Lucky Lotto Limited ("Company" "Administrators" "we" "us" "our") collects and processes information from members and potential members at several different points on Free Lotto (the ’Site’ ’Sites’) as well as through other methods of contact, including email.
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:
- We won’t sell your personal information to others;
- 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.
- 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 utilise 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 analyse 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 analysing 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 enquiries 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 analysing 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 optimisation 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
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 unauthorised access.
If we become aware of any unauthorised 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.
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.
To provide a personalised 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 customise 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.
Our Site runs a lottery winnings based cash reward service for customers of our retailer 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.
We work alongside affiliate networks and individual retailers 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 retailer, 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 retailers and/or other offer partners to ensure the offer is recorded correctly.
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 utilise 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 enquiries 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, 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.
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.
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.
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 enquiries you send to us, or as part of processing prizes or payments or otherwise administering claims.
18th Mar 2023
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 bank 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/).
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.