1. Introduction

Daily Sweepstakes Manager LLC (“DSM,” “we,” “us,” or “our”), an Oregon limited liability company, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website at dailysweepstakesmanager.com and our sophisticated countdown timer management services (collectively, the “Service”).

Our website address is: https://dailysweepstakesmanager.com

Service Description: DSM provides advanced countdown timer management software as a service (SaaS), including premium features, multi-device synchronization, and comprehensive notification systems. We may occasionally include referral links to third-party services, but our primary business is providing timer management tools.

By using our Service, you consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Service.

1.1 Site Features and Interactions

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded Content from Other Websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

• Username and display name
• Email address
• Password (encrypted)
• Timezone and location preferences with automatic detection capabilities
• Profile customization settings and theme preferences
• Age verification status (21+ requirement)
• Demo account status and trial period information

Subscription and Payment Information:

• Payment method details (processed by Stripe)
• Billing address
• Subscription preferences
• Payment history and transaction records

User Preferences:

• Theme and display preferences with responsive design options
• Comprehensive notification settings including email and push notification preferences per device
• Advanced timer customization options including display formats, auto-restart settings, and custom durations
• Language and accessibility preferences with keyboard navigation and screen reader support
• Timer grid preferences including pagination, sorting, and search settings
• Favorites and timer collection management
• Multi-device synchronization preferences and UUID management

Communications:

• Messages sent to customer support
• Feedback and survey responses
• Newsletter and marketing preferences

Contact Form Submissions (DSM Compliance):

• Name, email, subject, and message body you submit
• IP address and browser user agent
• Submission timestamp
• Stored in a database table dedicated to contact submissions

Referral Tracking Information (if applicable):

• Click tracking data for occasional referral links
• Referral source information (minimal)
• Timer usage patterns and preferences

2.2 Information Collected Automatically

Usage Data:

• Pages visited and features used
• Time spent on the Service
• Click patterns and navigation paths
• Device and browser information
• IP address and approximate location
• Referral sources

Timer and Activity Data:

• Timer creation, completion, and restart records
• Personalized timer collections and favorites management
• Notification interaction history across multiple devices
• Login and session information with timezone detection
• Feature usage statistics including grid interactions, search queries, and preference changes
• Demo account usage and trial period activities

Push Notification Identifiers (Perfecty Push):

• Anonymous push subscription UUIDs associated to your device/browser when you enable push notifications
• Used solely to deliver notifications you opt into

Referral Tracking Data (if applicable):

• Clicks on occasional referral links
• Basic referral tracking (minimal)
• Third-party interactions (limited)

Technical Information:

• Browser type and version
• Operating system
• Device identifiers
• Screen resolution and device capabilities
• Network connection information

2.3 Information from Third Parties

Payment Processing:

• Transaction data from Stripe
• Payment verification information
• Fraud prevention data

Authentication Services:

• Information from Google OAuth (if used)
• Social media profile data (if connected)

Third-Party Services (minimal):

• Basic referral tracking data (where applicable)
• Service integration information
• User preference coordination

Analytics Services:

• Aggregated usage statistics
• Performance metrics
• Error reporting data

3. How We Use Your Information

3.1 Service Provision

• Create and manage your account with comprehensive preference management
• Provide advanced timer management with custom durations, auto-restart functionality, and personalized collections
• Deliver multi-device notification services including email and browser push notifications
• Process payments and manage subscriptions with smart billing and discount systems
• Customize your user experience with themes, accessibility options, and synchronized preferences
• Provide customer support through integrated contact systems
• Verify age eligibility for account creation (21+ requirement)
• Manage demo accounts and trial access to premium features
• Coordinate multi-device synchronization and preference management

3.1.1 Premium and Payment Operations (Stripe)

• We do not store full payment card numbers. Stripe processes payments on our behalf
• We store limited Stripe-related identifiers in our database to manage your subscription (see Section 4.2)

3.2 Referral Operations (minimal, if applicable)

• Track occasional referral link usage
• Improve timer service recommendations
• Analyze service effectiveness
• Enhance user experience

3.3 Communication

• Send service-related notifications including timer completions and deadline reminders
• Deliver requested newsletters and updates through email and browser push notifications
• Respond to your inquiries and support requests through integrated contact systems
• Notify you of important account changes including subscription updates and preference modifications
• Send marketing communications (with consent) with per-device preference management
• Provide information about relevant timer features and service updates
• Deliver demo account notifications and trial period updates
• Coordinate multi-device notification delivery based on user preferences

3.4 Service Improvement

• Analyze usage patterns and preferences
• Develop new features and functionality
• Improve Service performance and reliability
• Conduct user research and testing
• Generate anonymized analytics
• Optimize affiliate marketing strategies

3.5 Legal and Security

• Comply with legal obligations
• Protect against fraud and abuse
• Enforce our Terms of Service
• Resolve disputes and legal claims
• Maintain Service security and integrity
• Comply with FTC affiliate marketing disclosure requirements

4. Information Sharing and Disclosure

4.1 Internal Access

The site administrator (business owner) has access to the information you provide us, including:

• Order information like what was purchased, when it was purchased, and subscription details
• Customer information like your name, email address, and billing information
• Support communications and account history
• Usage data and preferences for troubleshooting purposes

This information is accessed only as needed to fulfill orders, process refunds, provide customer support, and maintain the service. All data is handled in accordance with this privacy policy and applicable data protection laws.

4.2 Third-Party Service Providers

We share information with trusted third parties who provide services on our behalf:

Payment Processing:

• Stripe, Inc. for payment processing
• Information shared: Payment details, billing information, transaction data, purchase total
• Purpose: Process subscriptions and payments, fraud prevention
• Data protection: Subject to Stripe’s privacy policy and PCI DSS compliance
• Additional note: When processing payments, some of your data will be passed to Stripe, including information required to process or support the payment. Please see the Stripe Privacy Policy for more details: https://stripe.com/privacy

Push Notifications:

• Perfecty Push (push notifications service) used to send notifications you opt into
• Information shared: Anonymous subscription endpoint data and UUIDs necessary to deliver notifications
• Purpose: Deliver opted-in push notifications about timers and updates
• Data protection: Uses the browser’s Web Push infrastructure; you can revoke permission in your browser at any time

Email Services:

• Email service providers for notifications
• Information shared: Email addresses, notification preferences
• Purpose: Deliver service notifications and marketing communications
• Data protection: Encrypted transmission and storage

Affiliate Partners and Networks:

• Third-party sweepstakes websites and affiliate networks
• Information shared: Referral tracking data, aggregated user statistics, commission attribution data
• Purpose: Track referrals, attribute commissions, comply with affiliate program requirements
• Data protection: Limited to necessary tracking data, no personal identification shared without consent

Analytics and Performance:

• Analytics service providers
• Information shared: Anonymized usage data, performance metrics
• Purpose: Service improvement and optimization
• Data protection: Data anonymization and aggregation

Customer Support:

• Support platform providers (if used)
• Information shared: Support communications, account information
• Purpose: Provide customer assistance
• Data protection: Secure data transmission and access controls

WordPress-Specific Services:

• Password reset emails: If you request a password reset, your IP address will be included in the reset email
• Spam detection services: Visitor comments may be checked through an automated spam detection service
• Gravatar service: Email hash for profile pictures (subject to Automattic’s privacy policy)

4.3 Affiliate Marketing Disclosures

Commission Tracking:

• We share referral and conversion data with affiliate partners to track commissions
• This may include anonymized user behavior data and aggregated statistics
• Personal identification information is not shared unless required for commission attribution
• All sharing complies with affiliate program terms and applicable privacy laws

Third-Party Cookies:

• Our affiliate partners may place cookies for tracking purposes
• These cookies help attribute referrals and track conversions
• You can control cookie settings through your browser
• Affiliate cookies are subject to third-party privacy policies

4.4 Legal Requirements

We may disclose your information when required by law or in response to:

• Valid legal process (subpoenas, court orders)
• Government investigations
• Regulatory compliance requirements
• Law enforcement requests
• Protection of rights and safety
• FTC compliance and disclosure requirements

4.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

4.6 Consent-Based Sharing

We may share information with your explicit consent for specific purposes not covered in this policy.

5. Data Security

5.1 Security Measures

We implement reasonable technical and organizational measures to protect your information:

Technical Safeguards:

• SSL/TLS encryption for data transmitted to and from our site
• Secure authentication and authorization within our platform
• Least-privilege access to production systems

Administrative Safeguards:

• Access controls for site administrators
• Incident response and breach notification procedures

Physical/Platform Safeguards:

• Hosting provider safeguards and regular backups

5.2 Data Breach Response

In the event of a data breach, we will:

• Immediately investigate and contain the breach
• Notify affected users within 72 hours
• Report to relevant authorities as required
• Implement remediation measures
• Provide ongoing updates and support

6. Your Rights and Choices

6.1 Access and Portability

You have the right to:

• Access your personal information
• Request a copy of your data in a portable format
• Review how your information is being used
• Verify the accuracy of your data

6.2 Correction and Updates

You may:

• Update your account information at any time
• Correct inaccurate or incomplete data
• Request assistance with data updates
• Modify your preferences and settings

6.3 Deletion and Retention

You have the right to:

• Request deletion of your personal information
• Close your account and remove associated data
• Understand our data retention practices
• Request specific data deletion (subject to legal requirements)

6.4 Marketing Communications

You may:

• Opt out of marketing emails at any time
• Modify your communication preferences
• Unsubscribe from newsletters and promotions
• Control notification settings

6.5 Data Export and Deletion Rights

For registered users: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

6.6 Exercising Your Rights

To exercise any of these rights, contact us at:

• Email: privacy@dailysweepstakesmanager.com
• Response time: Within 30 days of request
• Identity verification may be required
• No fee for reasonable requests

6.7 Additional Data Subject Rights

As a data subject, you have additional rights under applicable data protection laws:

Right of access: You can request access to a copy of the personal data which we hold about you, as well as details about why and how we use it.

Right to rectification: You can ask us to change or complete any personal data we hold about you which is inaccurate or incomplete.

Right to be forgotten/erasure: You have a right, under certain circumstances, to ask us to delete any personal data we hold about you. Please note that there may be situations where we must retain your personal data after a request for erasure where we have a lawful basis for doing so.

Right of restriction: You can ask us to restrict (i.e. prevent) the processing of your personal data where you have objected to our use of it and we have no lawful basis to continue processing your personal data.

Right of data portability: In certain circumstances, you can ask us to transfer the data we hold about you to another organisation. This would be sent in a structured, commonly used, electronic form.

Right to object: You can object to us using your personal data for a particular purpose.

Automated decision making: You have a right not to be subjected to automated decision making and profiling in certain situations.

7. Cookies and Tracking Technologies

7.1 Types of Cookies

We use the following types of cookies:

Essential Cookies:

• Required for Service functionality
• Authentication and security
• Cannot be disabled without affecting Service

Authentication and Preference Cookies:

• If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
• If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
• When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
• If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Preference Cookies:

• Remember your settings and preferences
• Customize your experience
• Can be disabled in browser settings

Analytics Cookies:

• Collect usage statistics
• Measure Service performance
• Help improve functionality
• Can be disabled through cookie preferences

Affiliate Tracking Cookies:

• Track clicks on affiliate links
• Attribute referrals and commissions
• Monitor conversion rates
• Required for affiliate program compliance
• Subject to third-party privacy policies

7.2 Cookie Management

You can control cookies through:

• Browser settings and preferences
• Our cookie preference center
• Third-party opt-out tools
• Privacy browser extensions

Note: Disabling affiliate tracking cookies may affect our ability to earn commissions from your referrals but will not impact your use of our core tracking tools.

7.3 Do Not Track

We respect Do Not Track signals for our own tracking. However, affiliate partner tracking may not respond to Do Not Track signals as these are controlled by third parties.

7.4 Service Cookies We Set

We set first-party cookies for the following purposes (typical expiration: up to 1 year unless otherwise noted):

• Session identifier for associating cookie consent with your visit
• Flags that remember your cookie preferences (essential, analytics, marketing)
• A timestamp of your most recent consent action

We also use standard authentication and display preference cookies as described above.

7.5 LocalStorage and Similar Technologies

We use browser storage (e.g., LocalStorage) to store non-sensitive preferences and performance caches, such as:

• Push Notification User ID (for delivering opted-in push notifications)
• Last Activity Timestamp (for idle reminder and UX features)
• User Timer Settings Cache and Available Timers Cache (to improve loading performance)
• Timer Sort Preference and Available Timers Sort Preference (to remember your choices)
• Client-side timer state keys (to improve resilience across reloads)

These values stay on your device and can be cleared via your browser settings.

8. Children’s Privacy

8.1 Age Restrictions

Our Service is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18, including specifically those aged 13-16 years. This age restriction is in place because:

• Legal requirements for payment processing services
• Compliance with data collection and privacy laws
• Protection of minors’ personal information and privacy rights
• Ensuring users can enter binding agreements

8.2 Age Verification

We implement age verification measures including:

• Account registration age confirmation
• Age verification pages for new users
• Automatic account restrictions for users indicating they are under 21
• Compliance with COPPA requirements

When age verification occurs, we store the following in your account profile:

• Age verification status (boolean)
• Age verification date/time (timestamp)
• Age verification IP address

8.3 Parental Rights

If you believe we have collected information from a child under 18, please contact us immediately. We will:

• Verify the child’s age
• Delete the information if confirmed
• Implement additional safeguards
• Notify parents as appropriate

9. Automated Decision Making

9.1 Automated Processing

We do not use your personal data in any automated processes to make decisions about you that would have legal or similarly significant effects.

9.2 Profiling

Any profiling we conduct is limited to:
• Service personalization and customization
• Analytics for service improvement
• Fraud prevention and security
• Marketing optimization (with appropriate consent)

You have the right to object to profiling and request human review of any automated decisions that affect you.

10. Technical and Operational Security

10.1 Security Infrastructure

All our data is password protected and its access controlled by two-factor authentication, backed up securely and encrypted where appropriate. All passwords are monitored by leading enterprise security technologies and in case of any breaches or cyber-attacks, we are notified immediately.

10.2 Data Protection Procedures

We follow all data protection best practices to ensure the safest handling of your information and are aware of our obligations to ensure the privacy of all data subjects.

10.3 Ongoing Security Monitoring

We implement continuous monitoring systems to detect and respond to security threats, unauthorized access attempts, and potential data breaches.

11. Business Transfers and Changes

11.1 Ownership Changes

We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of DSM. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, depending on the lawful basis, be permitted to use that data only for the same purposes for which it was originally collected by us.

11.2 Notification of Changes

In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. We will ensure that any acquiring party agrees to protect your personal data in accordance with this Privacy Policy.

12. International Data Transfers

12.1 Data Processing Locations

Your information may be processed in:

• United States (primary location)
• Other countries where our service providers operate
• Countries with adequate data protection laws

12.2 Transfer Safeguards

For international transfers, we implement:

• Standard contractual clauses
• Privacy shield frameworks (where applicable)
• Adequacy decisions by regulatory authorities
• Additional security measures as required

12.3 EU and UK Users

For users in the European Union and United Kingdom:

• We comply with GDPR requirements
• Legal basis for processing is provided
• Additional rights may apply
• Contact our Data Protection Officer: dpo@dailysweepstakesmanager.com

13. State-Specific Privacy Rights

13.1 California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

Right to Know:

• Categories of personal information collected
• Purposes for collecting information
• Third parties with whom information is shared
• Specific pieces of information collected

Right to Delete:

• Request deletion of personal information
• Exceptions for legal requirements
• Confirmation of deletion upon request

Right to Opt-Out:

• Opt out of sale of personal information
• We do not sell personal information

Non-Discrimination:

• No discrimination for exercising CCPA rights
• Same service quality regardless of privacy choices

13.2 Oregon Residents

Oregon residents may have additional rights under state privacy laws:

• Right to access personal information
• Right to correct inaccurate information
• Right to data portability
• Right to opt out of certain data processing

13.3 Other State Laws

We comply with applicable state privacy laws and will update this policy as new laws take effect.

14. Data Retention

14.1 Retention Periods

We retain your information for the following periods:

Account Information:

• Active accounts: Until account deletion
• Closed accounts: 30 days after closure
• Legal requirements: As required by law

Payment Information:

• Transaction records: 7 years for tax purposes
• Payment methods: Until removed by user
• Billing history: 3 years after last transaction

Affiliate Tracking Data:

• Click tracking: 24 months
• Commission data: 7 years for tax purposes
• Referral attribution: 12 months
• Aggregated analytics: Indefinitely (anonymized)

Usage Data:

• Analytics data: 24 months
• Log files: 12 months
• Support communications: 3 years

Account and Content Data:

• Comments: Comments and their metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
• User profiles: For users that register on our website, we store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). The site administrator can also see and edit that information.
• Media uploads: Images and other media files are retained until manually deleted by the user or administrator

Cookie Consent Records:

• We retain records of your cookie preferences (including a session identifier, IP address, user agent, consent flags, and consent date) in a dedicated database table for compliance and auditing

Contact Form Submissions:

• We retain your contact submission data (name, email, subject, message, IP, user agent, submission time) in a dedicated database table to provide support and maintain records

Premium Subscription Records (Stripe-related):

• We store limited subscription metadata in database tables dedicated to premium account management, such as:
– Subscription identifier, payment method reference, and premium access end date/time – Payment provider customer identifiers saved in user meta (e.g., customer ID, customer email, customer name) – Synchronization logs for troubleshooting (no full card numbers are stored)

14.2 Deletion Process

When retention periods expire, we:

• Securely delete personal information
• Anonymize data where possible
• Maintain anonymized analytics
• Provide deletion confirmation upon request
• Notify affiliate partners of data deletion where required

15. Changes to This Privacy Policy

15.1 Policy Updates

We may update this Privacy Policy to reflect:

• Changes in our data practices
• New legal requirements
• Service improvements
• User feedback

15.2 Notification of Changes

We will notify you of material changes by:

• Email notification to registered users
• Prominent notice on our website
• In-app notifications
• Updated effective date

15.3 Continued Use

Continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

16. Contact Information

16.1 Privacy Questions

For questions about this Privacy Policy or our data practices:

Email: privacy@dailysweepstakesmanager.com Subject Line: Privacy Policy Inquiry Response Time: Within 5 business days

16.2 Data Protection Officer

For GDPR-related inquiries:

Email: dpo@dailysweepstakesmanager.com Subject Line: GDPR Inquiry Response Time: Within 30 days

16.3 Business Address

Daily Sweepstakes Manager LLC [Your Oregon LLC Registered Address] [City, State ZIP Code] Oregon LLC Registration: [Your Oregon LLC Number]

16.4 Regulatory Complaints

You have the right to file complaints with:

• Oregon Attorney General’s Office
• Federal Trade Commission
• Your local data protection authority (for EU residents)

17. Effective Date and Acknowledgment

This Privacy Policy is effective as of 2025-08-12 and applies to all users of the Daily Sweepstakes Manager service.

By using our Service, you acknowledge that you have read, understood, and agree to this Privacy Policy and our data practices.

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This Privacy Policy was last updated on 2025-08-12. We encourage you to review this policy periodically for any changes.