Background Reading > Privacy Policy

LOTTOLAND AFRICA - As at 15th March, 2021

INTRODUCTION

Welcome to Lottoland’s Privacy Policy.

Lottoland respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website/app (regardless of where you visit it from) or when we contact you and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how Lottoland collects, stores and processes your personal data.

It is important that you read this Privacy Policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

CONTROLLER

Lottoland is made up of different legal entities including EU Lotto Limited. This Privacy Policy is issued on behalf of the Lottoland Group so when we mention “Lottoland”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Lottoland Group responsible for processing your data. EU Lotto Limited is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Our full details are:

 
EU Lotto Limited
Suite A
Ocean Village Promenade
Ocean Village
Gibraltar, GX11 1AA

Our appointed Data Protection Officer can be reached on:
[email protected]

You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (GRA), Gibraltar’s supervisory authority for data protection issues (www.gra.gi) contact details:

The Data Protection Commissioner
Gibraltar Regulatory Authority
2 Floor Eurotowers 4
1 Europort Road
Gibraltar GX1 1AA.
[email protected]

We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact the DPO in the first instance.

YOUR DUTY TO INFORM US OF CHANGES AND CHANGES TO THE PRIVACY POLICY

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If any of your personal details are incorrect, you can update them in the “My Account” section, or you can contact our Customer Care team via email at [email protected]

We may need to change this Privacy Policy from time to time. If we do change the Privacy Policy, we will post the new version on the Website/App. The new version of the Privacy Policy will take effect immediately upon its publication on the Website/App.

 

YOUR DUTY TO INFORM US OF CHANGES AND CHANGES TO THE PRIVACY POLICY

THIRD-PARTY LINKS

This website or App may include links to third-party websites, plug-ins and applications (for example Facebook, Twitter etc). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes: first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes: address, email address and telephone numbers.
• Financial Data includes: bank account and payment card details.
• Transaction Data includes: details about payments to and from you and other details of bets placed, games played, and products purchased from us.
• Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions and other technology on the devices you use to access our products and games.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website/app, bets placed, products and games played.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to terminate your account or cancel a bet you have placed with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  1. Place a bet with us or play a game;
  2. create an account with us;
  3. request marketing to be sent to you;
  4. enter a competition, promotion or survey; or
  5. give us some feedback.
• Automated technologies or interactions. As you interact with our website/app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies (such as Google Analytics). We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may also receive personal data about you from various third parties and publicly available sources and utilize this information for things such carrying out further identification checks to minimize fraud or money laundering risks to the business.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

MARKETING

We strive to provide you with choices and a personalised online betting experience, so you can receive offers or betting products that are relevant for you, in accordance with your marketing preferences.

You can opt out and unsubscribe and stop receiving personalised offers via email and SMS by clicking the unsubscribe link within each email or SMS that you receive from us, or by changing your marketing preferences in the My Account section of your account.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. (we call this marketing).

You will receive marketing communications from us if you have opened an account with us, purchased a bet or played a game or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not unsubscribed from receiving such marketing communication.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Lottoland Group of companies for third party marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

COOKIES

To enable the working of certain functions during your visit to our website or App, we make use of cookies on various pages. Cookies are small text files that are stored on your device. We make use of certain cookies that are deleted after your browsing session (session cookies). Other cookies remain on your device and allow our business partners and us to read information we have written into the file. The second type of cookies are read by us on your next visit to our website/app (persistent cookies). 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website or App may become inaccessible or not function properly.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Other companies in the Lottoland Group acting as joint controllers or processors and who provide customer services, IT and system administration services.
• Fraud prevention agencies used to provide customer due diligence including, money laundering, fraud, sanction checks.
• External third parties to provide marketing and promotional services on our behalf.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• Service providers who provide IT and system administration services.
• Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services to Lottoland.
• Regulators and other authorities who require reporting of processing activities in certain circumstance.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within the Lottoland Group of companies and third party service providers. This may involve transferring your data outside of the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for money laundering purposes. 

9. YOUR LEGAL RIGHTS

At any point while we are in possession of or processing your personal data, you have the following rights:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. If you still wish to exercise your right to object, we may have to terminate your account or cancel a bet you have placed with us but we will notify you if this is the case at the time.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the DPO.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than this if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.