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Affiliate Agreement

This Agreement is made between the Affiliate named above (referred to as "Affiliate") and Promogratis Ltd. (Company No. 15102974) of 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom (referred to as "Company"). Collectively, both are referred to as the "Parties” or individually as the “Party”.

All the details provided in the Affiliate Details Form are considered part of this Agreement.

Whereas it is agreed as follows -

  1. DEFINITIONS
    1. "Affiliate" means an individual or business entity that is legally bound by this Agreement to promote the Company's free memberships and direct potential members to the Company's website, www.freelotto.club (referred to as “Site”). 
    2. "Affiliate Commission" means 10% of all monies paid to the Company monthly from interest based advertising displayed on the draw results pages of the Site (only) whereby members logging into the Site and visiting the draw results pages will automatically view displayed advertisements appearing thereon which creates exposure for the featured advertisers and attracts payments to the Company.
    3. "Affiliate Link" refers to the unique tracking link provided by the Company to the Affiliate for the purposes of tracking referrals and calculating Affiliate Commissions. 
    4. "Qualified Action" means an action by an individual member of the public first contacted by the Affiliate in accepting the Company’s free membership offer and thereafter using the Affiliate Link to join the Site.
  2. DUTIES AND OBLIGATIONS
    1. Affiliate Duties: The Affiliate agrees to perform the following duties:
      • Affiliate agrees to promote the Site free memberships using the Affiliate Link in accordance with the terms of this Agreement and in compliance with all applicable laws and regulations;
      • Affiliate agrees not to make any false or misleading statements about the Site or Site content
      • Affiliate agrees to use the Affiliate Link in a manner that does not negatively impact the Sites reputation or brand image; and 
      • Affiliate is solely responsible for any expenses incurred in connection with the promotion of the Site’s free membership services and the use of the Affiliate Link.
      • Taxes: The Affiliate is responsible for any and all taxes associated with the receipt of the Affiliate Commission.
    2. Affiliate Duties: The Affiliate agrees to perform the following duties:
      • The Company will provide the Affiliate with the Affiliate Link and any necessary promotional materials to effectively promote their products and services; 
      • The Company will provide necessary training and support to the Affiliate to enable them to fulfill their obligations under this Agreement effectively; 
      • The Company will track the customers referred by the Affiliate using the Affiliate Link and calculate the Affiliate Commissions due to the Affiliate; and  
      • The Company will pay the Affiliate Commissions to the Affiliate for the previous months advertising income, one month in arrears.
  3. CONFIDENTIALITY
    1. Definition: "Confidential Information" means any information that a Party ("Disclosing Party") discloses to the other Party ("Receiving Party") that is either designated as confidential at the time of disclosure or should be reasonably understood to be confidential given the nature of the information and circumstances of disclosure. Confidential Information may include, but is not limited to, business plans, customer lists, financial information, marketing strategies, non-public information relating to products or services, and other proprietary information.
    2. Non-Disclosure: The Receiving Party agrees to keep all Confidential Information strictly confidential. The Receiving Party will not disclose or make available any Confidential Information to any third party without the prior written consent of the Disclosing Party. The Receiving Party will use the Confidential Information solely for the purpose of performing its obligations under this Agreement. 
    3. Exceptions: The obligations under this section will not apply to any Confidential Information that: was already lawfully known to the Receiving Party at the time of disclosure; is disclosed to the Receiving Party by a third party who had the right to disclose it; is publicly available through no fault of the Receiving Party; or is independently developed by the Receiving Party without use of or reference to the Disclosing Party's Confidential Information. 
    4. Required Disclosure: If the Receiving Party is required by law, court order, or any government or regulatory authority to disclose any of the Confidential Information, it will give the Disclosing Party prompt written notice of such requirement before the disclosure and, if possible, enough time to contest the disclosure. 
    5. Return of Confidential Information: Upon termination of this Agreement, or upon the Disclosing Party's request, the Receiving Party will return all Confidential Information and all copies, notes, or extracts thereof to the Disclosing Party unless required by law to retain it. 
    6. Continuing Obligations: The Receiving Party's obligation to protect the confidentiality of the Confidential Information will survive termination of this Agreement and continue until such time as the Confidential Information becomes public knowledge other than through the Receiving Party's breach of this Agreement.
  4. INTELLECTUAL PROPERTY
    1. Ownership: Affiliate acknowledges that the Company and its licensors own all rights, title, and interest in the service(s), product(s), and all intellectual property rights therein. Nothing in this Agreement gives Affiliate any right, title, or interest in the service(s), product(s) or any associated trademarks, except the right to sell free membership to the Site in accordance with this Agreement.
  5. TERM AND TERMINATION
    1. Term: This Agreement shall commence on the date of signed submission by the Parties and will continue indefinitely unless and until terminated by either Party.
    2. Termination without Cause: Either Party may terminate this Agreement without cause upon providing thirty (30) days' prior written notice to the other Party. Upon termination without cause, the terminating party is under no obligation to provide reasoning for the termination.
    3. Termination for Cause: Either Party may terminate this Agreement immediately upon written notice if the other Party:
      • Breaches any material term or condition of this Agreement and fails to cure such breach within thirty (30) days after receipt of written notice of the same, unless such breach is such that it cannot be cured within thirty (30) days, in which case the breaching Party shall commence such cure promptly after receipt of such notice and continuously pursue such cure to completion;
      • Becomes the subject of a voluntary or involuntary bankruptcy, insolvency, reorganization, liquidation, dissolution, receivership, or similar proceeding, or otherwise ceases to do business; or 
      • Fails to comply with any applicable laws or regulations, which may harm the reputation or business of the other Party.
    4. Effect of Termination: Upon termination or expiration of this Agreement for any reason:
      • The rights granted to the Affiliate under this Agreement will immediately cease;
      • The Affiliate must promptly discontinue all promotion of free memberships; and 
      • Any fees owed to either Party at the time of termination or expiration will be paid according to the terms of this Agreement.
    5. Survival: The rights and obligations of the Parties set forth in this Section 6 and any right, obligation, or required performance of the Parties in this Agreement which, by its express terms or nature and context is intended to survive termination or expiration of this Agreement, will survive any such termination or expiration.
  6. GENERAL PROVISIONS
    1. Governing Law: This Agreement shall be exclusively governed by and interpreted in accordance with the laws of England and Wales.
    2. Entire Agreement: This Agreement, contains the entire agreement between the Parties and supersedes all prior and contemporaneous agreements, understandings, negotiations ,and discussions, whether oral or written, of the Parties with respect to the subject matter hereof. 
    3. Amendments: This Agreement may only be amended, modified, or supplemented by an agreement in writing signed by each Party. 
    4. Waiver: No waiver by any Party of any of the provisions hereof shall be effective unless explicitly set forth in writing and signed by the Party so waiving. No waiver by any Party shall operate or be construed as a waiver in respect of any failure, breach, or default not expressly identified by such written waiver. 
    5. Indemnification: Each Party agrees to indemnify and hold the other harmless from any claims, losses, damages, liabilities, or expenses incurred as a result of the negligent or intentional acts or omissions of the indemnifying Party.
    6. Severability: If any term or provision of this Agreement is invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other term or provision of this Agreement or invalidate or render unenforceable such term or provision in any other jurisdiction.
    7. Notices: All notices or other communications required or permitted under this Agreement must be in writing, sent by electronic mail. Notices should be addressed to the relevant Party at the email address outlined in this Agreement, or to any other address that the recipient Party has provided in writing to the sender. A notice will be considered effectively given at the time of email delivery.
    8. Independent Contractor Relationship: It is understood that the Affiliate is an independent contractor and not an agent, partner, or employee of the Company. The Affiliate shall not have any authority to enter into any agreements or obligations on behalf of the Company.
    9. Non-Exclusivity: The relationship between the Company and the Affiliate is non-exclusive. Both Parties are free to enter into similar agreements with other parties unless otherwise specified in this Agreement.
    10. No Assignment: The Affiliate may not assign or transfer this Agreement, or delegate its obligations under this Agreement, without the Company's prior written consent.
    11. Dispute Resolution: In the event of any dispute arising out of or related to this Agreement, the Parties agree to negotiate in good faith to resolve the dispute. If the Parties are unable to resolve the dispute, they agree to submit the dispute to mediation before resorting to litigation.
    12. Counterparts: This Agreement may be executed in counterparts, each of which shall be deemed an original, but all of which together shall be deemed to be one and the same agreement. A signed copy of this Agreement delivered by email, or other means of electronic transmission shall be deemed to have the same legal effect as delivery of an original signed copy of this Agreement. 

Membership Agreement

Last updated: 29th Nov 2024

  1. This Agreement governs your membership and use of the Free Lotto Club site and promotional service ("Site"). If you do not agree to be bound by the terms appearing below, the content of the FAQ page, How It Works page and all other game play and memberships information published on the Site and in printed materials ("Terms") please do not join by submitting a Join Free Registration herein or attempt to use the Site.
  2. Membership hereunder is free of charge and restricted to individual residents of the United Kingdom and all other world jurisdictions where Membership and participation is not prohibited by law. For legal reasons Memberships are only available to individuals aged over 18 ("Member" "Members"). Each Member is exclusively responsible for determining their legal entitlement to participate hereunder prior to joining.
  3. The Site is owned by Promogratis Ltd (company number 15102974) of 71 – 75 Shelton Street. Covent Garden. London. WC2H 9JQ United Kingdom (the "Company" "we" "us" "our").
  4. The Site displays fully underwritten, weekly free lottery draws known as the Free Lotto Jackpot and the Community Cash Prize Fund together the program ("Program").
  5. Subject to the Terms, Membership will be granted free of charge to individuals who apply through the Site for a single account. Individuals are not entitled to apply for, operate or control through others more than one account. If an individual is found to be in breach of this rule their membership will be terminated, their account or accounts closed and any otherwise due winnings hereunder voided.
  6. All Members shall receive with the compliments of the Company, 5 Free Lotto lines every day. These lines are not reliant on purchases being made but must be submitted for play by Members on the day they were issued, or they will be forfeit. Members will not qualify for any rewards or prizes from the Community Prize Fund as detailed herein, unless they have submitted all 35 free lines for play in the same winning weeks draw, and there is a jackpot win. All rewards and prizes detailed on the Site are paid from the Community Prize Fund, except in the case of the 6 ball Jackpot and 5, 4 and 3, ball wins.
  7. If a Member fails to login to the Site and submit their 5 free daily lines for a continuous period of 3 months (90 days) their membership will be terminated, their account closed and any otherwise potentially due winnings previously shown in their account prior to such closure voided.
  8. Neither the Company, the Site, or any individual connected to or with them promote a paid lottery or lotteries, are not a paid lottery promoter and do not offer a paid betting service. The services offered on the Site to Members, do not fall within the definition of gambling services nor do such services amount to a gaming company requiring a licence from the UK Gambling Commission. The services detailed on the Site as offered to Members free of charge are those of a free lottery winnings-based prize draw service which is NOT a service that is governed or regulated by the Financial Services Authority; participation by members of the public does not amount to joining a collective or other investment scheme.
  9. If more than one Member wins the Free Lotto jackpot in any week, the prize shall be divided equally between such winners. The value of any Jackpot prize quoted on the Site is always therefore estimated until after the relevant draw has taken place and its results published.
  10. In the event of there being a Free Lotto jackpot winner in any week, that player shall receive a prize of $1,000,000. Plus all players from the same week (that submitted all their 35 free lines ) shall receive a share of the total $2,000,000 value of the Community Prize Fund, after all or any go shopping cash back and bonus cash winner prize amounts have first been settled.
    1. Every player will receive a payment equal to 100% of any cash paid to a participating go shopping retailer for the earliest remaining site registered / validated purchase(s) made through the Site, since their last win. The maximum cash back amount that will be paid to a go shopping winner for an individual win is £5,000 of the total due as shown in their account area.
    2. In the unlikely event that the total underwritten community prize fund of $2,000,000 proves insufficient to pay all winners 100% of their otherwise due amounts in any winning week, each affected member shall receive a lower amount but not a lower percentage of the available fund. Underwriting cover shall thereafter be increased accordingly.
  11. Membership is subject to honest and truthful completion by the Member of the join free and registration form appearing on the Site. Only one account can be registered and/or held per person and the Program benefits can only be enjoyed by a Member on any individual purchase once. Membership and all Program benefits hereunder are non-transferable under any circumstance.
  12. Members agree to receive regular promotional and reminder emails and to publication of their names and/or likenesses in the event of becoming a paid winner hereunder.
  13. If we determine at our sole discretion that a Member is in breach of the Terms, we may under those circumstances issue immediate notice of termination to the Member, close the Members account and cancel any otherwise due, or potentially due Program benefit detailed in their account.
  14. We have the right to change these terms or close the Site temporarily or permanently at any time for any reason by posting revised Rules on the Site. Members should print and retain a hard copy of these terms for future reference and check this page regularly for changes.
  15. If there is, or may be a technical issue affecting the Program being accurately operated and administered, such as, but not limited to, computer malfunction, transmission of data issues, virus or any other issue or issues which may be capable of impairing the accurate and honest operation of the Program for any period of time, then the Program shall be suspended until such time as any such problem or problems have been eliminated.
  16. The invalidity or unenforceability of any provision of this Agreement shall not affect the validity or enforceability of any other provision. If any provision is determined to be invalid or otherwise unenforceable or illegal, the remainder of the Agreement shall otherwise remain in effect and shall be construed in accordance with their terms as if the invalid or illegal provision were not contained herein.
  17. This Agreement and the Site are governed by the laws of England and Wales and subject to the exclusive jurisdiction of the courts of England and Wales.

Frequently Asked Questions

  1. What is Free Lotto Club?

    Free Lotto Club is a free to play community lottery site which entitles members to login and submit 5 free lotto lines every day (35 lines every week) no purchase required. If one player wins our $1,000,000, 6 ball jackpot, every participant that week that played all their 35 free lines receives a share of our $2,000,000 community prize fund - "one winner wins for everyone".

    How’s that possible? we receive fees and sponsorships from advertisers which pays our running and underwriting costs on the $3,000,000 in prizes offered every week.

  2. How do I participate?

    Step 1)
    Join Free and register your details, we will automatically credit your new account with 5 Free Lotto lines every day, which must be submitted for play each day or they will be void. So, if you log in every day, you will be able to choose and submit 35 lines every week.

    Step 2)
    If you purchase anything from a participating retailer, advertising in our Go Shopping pages simply register what you bought in your account area. Once the merchant has validated your purchase, you will have the opportunity of winning 100% of all your cash back, from our $2,000,000 community prize fund, on all your validated purchases since your last win.

    Step 3)
    If any of your played lines match the winning jackpot result we publish, you will receive a phone call followed by an email confirming your good fortune and, $1,000,000 will be deposited into your bank account.

    Plus…
    If any of your submitted entries were chosen for the jackpot draw and matched 1, 2, 3, 4 or 5 balls you will receive -

    • $500 for a 5 ball win
    • $50  for a 4 ball win
    • $20  for a 3 ball win
    • $10* for a 2 ball win
    • $5* for a 1 ball win

    * Bonus Cash is paid as part of the community prize fund.

    Registering on-line purchases in your account.
    These are purchases made through the retailer’s website.
    If your purchase was made on-line (through the retailer’s website) simply register the details of your purchase in your account area and we will arrange for the retailer to validate it.

    Registering off-line purchases.
    These are purchases made in the retailer’s place of business NOT through a website.
    If your purchase was made offline (not through a website) once again, simply register the details in your account area. To register an off-line purchase, you will need to join free then submit some purchase details (like date, amount etc) and a photo/scan of your retailer issued purchase receipt or receipted invoice, which must show the retailer’s name. Your retailer will then validate your purchase.

  3. How do I choose my lines?

    Members daily 5 free lines are live for 24 hours and must be chosen and submitted each day for play in the next available draw, or they will be made void, please don’t forget to submit your free lines. Simply login, then choose 6 numbers from 1 to 59 and submit your entries.

    We operate two draws each week, as follows -

    1st - Is the Friday Jackpot Draw
    Shortly after Midnight GMT, when weekly line submissions have closed, our system randomly draws a number of submitted lines to play for the weekly Free Lotto jackpot of $1,000,000 and publishes them on the site in participating member account areas. The total number of lines selected for the weekly Jackpot Prize draw are exclusively based on a fixed percentage of the club’s interest based advertising income.

    2nd - Is the Saturday Community Cash Prize Draw
    If a 6 number jackpot winner is identified that player will have won $1,000,000 and unlocked our, $2,000,000 Community Prize Fund, where everybody that played their 35 free lines that week wins a share of our Community Prize Fund, after we have settled all bonus cash and go shopping cash back entitlements.

  4. Are there any costs?

    Members pay nothing to join or play - ever!

  5. What’s your unique referral program?

    For every new member you refer, that plays all their 35 free lines in any winning week, we pay them a full share from the community prize fund and increase yours by the same amount. So, for example, if you refer say 20 new members (family, friends, contacts, etc) and the community prize fund net share value in a winning week is £1,000 each, then each member you referred receives £1,000 and you receive your own share of £1,000 + £20,000 (20 referrals at £1,000 each) = £21,000 and that’s in every winning week – not just one week.

  6. How will I know if I have won?

    Simply visit the site and login anytime from Sunday morning. Winners will find confirmation and a withdrawable credit in their accounts a few days later.

  7. Do I have to claim my winnings?

    No, payments are automatic and confirmed by email.

  8. How are winning amounts confirmed?

    The prize amount of any winning line is confirmed to logged in members on the Free Lotto site and sent by email. Prizes are then credited to each winner’s account ready for withdrawal.

  9. Are winnings underwritten?

    Yes, all prizes are fully underwritten, and payment is made to winners as soon as verified by the Free Lotto Club.

    All Free Lotto Club draws are independently adjudicated by proDmedia Ltd. and player prizes are fully underwritten. Click here for confirmation.

  10. What’s the history?

    Our involvement with financial sales promotional programs began over 30 years ago, several years before the Internet existed. These programs were used by hundreds of international businesses such as Apple Computers, Johnnie Walker, Black & Decker, Dunlop Slazenger and many more. We have pictured a few winners from our offline cashback promotions on the home page.

  11. What if I have a problem with my product?

    When you buy from a merchant, your purchase agreement is with them. If you have a problem with the product you purchased, please contact your merchant. We are only responsible for our lottery program.

  12. How do I retrieve my password?

    If you forget your password, simply go to the login page and click Forgot Password, you will be prompted to enter and submit your registered email address and our system will automatically reply with a link to change the password.

  13. How do I change my account information, for example if I move home?

    Login to your account and click Account Settings in the menu. If you change your email address, we will need to verify it by sending you an email to the new address with a clickable verification link.

  14. Is my personal information safe?

    Yes, the Free Lotto Club site is protected by Secure Socket Layer technology.

  15. How do I make a complaint?

    If you have reason to make a complaint, please click on the Contact Us link and provide full details. We will respond by return with an answer or at least to confirm that we are working on your complaint. Please be assured that we value feedback from our members whether positive or negative.

Privacy Policy

Promogratis Limited ("Company" "Administrators" "we" "us" "our") collects and processes information from members and potential members at several different points on Free Lotto Club (the ’Site’ ’Sites’) as well as through other methods of contact, including email.

This Privacy Policy (’Policy’) along with our Membership Agreement and Cookie Policy sets out the way we collect, store and use data relating to you (your personal data) and the reasons for doing so.

By continuing to access the Site or Sites, by registering on the Site or Sites, or by providing information to us, you are accepting and consenting to our use of your personal data, as a Data Controller, in the ways set out in this Policy.

How We Collect, Store and Use Your Data

When it comes to your personal data, we operate on three very simple principles:

  1. We won’t sell your personal information to others;
  2. We won’t share your contact details with other organisations except where it will be impossible for us to provide a service to you without doing so. The emails you’re going to receive will therefore only be coming from us or organisations we are in a service partnership with.
  3. We will follow industry practices to secure your data and always take our responsibilities as a data controller seriously;

We collect information from various sources, including third parties. This information may be collected automatically, such as when you visit our Sites, or explicitly, such as when you answer questions or set your preferences.

We utilize this information to:

  • Improve your experience on our Sites, by giving you control over your settings and preferences and by providing more relevant advertisements and offers.
  • Measure, fix and improve the Sites performances.
  • Monitor the use of the Sites for a wide range of purposes, including the provision of rewards to our members, the prevention of suspicious or fraudulent claims and recording statistics that help us run more successfully as a business.
  • Share anonymous and aggregated statistics between our trusted partners including our advertisers, affiliates, acquisition partners and monitoring services.
  • Connect with third party services including social media companies.
  • Contact you, but only where you have consented or requested that we do so.

General Data Collection

The following personal data relating to you may be collected:

INFORMATION YOU PROVIDE

You may provide information to us through web forms on our Sites, by email, or by phone. The information you provide may include your name, address, e-mail address and phone number. We will not intentionally or systematically seek to collect, store, use or otherwise process information about you classed as ’sensitive personal data’ (for example, information relating to any trade union membership, ethnic origin or medical conditions). We cannot prevent you from disclosing the same to us, or our agents, as part of your correspondence with us but you should ensure that such information is only provided where it is necessary.

INFORMATION WE COLLECT

We automatically collect certain information to help analyze our Sites and our service, including: technical information like the internet protocol (IP) address used to connect your computer or device to the internet, your browser type and version, time zone setting, operating system and platform; and information about your visit including the full uniform resource locators (URL) clickstream to, through and from our site (including date and time); pages you visited or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. This General Data may be used for analyzing the performance of any aspect of our Sites.

Any phone number used to call our contact numbers, postal addresses supplied in correspondence and any email addresses used to contact us are also stored for the purposes of administration and record-keeping.

We also collect information from the third-party services outlined in this Policy.

Our services and our Sites are for use by members 18 years old and over only. We do not market to users under the age of 18 and do not intentionally collect data on users under the age of 18.

USING YOUR INFORMATION

We use the information you provide largely to contact you – by email, phone or by post – in order to seek further information, to update you on any changes to our service, to send you general commercial (non-marketing) communications, to send you any communications that you have specifically requested, and to inform you of any similar or related services that we provide that we consider may be of interest to you. We may keep this information on file to record inquiries that we have received about our service, to help us to assess how effective our various marketing programs are, and to comply with any legal obligations that may be imposed upon us from time to time, such as recording your consents to Notifications.

We use the information we collect to ensure our Sites and other communications with you are presented in the most effective way, to administer our Sites (including troubleshooting them and carry out testing and analysis), to ensure that our Sites and other arrangements for collecting your data and communicating with you are as secure as possible and for marketing purposes.

SHARING YOUR INFORMATION

We might share your information with others, in limited circumstances, including as follows:

We will share your information amongst our group companies (that means companies that partially own us or are owned by us) – as they may help in analyzing and progressing your potential instructions.

As mentioned above, we work closely with selected partners who may provide administrative support, who may assist in collecting and storing your information and who may assist us in contacting you.

We may share information with analytics and search engine providers that assist us in the improvement and optimization of our Sites. Please see the section on "Third party tracking" for details on how to opt-out where possible.

We may need to disclose your information if required by law, if we believe that disclosure is necessary to comply with a current judicial proceeding, or a court order or legal process served on us.

In the event we go through a business transition, such as a merger or being acquired by another company our users / members information will, in most instances, be part of the assets transferred.

STORING YOUR INFORMATION

Your information may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on secure server space. Unfortunately, the transmission of information (via the internet) is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of data transmitted either through our Sites or by post, email or phone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

If we become aware of any unauthorized access to data submitted to us, we will contact the Information Commissioner’s Office and the individuals affected in accordance with the General Data Protection Rules.

LINKS

The Website contains links to other sites. Please be aware that we are not responsible for the privacy practices or content of such other sites and you should read the terms and conditions, privacy policy and cookies policy before utilising such other sites.

If you believe that a site linked to our Site or Sites contains improper content or is misleading in content or service, please report the URL containing the link and the URL of the link itself to us by email.

Data Processing

To provide a personalized experience on our Sites, we store, and process information related to each member’s account (’Account Data’).

The Account Data includes specific information requested by us on the Join Free form and other registration forms appearing on our Sites. All Account Data can be controlled through your account settings page.

The Account Data also includes how each member was referred to us (e.g. whether they conducted a Google search, clicked on an advert for our service or were referred by an existing member or acquisition partner). This referral information will sometimes come through third parties and is used to calculate rewards for other members as well as fulfil contractual obligations we have towards third parties including acquisition partners.

We also record the registration time and date and the internet protocol address in use by the member at the time they registered. This is recorded to demonstrate a member’s eligibility for the draws and assist in preventing fraudulent claims.

We use the Account Data to customize the offers and advertisements a member may see on the Website or in notifications. This process does not involve sharing the Account Data with third parties.

Site Services

Our Site runs a lottery winnings based cash reward service for customers of our merchant clients (Service). To effectively administer the Service, we record all results including the email addresses and other data of any potential recipient of our winnings as registered to the site at the time of each lottery draw.

The Draws Data will be safely stored on the Website, securely copied to the Website’s email system and copied to our external client relationship manager, which is further detailed below.

The results of our Draws are set by requirements as detailed on our Sites, in our member agreements, FAQ pages and materials issued by us from time to time. Email addresses recorded as part of the Draws Data will only be used to help facilitate successful administration of the Service. This may be done through our external client relationship manager or require the use of a third-party payment portal, both detailed below.

Affiliate Networks

We work alongside affiliate networks and individual merchants to record when a member has completed an offer. These records are used to provide rewards to our members in addition to helping us track the performance of the offer. We also use the records to prevent the member claiming multiple rewards and to display the offers completed by the member on their account page.

To correctly record when a member has completed an offer we share a unique identifier with the affiliate network or merchant, which they return to us when the offer has been completed. The unique identifier used in this process is most likely to be the member’s personal id, which is a number assigned to them upon registration.

Some offers require another code or reference to be eligible for the offer. Where possible we automatically share this with our affiliate networks or merchants and/or other offer partners to ensure the offer is recorded correctly.

Advertisements

Advertisements help fund our lottery participation on our Site, so we encourage all members to whitelist our Site when using any advertisement blocking software.

We do not share any personally identifiable information collected about you with advertisers. When connecting you to third party services through our Sites, including our advertisers, your browser will share information about the connection. This is likely to include details about your internet protocol address, the device you are using, your web browser as well as additional information that assists in the connection being made and the transmission of the requested content or advertisement. To limit this information or restrict access to third party cookies, please refer your web browser’s documentation.

By default, the only data we share with advertisers or potential advertisers will be anonymous and aggregated, for the advertiser or potential advertiser to better understand the general demographics of our members, where required by them. None of the data shared by us can be used to target a specific individual.

We and our advertising partners, except for Google, adhere to the Interactive Advertising Bureau’s Transparency and Consent Framework. The details of which can be found at (https://advertisingconsent.eu/) (’Consent Framework’).

The Consent Framework ensures that any advertisers on our Sites are not permitted to process or store any personally identifiable information about you, including any data from third party sources, when serving you advertisements.

External Client Relationship Managers

To appropriately manage communication with our members, we utilize various third-party tools that help better maintain our relationship with our members (’CRMs’).

The CRMs record all information made available through emails to and from our support team and employees, including messages sent through our contact page. This includes responses to and from any such communication.

By emailing us, responding to our emails, or contacting us through the contact page, you are consenting for these details to be stored within the CRMs indefinitely, for the purposes of record keeping and processed to assist with your inquiries or improve how we manage relationships with our members.

The CRMs may contact you, but only on our behalf, examples of which are when we reply to your enquires, set up an automated response, or request feedback on how helpful our responses have been.

Payment Portals

Payment portals, such as PayPal, are used to facilitate the payment of prizes or rewards to members. All payment portals will require some unique personally identifiable information, such as an email address or bank account number, to get the payment to the appropriate recipient.

By supplying us with these details, you consent for us to use them to make such payments and to store them indefinitely as a record of the prize and related payment.

Email Verification

When joining our Site or updating your contact details, we send an email to your email address to verify that the address is correct and active.

Social Media

We reserve the right to collect information you publicly share to social media sites for republication. Where possible we will republish this information through the services provided through the social media site. This will allow you to control the shared information through your social media site account.

We also may collect and store any content you make available through the public comments on the Facebook commenting system.

Notifications

When registering an account with us or changing the email registered on your account, we will send you an email asking you to verify that the email address is real. We will also send you an email when you initially complete this verification process, confirming your participation in the services we provide.

We will also send you emails in response to any inquiries you send to us, or as part of processing prizes or payments or otherwise administering claims.

Changes

We will occasionally update this Privacy Policy to reflect company and customer feedback. We encourage you to periodically review this Privacy Policy to be informed of any changes to how we deal with your information. To help you in doing so, the version and date of this policy are stated below.

This Privacy Policy was last updated:
29th Nov 2024

Your Rights

You have the right to access and update the personal data we hold about you and the right to understand how it is being processed, used and shared.

You also have the right to delete personally identifiable data we hold about you, except where previously outlined in this Policy or as required by law.

You can exercise these rights at any time by visiting your private account page or by sending us details of your subject access request, including your email address, to our Data Protection Officer through the contact us form on the Sites.

We aim to respond to subject access requests within 7 days, starting the next working day (Monday to Friday, excluding public holidays) following receipt of the request.

If you are unhappy with anything related to the personal data you have shared with us, you have the right to make a complaint to our Data Protection Officer, or the Information Commissioner’s Office (https://ico.org.uk/concerns/).

Contacting Us

Our Data Protection Officer can be contacted through the contact us page on our Site.

Our admin team are always happy to help, so if you have questions about this Policy please use the contact us form on the Site.

Cookie Policy

This is the Cookies Policy (the 'Cookies Policy') for PromoGratis Ltd. 71-75 Shelton Street, Covent Garden, London. WC2H 9JQ United Kingdom (Company 'we' 'us' 'our'). Please read it carefully to ensure that you are willing to accept the cookies used by our Sites and the third-party services our Sites use.

By using our Sites and agreeing to this Cookies Policy, you are consenting to our use of cookies in accordance with the terms of this Cookies Policy and our Privacy Policy.

The definitions set out in the Membership Agreement will apply (except where the context otherwise requires).

What are Cookies?

Cookies are small ’packets’ of data downloaded to your computer which communicate with websites to provide information to those who operate them. For example, they may help website operators improve your experience on their website or distinguish you from other users.

How We Use Cookies

When you log into our Site, a cookie is set which stores an alphanumeric identifier that enables the browser to keep you logged in until you log out. There are two versions of this cookie to signify how you logged in, which determines what can be accessed through your account page.

We also store cookies to help manage your experience on our Site. This includes whether to load assets from our content delivery network, what landing page you signed up from, how long you have been a member and other tests we conduct in order to improve our Site.

All cookies set by us can be deleted from your device.

Third Party Cookies

When you visit our Site, you are also making connections to various third-party websites, each with access to set and manage cookies of their own. We do not have access to any data contained within these cookies, nor can we manage these cookies.

Google Analytics

We use a cookie named Google Analytics (which is part of the Google Analytics service) to analyze the use of our Site and other websites more generally. Google Analytics uses cookies to collect and create statistical and other data about website and internet use.

Google Analytics is a persistent cookie which is stored on your computer and will remain installed even after you have left our Site. You may have already downloaded Google Analytics from another website.

Refusing Cookies

Most browsers allow you to refuse to accept cookies in the following way:

In Internet Explorer, you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector
In Edge, you can refuse cookies by clicking "More", "Settings", "View advanced settings" then under "Privacy and services", set "Cookies" to "Block only third-party cookies" or "Block all cookies".

In Firefox, you can adjust your cookies setting by clicking "Tools", "Options" and "Privacy".

In Google Chrome, you can disable all cookies by clicking "Tools", "Options" and "Under the Bonnet", then selecting "Content Settings".

Refusing all cookies will prevent you from accessing our Site correctly or remembering who you are. Blocking third party cookies should not interrupt your experience on the Website.

Changes

We encourage you to periodically review this Cookies Policy to be informed of any changes to how we use cookies and what cookies are used by third parties. To help you in doing so, the version and date of this policy are stated below.

This Cookies Policy was last updated:
29th Nov 2024

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