AppSorteos · Raffles

Raffle Privacy Policy

Last updated: September 29, 2026

This Raffle Privacy Policy explains what personal data is processed when the AppSorteos "Raffles" feature is used, who is responsible for each processing activity, the purposes for which that data is used, and the rights of the individuals to whom it relates.

This policy supplements the AppSorteos general Privacy Policy. In the event of any conflict, this Raffle Privacy Policy shall prevail with respect to all matters relating to the Raffles feature. Capitalized terms have the meanings assigned to them in the Raffle Terms and Conditions.

1. Who We Are

The Raffles feature is provided by AppSorteos LLC ("AppSorteos," "we," or "us"), a company organized under the laws of the State of Delaware, United States of America, which operates the website https://app-sorteos.com. You may contact us at [email protected].

2. Who Is Responsible for the Data

The Raffles feature involves two types of processing, each with a different controller:

Organizers' data: AppSorteos is the controller of the Organizer's account data and of the technical data relating to use of the platform, in accordance with this policy and the general Privacy Policy.
Buyers' data: the Organizer of each Raffle is the controller of the data that Buyers enter in the registration form. AppSorteos acts as a processor: it hosts and processes that data on the Organizer's behalf, following the Organizer's instructions and solely in order to provide the service.

The Organizer is responsible for Buyers' data

When you purchase a number, you provide your data to the Organizer of that Raffle. It is the Organizer who decides what data to request, what to use it for, and how long to retain it. AppSorteos only provides the tool that allows the data to be collected and managed, and does not use it for its own commercial purposes.

3. Data Processed

3.1 Organizer Data

account data: name, email address, and login credentials;
Raffle data: title, description, images, prizes, price, quantity of numbers, draw date, and draw mode;
data regarding the payment method that the Organizer chooses to display or configure (for example, an alias, a payment link, or an account identifier);
record of acceptance of the Declaration of Responsibility: date, time, IP address, and associated technical data;
communications with the support team.

3.2 Buyer Data

first and last name;
email address;
phone number;
numbers purchased, purchase date, reported payment status, and, where applicable, the draw result.

3.3 Custom Fields

The Organizer may add additional fields to the registration form. The data collected through such fields is the sole decision and responsibility of the Organizer, who must limit itself to requesting information necessary for the Raffle. These fields may not be used to request sensitive data (for example, data concerning health, ethnic origin, beliefs, or sexual orientation), passwords, card data, or complete identity document numbers, unless applicable law expressly requires it for the Raffle.

3.4 Technical Data

When anyone visits a Raffle page or uses the tool, data such as IP address, browser and device type, language, pages visited, date and time of access, and usage events may be recorded automatically for purposes of operation, security, fraud prevention, and statistics.

4. How the Data Is Used

AppSorteos processes data for the following purposes:

Providing the service: creating and displaying Raffles, registering Buyers, assigning numbers, conducting the automatic draw, and publishing its results. Legal basis: performance of the contract with the Organizer and, for Buyers' data, the Organizer's instructions.
Sending service communications: purchase confirmations, notices about the draw or its result, and operational messages. Legal basis: performance of the service.
Security and fraud prevention: detecting abusive use, investigating reports, and protecting Users and the platform. Legal basis: the legitimate interest of AppSorteos and of Users.
Legal compliance: responding to requests from authorities, keeping records, and exercising or defending rights, including the record of the Declaration of Responsibility. Legal basis: legal obligation and legitimate interest.
Product improvement: compiling aggregated or anonymized statistics on use of the tool. Legal basis: legitimate interest.

AppSorteos does not use Buyers' data to send them its own advertising or to create commercial profiles, and does not sell it to third parties.

The Organizer, as controller, defines its own purposes with respect to Buyers' data (for example, contacting the winner or processing refunds) and must disclose those purposes and have a sufficient legal basis for them.

5. Access and Export by the Organizer

From "My Raffles," the Organizer can view the data of the Buyers in its Raffles and export it, for example as a CSV file. This data includes the information from the registration form and the custom fields.

AppSorteos does not control data once it is exported

When the Organizer downloads or copies Buyers' data, that data leaves AppSorteos' systems. From that point on, its custody, security, use, and deletion are the sole responsibility of the Organizer, and AppSorteos is not liable for its loss, leakage, or misuse.

The Organizer agrees to:

use Buyers' data solely to manage the Raffle and fulfill its obligations to them;
not sell or transfer the data, or use it to send advertising, without the Buyer's consent or another valid legal basis;
inform Buyers about the processing of their data and respond to their requests for access, rectification, erasure, or objection;
implement appropriate security measures and delete the data when it is no longer necessary;
comply with the data protection laws applicable to it in its own country and in the Buyers' countries.

6. Payments and Financial Data

Buyers pay for their numbers directly to the Organizer, through the payment method chosen by the Organizer (for example, Mercado Pago, PayPal, Wise, PIX, or bank transfer). AppSorteos does not process those payments and does not receive or store card numbers, banking credentials, or other financial data of Buyers.

The data that the Buyer provides when making a payment is processed by the relevant payment provider and, where applicable, by the Organizer, in accordance with their own privacy policies, which we recommend you review. AppSorteos is not responsible for the processing carried out by such third parties.

AppSorteos may share personal data only in the following cases:

With the Organizer: the data of the Buyers in a Raffle is made available to its Organizer, who is the controller of that data.
With the public: a Raffle page displays the numbers sold and the winning numbers. The Organizer's public profile may also display each winner's name in full, partially hidden, or not at all, depending on the setting chosen by the Organizer, who is responsible for that choice and for any additional information it decides to publish.
With service providers: companies that provide AppSorteos with hosting, database, email delivery, analytics, security, and support services, which access the data only to the extent necessary and subject to confidentiality obligations.
With authorities: when required by law, a court order, or a valid request from an authority, or when reasonably necessary to prevent fraud, protect the rights of AppSorteos or third parties, or investigate an allegedly unlawful Raffle.
In corporate transactions: in the event of a merger, acquisition, reorganization, or sale of assets, the data may be transferred to the successor entity, which will be bound by equivalent commitments.

AppSorteos does not sell or rent personal data.

8. International Transfers

AppSorteos is headquartered in the United States of America, and data may be hosted or processed in that country or in other countries where its providers operate. These countries may have data protection laws that differ from those of the data subject's country of residence. AppSorteos takes reasonable measures to ensure that the data receives an adequate level of protection. By using the Raffles feature, the User understands that its data may be transferred outside its country.

9. Retention Periods

The Organizer's account data is retained for as long as the account is active and for such period thereafter as is necessary to comply with legal obligations or address potential claims.
Buyers' data is retained for as long as the Raffle exists in the Organizer's account. If the Organizer deletes the Raffle or its account, AppSorteos will delete or anonymize that data within a reasonable period, unless it must retain it due to a legal obligation or for its defense against claims.
The record of the Declaration of Responsibility and security logs may be retained for the period necessary to demonstrate compliance and to exercise or defend rights.
Technical and statistical data is retained for as long as necessary for its purposes and is then deleted or anonymized.

Retention periods for data exported by the Organizer are set and managed exclusively by the Organizer.

10. Data Subject Rights

Depending on the laws applicable in your place of residence, you may have the right to access your data, rectify it, request its erasure, object to or restrict its processing, request its portability, and withdraw any consent you have given.

If you are a Buyer: you must first direct your request to the Organizer of the Raffle, who is the controller of your data. If you write to us, we will forward your request to the Organizer and cooperate with the Organizer to the extent appropriate to our role as processor.
If you are an Organizer: you may exercise your rights by writing to [email protected].

We may request additional information to verify your identity before responding to your request. We will respond within the time limits established by applicable law. If you believe that your rights have not been respected, you may also file a complaint with the data protection authority in your country.

11. Security

AppSorteos implements reasonable technical and organizational measures to protect data against unauthorized access, loss, or alteration, such as encryption of communications, access controls, and restricting internal access to those who need it. However, no system is completely secure, and AppSorteos cannot guarantee absolute security. The Organizer is responsible for protecting its login credentials and for the security of the data it exports.

12. Minors

The Raffles feature is intended exclusively for persons over 18 years of age. AppSorteos does not knowingly collect data from minors. If you become aware that a minor has provided data through a Raffle, you may report it to [email protected] so that appropriate measures can be taken.

13. Cookies and Similar Technologies

The pages of the Raffles feature may use cookies and similar technologies that are necessary for their operation (for example, to maintain the session or remember preferences), as well as analytics cookies to understand how the service is used. You can configure your browser to block or delete cookies, although some features may no longer be available. The use of cookies is also governed by the general Privacy Policy.

14. Changes to This Policy

AppSorteos may update this Raffle Privacy Policy at any time. The current version will always be posted on this page together with the date of its last update. When changes are material, we may give notice of them by reasonable means, such as a notice on the platform or an email.