Privacy Policy

1. Introduction

Promogratis Limited ("Company", "we", "us", "our") operates Free Lotto Club (the "Site", "Sites") located at freelotto.club. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services.

This policy complies with:

• UK General Data Protection Regulation (UK GDPR)
• EU General Data Protection Regulation (GDPR)
• California Consumer Privacy Act (CCPA)
• Other applicable privacy laws

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

2. Information We Collect

2.1 Information You Provide Directly

When you register or interact with our Site, you may provide:

• Account Information: Name, email address, postal address, telephone number
• Payment Information: PayPal email address or other payment details for prize payments
• Communications: Content of emails, support requests, and feedback
• Preference Information: Your communication preferences and lottery participation choices

2.2 Information Collected Automatically

When you visit our Site, we automatically collect:

• Device Information: Browser type, operating system, device type, screen resolution
• Usage Data: Pages viewed, time spent on pages, clicks, scrolling behaviour
• Network Information: IP address, ISP, geographic location (country/region level)
• Referral Data: How you arrived at our Site (search engine, advertisement, direct link)

2.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies. Please refer to our separate Cookie Policy for detailed information about:

• Types of cookies we use
• Purposes for each cookie category
• How to manage cookie preferences
• Third-party cookies including Google AdSense

3. How We Use Your Information

3.1 Primary Purposes

We use your information to:

• Provide Services: Operate the lottery participation service and process winnings
• Account Management: Create and maintain your account, verify identity
• Communications: Send service updates, respond to enquiries, provide customer support
• Payment Processing: Facilitate prize payments through PayPal or other methods
• Legal Compliance: Meet regulatory requirements, prevent fraud, ensure fair play

3.2 Advertising and Analytics

We use your information for:

• Personalised Advertising: Display relevant advertisements through Google AdSense
• Analytics: Understand Site usage through Google Analytics
• Performance Improvement: Optimise Site functionality and user experience
• Aggregated Reporting: Create anonymous statistics for business partners

3.3 Legal Bases for Processing (UK/EU Users)

We process your data based on:

• Consent: For cookies and marketing communications
• Contract: To provide our lottery services
• Legitimate Interests: For security, fraud prevention, and service improvement
• Legal Obligations: To comply with applicable laws

4. Third-Party Services and Data Sharing

4.1 Advertising Partners

Google AdSense

• We use Google AdSense to display advertisements
• Google may use cookies to serve ads based on your prior visits
• You can opt out of personalised advertising at www.google.com/settings/ads
• View Google's privacy policy at www.google.com/policies/privacy

4.2 Analytics Services

Google Analytics

• Helps us understand Site usage patterns
• Uses cookies to collect anonymous data
• You can opt out using the Google Analytics Opt-out Browser Add-on

4.3 Payment Processors

PayPal

• Used for prize payments
• We share only necessary payment information
• PayPal's privacy policy: www.paypal.com/privacy

4.4 Other Sharing

We may share your information:

• With affiliated companies for service provision
• With service providers who assist our operations
• When required by law or legal process
• In connection with a business transfer or merger
• With your explicit consent

5. Data Retention

We retain your information for different periods based on purpose:

Data Category	Retention Period
Account Information	Duration of account plus 6 years
Payment Records	7 years (legal requirement)
Marketing Preferences	Until withdrawn or account closed
Cookie Data	See Cookie Policy for specific durations
Support Communications	3 years from last interaction
Analytics Data	26 months (Google Analytics default)

6. Your Privacy Rights

6.1 UK/EU Residents (GDPR Rights)

You have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate data
• Erasure: Request deletion ("right to be forgotten")
• Restriction: Limit processing of your data
• Portability: Receive your data in a portable format
• Object: Object to certain processing activities
• Withdraw Consent: Withdraw consent at any time

6.2 US Residents (CCPA Rights)

California residents have the right to:

• Know what personal information we collect
• Request deletion of personal information
• Opt-out of the sale of personal information (we do not sell data)
• Non-discrimination for exercising privacy rights

6.3 How to Exercise Your Rights

Contact Methods:

• Email: Use our contact form on the Site
• Post: Promogratis Limited, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK

Response Time: We aim to respond within 7 days, and will fulfil requests within 30 days

Verification: We may request information to verify your identity

6.4 Cookie Consent Management

You can manage cookie preferences:

• Through our cookie consent banner
• Via the cookie settings button on our Site
• Through your browser settings
• Using opt-out tools provided by advertising partners

7. Children's Privacy

Our Site is not intended for anyone under 18 years of age. We do not knowingly collect personal information from children. If we discover we have collected information from a child under 18, we will delete it immediately.

8. Data Security

We implement appropriate technical and organisational measures to protect your information, including:

• SSL encryption for data transmission
• Secure servers with restricted access
• Regular security assessments
• Employee data protection training

However, no method of internet transmission is 100% secure. We cannot guarantee absolute security.

9. International Data Transfers

Your information may be transferred to and processed in countries outside the UK/EEA, including the United States. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the UK/EU
• Adequacy decisions
• Your explicit consent

10. Third-Party Links

Our Site may contain links to third-party websites. We are not responsible for their privacy practices. We encourage you to read their privacy policies before providing any information.

11. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by:

• Posting the new policy on this page
• Updating the "Last Updated" date
• Sending an email notification for significant changes

12. Contact Information

Supervisory Authorities

UK Users: Information Commissioner's Office (ICO)
Website: ico.org.uk
Helpline: 0303 123 1113

EU Users: Your local Data Protection Authority
List available at: edpb.europa.eu

13. Consent to Privacy Policy

By using our Site, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

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Version: 2.0
Previous Version Date: 22nd March 2025