Privacy Policy

Last updated: January 2025

1. Introduction

FeFem Holding B.V. ("we", "us", or "our") operates PredictLot. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data Controller

FeFem Holding B.V.
Email: privacy@predictlot.com
Netherlands

3. Data We Collect

3.1 Account Information

• Email address
• Display name
• Password (encrypted)
• Language preference

3.2 Payment Information

• Billing address
• Payment method details (processed by Stripe)
• Transaction history

Note: We do not store complete credit card numbers. Payment processing is handled by Stripe.

3.3 Usage Data

• Analysis requests and results
• Feature usage patterns
• IP address and device information
• Browser type and version

3.4 Communications

• Support requests
• Chatbot conversations
• Email correspondence

4. Legal Basis for Processing

We process your data based on:

• Contract: To provide our services to you
• Legitimate Interest: To improve our services and prevent fraud
• Legal Obligation: To comply with tax and financial regulations
• Consent: For marketing communications (where applicable)

5. How We Use Your Data

• Provide and maintain our Service
• Process payments and manage subscriptions
• Send transactional emails (invoices, confirmations)
• Provide customer support
• Improve and personalize our Service
• Detect and prevent fraud
• Comply with legal obligations

6. Data Sharing

We share your data only with:

• Stripe: Payment processing
• OpenAI: AI analysis (anonymized queries only)
• Email providers: Transactional emails
• Legal authorities: When required by law

We do not sell your personal data to third parties.

7. Data Retention

• Account data: Until account deletion + 30 days
• Analysis history: 2 years from creation
• Payment records: 7 years (legal requirement)
• Support communications: 3 years

8. Your Rights (GDPR)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data ("right to be forgotten")
• Portability: Receive your data in a machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interest
• Withdraw consent: Where processing is based on consent

To exercise these rights, contact us at privacy@predictlot.com

9. Data Security

We implement appropriate security measures including:

• Encryption in transit (TLS/SSL) and at rest
• Secure password hashing
• Regular security audits
• Access controls and authentication
• Data protection training for staff

10. Cookies

We use essential cookies for:

• Authentication and session management
• Security and fraud prevention
• Remembering your preferences

We do not use tracking or advertising cookies.

11. International Transfers

Your data may be processed outside the EU/EEA by our service providers. We ensure appropriate safeguards through:

• EU-approved Standard Contractual Clauses
• Adequacy decisions
• Certification schemes (where applicable)

12. Children's Privacy

Our Service is not intended for users under 16 years of age. We do not knowingly collect data from children.

13. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via email or through the Service.

14. Complaints

If you have concerns about our data practices, you have the right to lodge a complaint with your local data protection authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

15. Contact

For privacy-related questions or requests:

Data Protection Officer
FeFem Holding B.V.
Email: privacy@predictlot.com