The World's First Green Draw

O! Millionaire's DATA PRIVACY AND COOKIE POLICY

Definitions:

“EU” shall mean the European Union.

“GDPR” shall mean the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016) on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, as amended and supplemented from time to time.

“EU Data Act” shall mean Regulation (EU) 2023/2854 of the European Parliament and of the Council of December 13, 2023, on harmonised rules for fair access to and use of data, effective from September 12, 2025.

“Applicable Data Protection Laws” shall mean the GDPR, the EU Data Act, the ePrivacy rules, and any other EU or Member State legislation governing the protection of personal data, cybersecurity, or electronic communications, as each may be amended, replaced, or supplemented from time to time.

The entity responsible for your Personal Data is GreenBloom Global Limitada.

O! Millionaire is a brand of GreenBloom Global Limitada, which is a Limited Liability Company incorporated in Barrio Dent, Costa Rica, whose principal place of business is located at Office number 3, Ofident Bldg, San Jose Montes De Oca, Barrio Dent, Costa Rica

O! Millionaire takes data protection and privacy responsibilities seriously. This Data Privacy and Cookie Policy ("Privacy Policy") describes how O! Millionaire collects, processes, uses, discloses, and transfers Personal Data as a "data controller". A "data controller" is an entity that determines why and how it processes Personal Data it possesses. This Privacy Policy covers instances when contacting us, buying an entry and Green Certificate, choosing numbers for the Draw and the Raffle, or interacting with our website www.omillionaire.com or the O! Millionaire apps to be found in the Apple App Store, Google Play, or Huawei AppGallery.

1. TERMS OF USE

1.1 Use of the O! Millionaire Websites is subject to this DATA PRIVACY AND COOKIE POLICY ("Policy"). Please ensure to read them carefully and understand them. In jurisdictions where any consent to this Policy is required, you hereby consent to it and agree to be bound by this Policy and Terms.

1.2 Policy Applicability

The Data Privacy and Cookie Policy applies to Virtual and website visitors, O! Millionaire mobile app users, and third parties. Please refer to section 5 in this Policy to understand what Personal Data is and how and why O! Millionaire uses your data.

2. DATA ACCURACY

The accuracy of your data is important to us. You are required to provide us with correct and accurate information.

3. UPDATES

3.1 O! Millionaire will make necessary changes to this privacy policy at its sole discretion, wherever or whenever required, without any notice. However, we recommend that you review this Policy periodically to check for any updates.

4. THIRD PARTY WEBSITES

4.1 We may, from time to time, partner with advertising networks, social media agencies, digital services, and other online advertising providers to deliver advertisements on our behalf across the Internet. These preferences may be inferred based on information collected about your browsing behavior on our websites and other non-afﬁliated sites and apps across time.

5. WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT

5.1. Personal Data in this Privacy Policy means any information relating to an identified or identifiable natural person (a 'data subject'). An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier. O! Millionaire may collect such information as name, birthday, credit card number, mobile phone number, or email address.

5.2 When and why is Personal Data collected?

We collect personal data only when it is necessary to provide our services, improve user experience, or comply with legal requirements. This may occur when you register, make a purchase, or interact with our platform.

5.3. Purchasing an entry and a Green Certificate

5.3.1. When you use the O! Millionaire Website to purchase an entry and the Green Certificate, we will collect and use information about you as necessary to manage the purchase. This may include Personal Data such as your name, date of birth, gender, nationality, country of residence, contact information (such as mobile phone number and email address), as well as information collected about your navigation patterns on our websites. We may also seek to collect special categories of information from you to enhance your purchase and user experience.

5.4. Customer Support and Online Services

5.4.1. If you contact us by way of email or any other facility made available by O! Millionaire with a query or comment about any of our products or would like us to keep you informed about the latest news and developments at O! Millionaire through newsletter or other means (for example, direct marketing), we will need to collect information about you (including your contact details) to help us respond to your query or request or provide our services to you. We may do this when you call our Customer Support Centre or interact with us through our online support tools. This information may include identification data (such as your name, date of birth, gender, nationality, etc.), contact details (such as email address and mobile phone number), and other information.

5.4.2. We may also keep a record of any communications we have with you (including a recording of any calls you make). We do this to help monitor and improve the quality of our customer support services, to make and defend legal claims, and to comply with legal obligations to which we are subject.

5.5. Creating Registered Accounts on O! Millionaire Website

5.5.1. There are several sections of the O! Millionaire Website that we require you to register for to be able to make full use of the services available under them.

5.5.1.1. If you register with us to create an O! Millionaire Website account, we may process your Personal Data to:

manage your access to O! Millionaire Website allowing you to make purchases of one or more entries and Green Certificates (and other merchandise as offered in www.omillionaire.shop);
send you newsletters and marketing and promotional materials (including via social media, based on the contact details you provide us), subject to your marketing preferences.

5.5.1.2. If you register with us to create an O! Millionaire Website account, the Personal Data we will collect from you may include identification data (such as your name, age, gender, and country of residence), contact details (such as your email address and mobile phone number), your preferences (which we can ascertain from the way in which you have navigated the O! Millionaire Website).

5.5.1.3. If you create an account with us, we may use your Personal Data to verify your identity when using the O! Millionaire Website or Apps. We may also use your contact details to send you marketing as well as non-marketing messages pertaining to your account.

5.6. Application users

5.6.1. If you use the O! Millionaire application, we may collect information about you as necessary to enhance your user experience as part of fulfillment. This information may include your name, date of birth, country of residence, gender, nationality, contact details (such as email address and mobile phone number), geolocation data, unique identifier (such as device or person), and third-party data about you, for example, your X (Twitter), Facebook, Instagram, TikTok, YouTube or other social media profiles.

5.6.2. Tracking and Automatic Collection

5.6.2.1. O! Millionaire and third parties that provide content, advertising, or other functionality on our services may use Cookies, pixel tags, local storage, and other technologies to collect information through the services automatically. These are collected for the purposes of:

5.6.2.1.1. developing the design and style of our products and services to make improvements.

5.6.2.1.2. Carrying out statistical, technical, and logistical analysis and strategic development.

5.6.2.1.3. Carrying out market research.

5.6.2.1.4. Understanding more about you such as your location and demographic information; and

5.6.2.1.5. Providing you with personalized services, such as recommendations on our websites, and apps, and in direct marketing and tailored advertising.

5.6.2.1.6. O! Millionaire Website collects information about how you use our content online, and the device(s) you use to access the site. This includes collecting unique online identiﬁers such as IP addresses, which are numbers that can uniquely identify a speciﬁc computer or other network devices on the Internet.

6. LAWFUL BASES FOR USING YOUR DATA

6.1. We will only collect, use, and share your Personal Data where we have an appropriate lawful basis to do so. Depending on where you are, appropriate legal bases may include:

6.1.1. where we need to use your Personal Data to perform a contract or take steps to enter into a contract with you.

6.1.2. our legitimate interests as an organization, for example, we may use user contact information to keep our users informed about changes to O! Millionaire and other relevant service messages.

6.1.3. where we need to use your Personal Data to comply with a relevant legal or regulatory obligation that we have; and

6.1.4. where we have your consent to use your Personal Data for a particular activity. If you are a data subject in our operating areas, this will always be the legal basis upon which your Personal Data will be processed.

7. HOW WE SHARE INFORMATION WITH OTHERS

7.1. We work closely with several trusted partners with whom we may need to share your Personal Data to help us provide our services, such as:

7.1.1. banks and payment providers, to authorize and complete payments.

7.1.2. third parties who help manage our business and deliver services. For example, these may include IT service providers who help manage our IT and back-office systems.

7.1.3. We may share your Personal Data with our partners who may send you marketing and promotional information.

7.1.4. From time to time we may share information about you with government organizations and agencies, including international organizations, to comply with applicable laws, regulations, and rules, and legitimate requests from law enforcement, regulatory, and other government or international agencies, or when to do so is in our legitimate interests, even if we are not compelled to share that information by applicable law.

7.2. If, in the future, we may sell or transfer some or all of our business or assets to a third party, we may disclose or transfer information to a potential or actual third-party purchaser of our business or assets.

8. MORE ABOUT DIRECT MARKETING, PROFILING AND AUTOMATED DECISION MAKING

8.1. Direct marketing

8.1.1. We are committed to keeping you informed about O! Millionaire and our products and services in line with your personal preferences.

8.1.2. We will usually send this by email, SMS (text messaging), or WhatsApp, but we may choose to contact you in other ways for example by phone, post, and/or other electronic means if that is more appropriate.

8.2. Managing Your Marketing Preferences

8.2.1. To protect privacy rights and to ensure you have control over how we manage marketing with you:

8.2.1.1. we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications that we believe may be of interest or relevance to you.

8.2.1.2. to stop receiving marketing material from us, you can click the "unsubscribe" link that you will find on any electronic communications that you receive from us, or, for other types of communications, by contacting us; and

8.2.1.3. you can change the way your browser or device manages Cookies, which may be used to deliver online advertising, by following the settings on your browser as explained in the "Cookies" section (section 11) below.

8.2.2. We recommend you routinely review the privacy policies and preference settings that are available to you on any social media platforms.

8.3. More about profiling and analytics

8.3.1. We use some of the information you provide to us to perform profiling and analytics with the data.

8.3.2. One of the methods by which we do this is by installing and using Cookies on your browser or device. You can learn more about adjusting settings related to Cookies on your browser and device, as well as our Cookie Policy, in the "Cookies" section (Section 11) below.

8.3.3. Some of the legitimate purposes according to which we profile and analyze data include:

8.3.3.1. to allow us to enhance our provision of services to you.

8.3.3.2. to provide you with tailored content online and optimize your experience of our website.

8.3.3.3. to obtain a better understanding of our users, what you would like to see from us, and how we can improve our services for you.

8.3.3.4. to share advertising material, we believe may be of interest to you and

8.3.3.5. to help us operate our website more efficiently.

8.3.4. If you are using O! Millionaire Website from a location in the EU or a country with similar data protection laws, we will only profile your Personal Data on the basis of our legitimate interests if this does not override your own interests or fundamental rights and freedoms.

9. CROSS BORDER TRANSFERS

9.1. We operate our organization from multiple locations, where we have offices, remote working employees, and agencies.

9.2. In performing our operations, we may need to transfer data, including your Personal Data, to the European Union ("EU") and Mauritius, in the event it leaves the EU and/or Mauritius. Our third-party service providers may also need to transfer your Personal Data to third countries outside the EU and/or Mauritius to perform their services.

9.3. We will take appropriate steps to ensure that transfers of Personal Data are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. If your Personal Data is being transferred outside the EU and/or Mauritius, then transfers will be limited to countries recognized as providing an adequate level of legal protection, as assessed by the European Commission, or where we can be satisfied that alternative data protection arrangements are in place to protect your privacy rights. To this end, if required by law, when we transfer your Personal Data to third parties who assist in providing our products and services, we obtain contractual commitments from them to protect your Personal Data.

9.4. You have a right to contact us for more information about the safeguards we have put in place (including, for EU data subjects, the right to receive a copy of relevant contractual commitments we have put in place, which might be redacted) to ensure the adequate protection of your Personal Data when this is transferred as mentioned above. See also the section titled "Your Rights" (section 12), below.

10. HOW WE PROTECT AND STORE YOUR INFORMATION

10.1 . ow we protect your information

10.1.1. O! Millionaire invests in an appropriate and reasonable level of cyber security measures and practices to keep your Personal Data secure and confidential, including but not limited to:

10.1.1.1. Restriction of access to your Personal Data, including through password protection and, in some cases, encryption, and ensuring that Personal Data is used only on a strictly need-to-know basis, such as responding to an inquiry or service requests.

10.1.1.2. Implementation of physical, electronic, administrative, technical, and procedural safeguards to protect your Personal Data from unauthorized or inappropriate access, alteration, disclosure, and/or destruction.

10.1.2. Where you disclose information to us using our mobile App, please ensure that your device remains safe. We cannot be held responsible for any data misuse arising from unauthorized access to your device.

10.2. Storing Your Personal Data

10.2.1. We will store your Personal Data for as long as reasonably necessary for the purposes for which it was collected, as explained in this Privacy Policy.

10.2.2. In some circumstances, we may need to store your Personal Data for longer periods of time, for instance, where we are required to do so in accordance with legal, reporting, regulatory, tax, accounting, or anti-money laundering requirements. Should you require information about how we retain information, you can contact us.

10.2.3. In specific circumstances we may store your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

10.2.4. To determine the appropriate retention period for Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we process the Personal Data and whether we can achieve those purposes through other means.

11. COOKIES

11.1. Our Policy on "Cookies"

11.1.1. A cookie is an element of data that a website sends to your browser, which then stores it on your system. Cookies may collect Personal Data about you. Cookies enable us to understand which pages and advertisements have been viewed, determine the frequency of page visits, and identify the most popular areas of our website. Cookies also allow us to make the O! Millionaire Website more user-friendly by, for example, allowing us to direct you to the language site you last used, so that we can provide a better experience when you return to our website.

11.1.2. Cookies will be deployed on your device when you visit O! Millionaire Websites unless you indicate that you do not wish this to happen or if you have turned this feature 'off' in your web browser or device settings.

11.1.3. Only the issuer of the cookie concerned may read or modify the information contained therein.

11.1.4. Most Cookies won't collect information that identifies you. Instead, they will collect more general information, such as your general location or how you arrive at and use our website.

11.2. Cookies deposited by a third party on the O! Millionaire Website

11.2.1. Our websites may contain Cookies issued by third parties (e.g., communication agencies, audience measurement companies, targeted advertising provider, etc.) allowing them, during the validity period of their Cookies:

11.2.1.1. to collect browsing information about browsers browsing our websites; and

11.2.1.2. to determine the advertising content that may correspond to your interests; and

11.2.1.3. to send you targeted advertising, in view of your browsing history collected by the third party.

11.2.2. At any time, you can prevent the collection of information about you via these third-party Cookies by clicking on the corresponding links (see section 11.3 below).

11.2.3. The issue and use of Cookies by a third-party company is subject to the respective company's own terms of use.

11.3. Your management and use of Cookies

11.3.1. Enabling our website to function properly: Some cookies are essential for the operation of our websites, e.g., we use Cookies to ensure that you are shown the correct webpages for your location or to identify when we have broken links or other technical issues with the website.

11.3.2. Analyzing user behavior: We use Cookies to analyze how our visitors use our websites and to monitor website performance. This enables us to deliver a high-quality experience by ensuring that our content and layout remain relevant to you.

11.3.3. Optimizing and personalizing: Cookies are also used to optimize the web pages that you visit, and to personalize the content that we show you across all our digital assets, based on what we understand about your requirements

11.3.4. Managing your Cookies: You can control whether to accept Cookies or not. If you decide not to accept Cookies, some features and services on our websites may not function properly. If you would prefer not to accept the Cookies, you can either set your browser not to accept any Cookies and/or manage and modify your use of Cookies.

12. USE OF ARTIFICIAL INTELLIGENCE

12.1. Our Policy on “AI Usage”

12.1.1. We may use Artificial Intelligence (“AI”) tools and systems to process certain personal or anonymized data. AI helps us improve our services, personalize user experiences, detect fraudulent activity, and optimize marketing communications.

12.1.2. Data processed through AI is handled in compliance with applicable privacy laws, and only to the extent necessary for analysis, service improvements, or communication purposes.

12.1.3. AI-driven processing may include automated decision-making or profiling; however, these processes are regularly monitored to ensure fairness, accuracy, and transparency.

12.1.4. Personal data is never sold or shared with third-party AI systems without proper safeguards and, where required, user consent.

13. YOUR RIGHTS - LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY

13.1. You may have certain rights relating to your Personal Data depending on the country in which you access the O! Millionaire website. In some cases, depending on applicable legislation, such as GDPR, these rights may include: To be informed – this right allows you to receive information from us about what Personal Data we collect and what we do with it. The purpose of this Policy is to fulfill this right.

13.1.1. to access your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

13.1.2. to erase your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Please note that for certain purposes, we may be legally obligated to retain your data (see section 10.2).

13.1.3. to restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data under the following circumstances:

13.1.3.1. if you want us to establish the data's accuracy.

13.1.3.2. where our use of the data is unlawful.

13.1.3.3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or

13.1.3.4. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

13.1.4. to transfer your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

13.1.5. to object to the processing of Personal Data, including how we use it for direct marketing purposes, provided you can justify your objection on the basis that your fundamental rights and freedoms override our legitimate interests or those of a third party. At the same time, you acknowledge that we (or a third party) may demonstrate that we (or they) have compelling legitimate grounds to process your information, which may override your rights and freedoms.

13.1.6. to obtain a copy of safeguards used when we transfer your Personal Data outside the jurisdiction in which the Personal Data was captured (as per paragraph 9.4).

13.1.7. to complain with your local data supervisory authority.

13.2. Please note that the rights referred to in paragraph 12.1 are not absolute and may be subject to our own rights with respect to the Personal Data.

13.3. You may raise your concerns with your local data protection authority directly. However, we encourage you to contact us initially, as we aim to promptly resolve any concerns or complaints you may have regarding our processing of your Personal Data.

13.4. You can exercise your rights by contacting us as set out in Section 13.3. Subject to legal and permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information to fulfill it. This may include asking you to confirm your identity or provide other information for security purposes before disclosing Personal Data to you. We may not always be able to fully address your request, for example, if it would compromise our duty of confidentiality to others or if we are legally entitled to treat your request differently. We reserve the right to refuse your request if it is manifestly unfounded or excessive.

13.5. You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your Personal Data when this is transferred as mentioned above.

14. CONTACT US

14.1. If you have any questions, concerns, or complaints regarding our compliance with this Privacy Policy and the data protection regulations, or if you wish to exercise your rights, please get in touch with us. We will investigate and attempt to resolve complaints and disputes, and make every reasonable effort to honor your wish to exercise your rights as quickly as possible, in any event, within the timescales provided by applicable data protection laws.

14.2. In some countries, you may have a right to complain with your local data protection supervisory authority. We ask that you please attempt to resolve any issues with us before referring us to your local supervisory authority.

14.3. If you have any questions or comments regarding the processing of your personal information and O! Millionaire's privacy practices or if you would like us to update the information or preferences you provided to us, you can contact us via email at [email protected].