www.instantadvantageapp.com is owned and operated by RCteca Holdings, LLC having its principal office at 262 N. Cassingham Rd, Columbus, OH 43209, USA (“RCteca”). RCteca is committed to ensuring the confidentiality and privacy of our Subscriber’s personal information.

This Data Protection and Privacy Policy below describes the principles and practices that apply to the Personal Information (defined below) that we collect and hold from individuals online or offline (visitor or you), such as individuals who browse through our Site (defined below), register on the Site, use the online services provided on the Site, interact with the Site, communicate with us through telephone, email, text or other means, participate in our interviews, surveys or promotions, or read or receive our newsletters.

We made good efforts to make it sure that we meet the requirements applicable Data Protection Laws, to the best of our knowledge to protect the security of your Personal Information. We will only use and disclose your personal information for the primary purposes of our business when you have given express consent to do so. We do not disclose your personal information to any third party. We do not exchange any data out of EU, GDPR is not applicable.

DEFINITIONS

DATA WE COLLECT OR RECEIVE

Our Services consist collection of data from State lottery Agencies websites, computation of such data, and display the new data for Users of our Services. Where we source the data directly from the relevant platforms, we determine the purpose of processing, which is developing and constantly enhancing our Services and offering them to our customers on a world-wide basis, via our Services.

CONSENT

By using the Services and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy and agree that we may collect, use, disclose, store, transmit, or process such Personal Information in accordance with this Privacy Policy or as required by law.

By providing your Personal Information to us, you acknowledge and agree that:

• You are responsible for providing accurate and complete information when completing an assessment;
• You agree to use and access the website in a manner that will not disrupt, corrupt, or otherwise damage theSite or the App; and
• Accordingly, theServices shall not be used in a manner that is prohibited by law. Use of the Services is subject to your compliance with all applicable laws and regulations in your location.

If you register or create an account – If you register or create an account on the Services, we require that you fill out a form to register with us. We collect your name, contact information, email address, location, and other information, and may ask you for other optional information that helps us serve you better.

If you subscribe for Services – If you subscribe for Service, we collect your contact information as necessary to fulfill the Services (such as name, address, email address or telephone number) and optional information if you provide it.

If you pay for an online Services – When you subscribe an online Service, we do not collect payment information ourselves. Instead, you are redirected to our payment processor’s website, which collects directly your payment information. RCtecaonly receives a notice of the receipt of the payment, a confirmation number (for verification purposes), the name and contact information of the recipient of the Service, and the name and contact information of the cardholder if different from the name of the person receiving the Services.

SOCIAL NETWORK USER DATA

The type and scope of personal data obtained from social media platforms depends on the type of the APIs and permissions set out by the respective platforms, and on the administrative permissions granted to us by our customers, where applicable.

Below are the most typical examples of data collected about social media platform users:

• Basic user profile information (such as the username);
• User generated content (such as posts, comments, pages, profiles, images or feeds) including its metadata (such as time and location of a post or comment);
• Contact details (such as name, email address, telephone number) if made public by the user; and
• Additional individual information (such as age, gender, employer, profession, geographic location, education information, financial status, habits and preferences) published by the user.

We only process data that the social network users made available to general public, pursuant to the relevant platforms’ terms, and that are generally accessible via the social network APIs, or data that our customers grant us permission to access.

If you participate in a survey – If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address (to avoid duplicate responses), as well as any other Personal Information that you may provide in your survey responses.

If you sign up to receive an Instant Advantage  newsletter– If you sign up to receive anInstant Advantage  newsletter, we may collect information on the open rate of the newsletter, and whether a specific individual has clicked on a link contained in a particular issue of our newsletter.

If you participate in our blogs or forums or if you write to us – We may collect the Personal Information that you provide in your correspondence and communications with us, or through your participation in surveys, blogs and forums.

If you interact with third parties regarding our products or services – We may receive Personal Information about you from third parties, such as from, websites where we advertise, business partners and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.

HOW WE USE PERSONAL INFORMATION

We use Personal Information in order to provide and enhance the Servicesthat we offer, as explained below:

To facilitate the use of the Services – We may use the Session Data to ease navigation through the Services , to enhance navigation (such as to determine the language of the country where the visitor is located), keep track of the shopping cart or keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general, to enhance the quality of our Site and the content provided on the Site.

HOW WE RETAIN PERSONAL INFORMATION

To provide our Services – The Personal Information collected from subscriber order forms is used to send to our records department. The limited payment information that we receive from our payment processors is used to verify that a Service has been paid for. We recommend that you read the privacy policies and statements that are posted on the relevant third parties' websites to understand their procedures for collecting, using, storing and disclosing Personal Information.

For research purposes – We may use aggregated session data to better understand how our Site is navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Site, the different types of searches of our Site content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Site, in order to improve our Site and enhance our content.

We may use IP addresses to collect information – This information is not associated with any individual and is therefore anonymous. The IP addresses are then disposed of in accordance with our record retention policy.

For maintenance purposes – We may use IP addresses and session data to diagnose problems with our server and to administer our Site.

For marketing purposes – Once we have obtained your explicit consent we may use email addresses or other contact information to send mailings, newsletters. We may use your telephone number to contact you for marketing purposes. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send.

For survey analysis – The information that we collect through our surveys (including surveys administered by our related companies) is not used other than to garner survey results and statistical analysis.

TO WHOM WE DISCLOSE PERSONAL INFORMATION

From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

Service providers – We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, , order fulfillment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, direct marketing campaigns and survey administration.

To defend or enforce our rights – We may use Personal Information to protect itself or to protect the Site, to respond to a breach of its terms and conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies.

Related companies – We may disclose any Personal Information we collect to our related companies or may store or process Personal Information using systems which are shared with our related companies.

Merger, acquisition or bankruptcy – If any or all of the RCtecaassets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users’ Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.

Law enforcement and litigation – Certain local, overseas or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information:

• If we believe in good faith that a law, regulation, rule or guideline requires it;
• To a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person; or
• In other circumstances where we are permitted to do so by law.

Aggregated data – Other than as stated above, if we use your Personal Information, it will be in the form of aggregated data and used for product development, research or statistical analysis. Aggregated data is created from records that are stripped of all personal identifiers, such as a combination of thousands of answers to survey questions and instrument responses.

Affiliates: We may share data with its following affiliates:

• Stripe payment platform;
• Bluehost/Wordpress website hosting platform; and
• AWS data storage platform.

COOKIES AND OTHER TRACKING TECHNOLOGIES

A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected or identified by configuring your browser’s preferences. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We do not tie the information gathered by clear gifs to Personal Information. You can learn more about cookies by visiting www.allaboutcookies.org.

Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual visitor is. Our third party advertising partners may employ pixel tags that help us better manage content on our Site by informing us what content is effective.

HOW LONG WE RETAIN PERSONAL INFORMATION

We retain your responses and the related Report associated with the user ID or transaction number that our Customers provided us in accordance with our internal record retention policy and for at least five (5) years from the date when a Subscriber terminate his/her Subscription. Thereafter, we retain the Subscribers records in an anonymized format for as long as the information is needed for our research, statistical analysis or product development.

HOW WE PROTECT PERSONAL INFORMATION

Security – We will not transfer your personal information, to any other company. We use administrative, physical, and technical measures designed to protect it from unauthorized access, loss, misuse, disclosure, alteration or destruction.

Encryption - Any data collected by us for the purposes of assessments and to provide its Services is protected by encryption. This means we keep data in an unreadable state unless a user or process presents the appropriate key., this simple control method restricts data processing only for authorized use and restricts the amount of time that you are identifiable by your data. Our data is encrypted at rest and in transit. Encryption prevents unauthorized data manipulation; limits data access to authorized users and monitors key usage to ensure that the data cannot be changed without authorization. Our use of encryption together with our access controls provides users to have confidence in their data’s integrity.

Transit – When we need to transfer information out of our firewall, we use encryption methods to protect your data while in transit through the internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. Therefore, while we use the highest standards commercially available to protect your personal information, no method of transmission over the internet or method can ever guarantee its absolute security.

Identity theft – Identity theft and the practice currently known as 'phishing' are of great concern to us.

Please understand that you also have a responsibility in protecting your information. The only time when our associate may contact you (via electronic communication, postal mail, telephone, etc.) about your credit card or payment information is in connection with a transaction that you have initiated. Otherwise, no one from RCtecais permitted to contact anyone to request your credit card information, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.

DATA ACCURACY

We will exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the Contact Us section (below).

YOUR RIGHTS

Right of access, modification – In general, you have the right to access your Personal Information and to correct or update the Personal Information that you have provided to us. If you wish to do so, please contact us with proof of identity, as provided in the Contact Us section (below). You can expect a response to your request within seven business days.

If you are Subscriber to the Service and you wish to have access to a copy of your responses to an Assessment or a copy of the Assessment Report that we from the evaluation of your responses, please contact the Test Supervisor who is managing your specific Assessment.

Right to be forgotten – If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us with proof of identity, as provided in the Contact Us section (below). We will accommodate your request to the extent practicable and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Right to opt-out of the use of your Personal Information – You may unsubscribe from receiving a newsletter by contacting us as set out in the Contact Us section (below) or clicking on the unsubscribe link provided in the newsletter.

If you wish to opt-out of direct marketing communications, you can always do so by contacting us as set out in the Contact Us section (below). In some cases, we may not be able to remove your Personal Information, in which case we will let you know this and explain why.

Right to Block Cookies – You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Services.

COMPLAINTS AND DISPUTES

If you have questions or complaints regarding our privacy policy or practices, you should first contact us as indicated in the Contact Us section (below). We will respond to you within a reasonable period of time and will attempt to resolve all complaints promptly.

If we are unable to satisfactorily resolve your concerns about the privacy or handling of your Personal Information, you can contact to submit a complaint concerning our data processing activities to the Federal Trade Commission (FTC) or your state’s attorney general in the United States.

CHANGES TO THIS PRIVACY POLICY

From time to time we will revise and change this Privacy Policy. If we make material changes, we will place a prominent notice on the Site or will send you a notice to the email address that you provided to us.

CONTACT US

If you have any questions or complaints about (i) this Privacy Policy, (ii) the collection, use, management, or disclosure of your Personal Information, or (iii) accessing or modifying your Personal Information please contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.