support sessions (see Sections 17 and 18).
• Our custom software development services (see Section 19).
• Sales, support, and account communications between us and our business customers.

2. Nature of Our Service — Business Software, Not Gambling

Lottery Management is a software-as-a-service tool that helps lottery retailers manage their own store operations. It lets a retailer record its instant-ticket pack inventory (received, activated, sold out), record and review ticket sales, close out shifts and business days, produce sales reports, manage staff permissions, and show product information, prices, and the store's own announcements and advertising on in-store display screens.

Lottery Management is not a gambling, gaming, betting, or lottery service. Specifically, neither Syntropy AI Global nor Lottery Management:

• Operates, conducts, sponsors, or promotes any lottery, raffle, sweepstakes, contest, game of chance, or game of skill.
• Sells, resells, issues, or delivers lottery tickets or lottery shares, whether online or in person, and does not act as a lottery sales agent or courier.
• Accepts wagers, bets, stakes, entry fees, or any payment from players or members of the public.
• Collects, holds, transfers, or settles lottery ticket proceeds, player funds, or prize money, and does not validate, claim, redeem, or pay lottery prizes.
• Provides odds, predictions, number selections, or any service intended to influence the outcome of a lottery drawing or game.
• Offers accounts, purchases, or any interactive features to consumers or lottery players. Only businesses and their authorized staff have accounts.
• Connects to, replaces, or functions as a state lottery terminal or a state lottery's sales, validation, or accounting system.

3. Legal Context: State Lotteries in the United States

In the United States, lotteries are lawfully conducted by state and territorial governments under their own state laws. Official government lotteries operate in most U.S. states and in the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Each jurisdiction's lottery is a government agency (or a government-controlled entity) that sets the rules for its games and licenses the retail businesses permitted to sell its tickets.

Federal law recognizes state-conducted lotteries. 18 U.S.C. § 1307 provides express exceptions from the federal lottery statutes for "a lottery conducted by a State acting under the authority of State law," and defines "State" to include the states, the District of Columbia, Puerto Rico, and U.S. territories.

State lotteries sell tickets through retail businesses that they license, such as convenience stores, gas stations, grocery stores, and pharmacies. Licensing typically involves an application, background and financial checks, retailer training, and ongoing compliance with the state lottery's rules. For example, New Jersey law provides for the licensing of lottery sales agents by the state lottery (N.J.S.A. 5:9-11), and the Kansas Lottery requires prospective retailers to complete an application and pass a criminal background check.

Lottery Management is designed for these licensed retailers. Each customer is responsible for holding and maintaining any license required by its state lottery and for complying with that lottery's rules, including rules on the sale of tickets only to adults of legal age, advertising, and responsible-gaming messaging. We may ask for or record a customer's state lottery retailer number, and we may suspend accounts that we reasonably believe are being used outside a licensed retail context or for any unlawful purpose.

4. Our Role: Business, Controller, and Service Provider

We act as the "business" or "controller" for personal information about visitors to our websites, people who contact us, and the owners and billing contacts of our customer accounts.

We act as a "service provider," "processor," or "contractor" for information that a customer places in its Lottery Management workspace — for example, its employees' staff accounts and its store sales and inventory records ("Customer Data"). We process Customer Data only to provide and support the Services for that customer and as described in this policy and our agreement with the customer. Questions or requests about Customer Data should be directed to the relevant customer, and we will assist that customer as required by law.

5. Information We Collect

The information we collect depends on how you interact with the Services. The table below covers our websites and Lottery Management; SyntropyCRM is covered in Sections 17 and 18, and custom software services in Section 19.

6. How We Use Information

We use personal information to:

• Create and manage accounts, authenticate users, and enforce the permissions a store owner sets for its staff.
• Provide the Services, including recording inventory and sales, preparing shift, day, and month reports, emailing reports to the address the customer designates, and updating in-store display screens in real time.
• Process subscriptions, invoices, renewals, and cancellations through our payment processor.
• Respond to inquiries, demo requests, and support requests, and send service, security, and account notices.
• Provide the Lottery AI Assistant and voice commands when a user chooses to use them.
• Protect the Services and our customers — for example, to prevent fraud and abuse, limit repeated requests, investigate security incidents, and verify that accounts are used by legitimate retail businesses.
• Maintain, troubleshoot, and improve the Services and develop new features.
• Comply with law, legal process, tax and accounting obligations, and enforce our agreements.

7. The Lottery AI Assistant

The Lottery AI Assistant answers questions about a store's own sales, inventory, displays, and settings. When a user asks a question, we send the question, up to the last few messages of the conversation, any file the user uploads, and a summary of the relevant store records (which may include the account owner's name and the store name) to a third-party AI model provider to generate the response. We currently use Google (Gemini) and, as a fallback, Groq.

We do not store AI Assistant conversations or uploaded files after the response is returned, and we do not use Customer Data to train artificial-intelligence models. AI providers process the information under their terms for business API customers. The AI Assistant is an informational tool: it does not change records, close shifts, or take actions on its own, and all sales and inventory figures are calculated by the software, not by the AI model.

8. Voice Features and In-Store Display Screens

Speech recognition. Voice input for the AI Assistant and voice commands for display screens use the speech-recognition service built into the user's web browser or device (for example, Google Chrome sends audio to Google for transcription). When audio is uploaded to the AI Assistant, it is transcribed using a Google speech-recognition service. We use the resulting text only to carry out the command or answer the question. We do not record, store, or retain audio, and we do not use voice data to identify any person.

Display voice control. When voice control is enabled on an in-store display screen, the screen's browser listens for spoken commands that begin with the word "Display" (for example, "Display, show twenty dollar tickets") so staff can change what the screen shows hands-free. Because the display is located in a store, speech from people nearby may be processed by the browser's speech-recognition service while it listens for the command word. Only recognized commands are acted on, and no audio or transcript is stored by us. Customers that enable voice control are responsible for providing any notice to shoppers and employees required by the laws of their state, and may turn voice control off at any time.

Public display content. Display screens and display links are designed to be shown publicly. They present the store's name and logo, ticket and price information, announcements, and the store's own advertising. Customers should not place personal information about any individual in display content.

Camera use for pairing. When a user scans a QR code to pair a display device, the camera image is processed locally on the user's device to read the code. Camera images are not uploaded or stored.

9. Cookies, Local Storage, and Advertising

Essential cookies and storage. Lottery Management uses cookies and browser storage that are necessary for the Services to work, including a sign-in token, basic profile information for the signed-in user, staff session information, a marker used when our support personnel access an account at the customer's request, and saved preferences such as theme, remembered sign-in email, and dismissed notices. These remain until you sign out, clear your browser data, or they expire (no longer than one year).

Syntropy AI Global website. Our corporate website uses only strictly necessary storage (for example, your theme and cookie choices). It does not load analytics or advertising scripts unless you opt in through our cookie settings.

Advertising on Lottery Management. The Lottery Management website and application display advertisements served by Google AdSense. Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to this and other websites. Google's use of advertising cookies enables it and its partners to serve ads to users based on their visits to our sites and other sites on the internet.

• You may opt out of personalized advertising from Google by visiting Google My Ad Center (https://myadcenter.google.com) or Google Ads Settings (https://adssettings.google.com).
• You may opt out of personalized advertising from participating third-party vendors at https://www.aboutads.info/choices.
• Learn how Google uses information from sites that use its services at https://policies.google.com/technologies/partner-sites.
• You can also block or delete cookies in your browser settings. Blocking essential cookies will prevent you from signing in.

10. How We Share Information

We do not sell personal information for money. We disclose personal information only as follows:

• Service providers. With vendors that process information on our behalf to operate the Services, under contracts that limit their use of the information. Our current service providers are listed in the table below.
• Within the customer account. With the account owner and the staff members the owner authorizes, according to the permissions the owner sets, and by email to the report recipients the owner designates.
• Support access. Our authorized support personnel may access a customer's account to provide support, investigate issues, or verify account eligibility. Such access is limited to that purpose.
• Advertising. Through Google AdSense as described in Section 9. Under some state laws, this may be considered "sharing" for cross-context behavioral advertising or "targeted advertising." See Section 13 for how to opt out.
• Legal and safety. When we believe in good faith that disclosure is required by law, subpoena, or court order, or is necessary to protect the rights, property, or safety of our customers, users, the public, or us.
• Business transfers. In connection with a merger, acquisition, financing, or sale of all or part of our business, subject to this Privacy Policy.
• With consent. With any other party when you or the customer direct us to.

11. Payment Information

Subscription fees for Lottery Management are paid by our business customers through Stripe Checkout and the Stripe customer portal. Payment card details are entered on pages hosted by Stripe and are processed and stored by Stripe in accordance with the Payment Card Industry Data Security Standard. We do not receive, store, or have access to full payment card numbers or card security codes. We receive only the information needed to manage the subscription, such as the Stripe customer and subscription identifiers, plan, and payment status. Stripe's handling of personal information is described in the Stripe Privacy Policy at https://stripe.com/privacy.

The only payments processed in connection with Lottery Management are business software subscription fees. No lottery ticket purchases, wagers, entry fees, or prize payments are ever made through, processed by, or held by our Services.

12. How Long We Keep Information

We retain personal information only for as long as needed for the purposes described in this policy:

• Account, staff, and store business records: for as long as the customer's account is active. When an account is closed, the customer may request deletion, and we will delete or de-identify the account's data within 90 days of the request, except as described below. Reports already emailed to recipients the customer designated remain in those recipients' mailboxes.
• Inquiry and sales communications: for up to 24 months after our last interaction, unless you ask us to delete them sooner.
• AI Assistant conversations, uploaded files, and voice audio: not stored after the request is completed.
• Billing, tax, and transaction records: for as long as required by tax and accounting laws, generally up to seven years.
• Security and support logs: for as long as reasonably necessary to protect the Services and investigate incidents.

13. Your Privacy Rights

Residents of California and other states with comprehensive privacy laws (including, for example, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia) have rights regarding their personal information, subject to exceptions in those laws. These may include the right to:

• Know and access the personal information we have collected about you and how we use and disclose it.
• Correct inaccurate personal information.
• Delete personal information we collected from you.
• Receive a copy of your personal information in a portable format.
• Opt out of the "sale" or "sharing" of personal information, targeted advertising, and certain profiling. We do not sell personal information for money. To opt out of personalized advertising, use the Google and industry opt-out tools listed in Section 9, or contact us.
• Limit the use of sensitive personal information. We use sensitive personal information (such as account passwords and any bank account details a customer provides) only to provide the Services, as permitted by law, and not to infer characteristics about you.
• Appeal our decision on your request, by replying to our decision and asking for an appeal.
• Not be discriminated against for exercising any of these rights.

14. How to Make a Privacy Request

To make a request, email privacy@syntropyaiglobal.com or get@lotterymanagements.com with the subject "Privacy Request", or call +1 201-552-3177. Please tell us your name, the email address associated with your account or inquiry, and the right you wish to exercise. We will verify your request by matching the information you provide with information we hold, and may ask for more information where needed. You may use an authorized agent; we may ask the agent for proof of authorization and ask you to verify your identity directly.

We will respond within 45 days, or tell you if we need up to 45 more days as permitted by law. If your personal information was placed in Lottery Management by a store that employs you, that store controls your information; we will refer your request to the store or assist the store in responding.

15. How We Protect Information

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit (HTTPS/TLS), one-way hashing of passwords, hosting with infrastructure providers that encrypt stored data at rest, separation of each customer's data, role-based permissions that store owners control, and logging of support access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you and the relevant authorities as required by law.

16. Children and Age Requirements

The Services are intended solely for businesses and their adult personnel. They are not directed to children, and we do not knowingly collect personal information from anyone under 18 years of age. Lottery tickets are sold only by licensed retailers to adults of legal age under state lottery rules; our Services do not sell or advertise the sale of lottery tickets to anyone. If you believe a minor has provided personal information to us, contact us and we will delete it.

17. SyntropyCRM and the Syntropy Support App

SyntropyCRM is a sales CRM that businesses use to capture leads, manage contacts, companies, deals, tasks, and quotes, and message their customers. For the information a business places in or receives into its SyntropyCRM workspace, the business is the controller and we act as its service provider or processor, as described in Section 4. If you are a customer or lead of a business that uses SyntropyCRM, please contact that business first; we will help it respond to your request.

Information processed in SyntropyCRM:

• Workspace and user accounts: business name, tax registration number (if provided), currency and time zone, and each user's name, email address, role, and hashed password, plus sign-in sessions and security logs.
• Contacts, companies, and leads: names, phone numbers, email addresses, company details, notes, and lead form answers, entered by users, imported from spreadsheets, or received from lead sources the business connects, such as Facebook and Instagram Lead Ads, Google Ads lead forms, and forms on the business's own website.
• Deals, tasks, activities, and quotes, including prices and line items, created by the business's users.
• WhatsApp conversations: when a business connects its WhatsApp Business account, messages sent and received through the WhatsApp Business Platform (Cloud API), sender phone numbers and profile names, and message templates. Attachments are fetched from Meta when a user opens them and are not stored by us.
• Remote support sessions: when a business uses SyntropyCRM to offer remote support, the session request, the reason given, the consents given, and a record of session events (who requested, allowed, connected, and ended the session, when, and from which IP address and browser).

18. Remote Support, Data Deletion, and Retention in SyntropyCRM

Remote support. A remote support session starts only after the person being helped ticks a consent box and allows access on a web page, and then presses "Share screen" in the Syntropy Support desktop app. The app shows who is asking and why before anything is shared, and the person can pause control or stop sharing at any time. Screen and control traffic travels directly between the two computers, or through an encrypted relay when needed. We do not record, store, or view the screen or the session content. We keep the session event record described above for security and accountability.

Facebook and Instagram data. If you remove our app from your Facebook account or ask Facebook to delete your data, Meta notifies us automatically. We then delete the Page access tokens you authorized and disconnect those Pages, and give you a confirmation code to check the status of the request. You can also email privacy@syntropyaiglobal.com to request deletion.

Erasing leads. Workspace owners can erase a lead at any time, which deletes its personal details, form answers, and the original data received from the lead source.

Retention. SyntropyCRM workspace data is kept while the business's subscription is active. After a workspace is closed and deletion is requested, we delete or de-identify its data within 90 days, except records we must keep for tax, legal, or security reasons, as described in Section 12.

Cookies. SyntropyCRM uses a strictly necessary sign-in session cookie. It does not use advertising or analytics cookies.

19. Custom Software Development Services

When we provide custom software development, integration, cloud, data, or support services, we may receive business contact details of the client's personnel and, where the project requires it, access to the client's systems or data. We use this information only to perform the services under our Statement of Work and the client's instructions, act as the client's service provider or processor for any personal information in the client's systems, and return or delete client data at the end of the engagement as agreed in the contract.

20. Data Location, Changes to This Policy, and Contact Us

Data location. The Services are offered to businesses in the United States, and information is stored and processed in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States.

Changes. We may update this Privacy Policy from time to time. We will post the updated policy on this page with a new "Last Updated" date and, for material changes, notify customer account owners by email or in the application before the change takes effect.

Contact. Syntropy AI Global Inc., 201 Saint Pauls Ave, Apt 1G, Jersey City, NJ 07306, United States. Privacy: privacy@syntropyaiglobal.com. Lottery Management: get@lotterymanagements.com, +1 201-552-3177, https://www.lotterymanagements.com. SyntropyCRM: support@syntropyaiglobal.com, https://www.syntropycrm.com.