Privacy Policy

We are committed to protecting your privacy and promise to collect, process and share your data safely and securely when you use the Islands Lotto website. Our Privacy Policy tells you how we do this and what your rights are. Any personal data processed in line with our Privacy Policy is controlled by us, as the data controller.

Any changes that we may make to our Privacy Policy in the future will be posted on our website. Where appropriate, we will notify you of the changes when you next visit our website.

This Privacy Policy was last updated on 24th January 2022.

Our principles of data protection

Transparency – We will always tell you what data we’re collecting about you and how we use it. We only share your data with trusted partners and will never sell your data.

Secure – We are committed to always follow industry best practices to ensure your data is stored safely and securely. We protect the confidentiality, accuracy and availability of the information we collect about you.

Control –You can stop receiving marketing communications at any time you decide.

Contents

Back to Contents 1 Our principles of data protection

Transparency – We will always tell you what data we’re collecting about you and how we use it. We only share your data with trusted partners and will never sell your data.

Control –You can stop receiving marketing communications at any time you decide.

Back to Contents 2 Information we collect about you

Personal and contact information when you open an Islands Lotto account online (or update that information in your account), including your name, address, email address, telephone number(s), Islands Lotto account username, social media username(s), and date of birth. We may collect some of that contact information when you interact with us including via our Islands Lotto Support Team.
Details (and copies) of your communications and interactions with us via our Islands Lotto Support Team or otherwise, including by email, telephone, post and online via the Help menu or on Islands Lotto social media channels.
Copies of documents you provide to prove your identity (including driving licence and passport) when you are claiming a prize, or where there is a legal reason to request this from you.
Transaction details including payments from you for Islands Lotto games, payments to you (for example prizes), details of Islands Lotto games played and the outcomes of those games.
We do not control or process your payment card information, when you top up your Islands Lotto account wallet, this data is processed by our payment providers and it is not stored by Islands Lotto.
Information about how you use our website, and which websites you came to the Islands Lotto website from.
Technical information about your device or browser when you use our website, including geolocation data to determine what country you are accessing our website from, your internet protocol (IP) address, device ID, browser type and version and time zone setting, which may in some circumstances be personal data.
We may also receive personal data directly from you or from social media channels (if you interact with us through those channels).

Back to Contents 3 How and why we use your personal data

In the table below, we set out all of the ways we use your personal data, and why. We have also identified what our legitimate interests are where appropriate.

It is sometimes necessary for us to process your personal data in order to enter into a contract with you, or to satisfy a contractual requirement (referred to as ‘performance of a contract with you’ below), or to comply with a statutory requirement. In those circumstances, if you do not provide the personal data we require, we will be unable to provide our games or other services to you.

Use	How we use your personal data	Why we use your personal data
Registration	We use your personal and contact information to register you as a new player.	Necessary for the performance of a contract with you.
Eligibility	We use the personal details you provide at account set up and, where relevant, any identity documents you have provided to check whether you are eligible to play our games. For example, when you set up your account we have an automated process in place to verify that the details you provide are correct and to verify you are over 18, and your place of residence or location.	Necessary for compliance with a legal obligation.
Verification	We may require copies of documents to verify your identity where we are not able to verify your age and country of residence via our automated process, or when a prize claimed amount exceeds the thresholds stated in our terms and conditions, or we are required by law to provide assistance or in order to comply with any request you may make regarding an Islands Lotto account. For example, for deceased players we require certain verification information in order to close that player’s account.	Necessary for compliance with a legal obligation.
Prize claim validation	We require copies of documents to verify your identity and place of residence when you claim a Large Prizes, defined in our terms and conditions. We will share these documents with the Insurer or any intermediary between Islands Lotto and that Insurer, to ensure you are allowed to participate in that game.	Necessary for the performance of a contract with you. Necessary for our legitimate interests (being able to claim prizes from Insurer).
Playing our games	We use the personal and contact information provided by you and the transaction details about your purchases, to provide our games and other services to you.	Necessary for the performance of a contract with you.
Lottery Betting games	We register your IP address when playing Lottery Betting games. Your access to this games may be restricted according to your location. We may share your IP address with the Insurer or any intermediary between Islands Lotto and that Insurer, to ensure you are allowed to participate in that game.	Necessary for the performance of a contract with you. Necessary for our legitimate interests (being able to claim prizes from Insurer).
Managing your account	We use your personal and contact information, and transaction details about your Islands Lotto purchases, to manage your Islands Lotto account, to contact you if you’ve won a prize, and to pay those prizes.	Necessary for the performance of a contract with you.
Communicating with you	We use the personal and contact information provided by you, copies of your communications with us and, in some circumstances, transaction details, to manage our relationship with you. For example: to notify you about changes to our Account Terms or Privacy Policy; to communicate with you in response to any query, request or complaint you may have including by email, telephone and in raise a query whether relating to any games that you have purchased from us or otherwise.	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how players play our games).
Staff training	We use copies of your communications with us in order to train our staff.	Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).
Market research	We may use the personal and contact information you have provided to ask you to take part in market research or a survey. We also use the results of any surveys or market research that you undertake to improve our games, our app, our website, or our service.	Necessary for our legitimate interests (to assess and improve our games, service and business).
Prize draws and competitions	We may use your personal and contact information, and transaction details as part of a prize draw or competition (including to enter, take part and pay any prizes due as part of that prize draw or competition).	Necessary for the performance of a contract with you.
Technical issues	If you contact us about an issue, we may require and use technical information, and personal and contact information to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Necessary for our legitimate interests (for running Islands Lotto, the provision of administration and IT services, security and fraud prevention). Necessary to comply with a legal obligation.
Experience	We use information about your use of our website, together with technical information about your device and (in some circumstances) your personal and contact information, and other relevant information that we receive from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant website content, prize draws, competitions and other direct marketing to you, and to manage the delivery of that content. For example, we may automatically display relevant advertisements to you based on your use of our website.	Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our app or website and the Islands Lotto games you have played).
Direct marketing	To make suggestions and recommendations to you about products that may be of interest to you. To keep you informed about our new products and provide you with exclusive offers.	Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).
Public Relations	When you win a prize we may use your first name, country of residence and the amount of the prize for public relations purposes.	Necessary for our legitimate interests (to advertise our products/services and provide credibility to our business). We won’t share any other information which might allow the public to identify You.
Advertising effectiveness	We use information about your use of our website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.	Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising, its relevance and in order to fulfil contracts we have with our marketing partners).
Analytics	We use information about your use of our website and technical information, including about your device or where you are accessing our website from, to optimise our service and to improve our website, games, services, direct marketing, player relationships, behaviour profiling and experiences.	Necessary for our legitimate interests (to measure the interactions with our website, to define types of players of Islands Lotto games, how players play the games, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Winners	If you win on an Islands Lotto game, we may use your personal and contact information to contact you to arrange support.	Necessary for our legitimate interests (to develop our games and to manage our winner services).
Regulatory compliance	We may use your personal and contact information, information about any transaction between you and us, information about your use of the website, or technical information, to enable us to comply with our legal and regulatory obligations. These include reporting aggregated data to the Jersey Gambling Commission or other regulatory authority, taking player protection measures, and to allow us to provide any information to the Jersey Gambling Commission, or other regulatory authority or to the police or any other law enforcement agency, as we are required to do from time to time.	Necessary to comply with a legal obligation.
Fraud prevention	We may use your personal and contact information, information about any transaction between you and us, information about your use of the website, or technical information, in order to undertake analysis for the purposes of identifying and dealing with any fraud or fraudulent activity and to provide information to the police or any other law enforcement agency.	Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent). Necessary to comply with a legal obligation.
Self-exclusion	If you request a self-exclusion, we may apply best practices to prevent you from using your account for the period of your self-exclusion (including, for example, but without limitation, using Your name and address).	Necessary to comply with a legal obligation. Necessary for our legitimate interests (to ensure that players are not Ineligible to have an active account in our Site).
Queries	We may use your personal and contact information, information about any transaction between you and us, information about your use of the website, or technical information for the purpose of dealing with any request, complaint or query from you.	Necessary to comply with a legal obligation. Necessary for our legitimate interests (to respond to you and to deal with any request you may have).

We use your personal data to create aggregated data sets. You are not identifiable from that aggregated data and it is not considered personal data.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Back to Contents 4 How we use your personal data for direct marketing

We send you marketing communications through a number of different channels and via our advertising partners. You will receive direct marketing by email or to your mobile (if you have provided it) if you have opened an Islands Lotto account through our website and this is in our legitimate interests. We will always offer a way out of receiving this in every email marketing communication, and you can opt out to receive any mobile reminders by unticking the ‘SMS Reminder’ box in your Account Preferences.

Personalisation

We want to give you the best possible experience when you play Islands Lotto and when we communicate with you. To do this we want to understand our players, what games you play and how you use our website. We use this information to offer you promotions that are most likely to interest you and to personalise our communications and content to make them relevant.

You will receive personalised marketing by email if you have opened an Islands Lotto account through our website and this is in our legitimate interests. We will always offer a way out of receiving this marketing in every marketing communication.

How to opt out of direct marketing and personalised marketing

You can opt out from receiving direct marketing and personalised marketing communications by clicking 'unsubscribe' in any marketing email we send you.

Back to Contents 5 How we share data with third parties

We sometimes share the data we collect from you with the following trusted third parties:

Payment providers – to obtain payment of any amounts due to us.
Our IT system providers – in order to provide software to set up your player account, to communicate with you via query system and other communications providers and to provide our systems to us, including for the purposes of hosting, support and software licensing.
Insurer and intermediaries between them and us – to validate a prize claim.
Marketing service providers – to allow us to send email or mobile communications (including, for example, direct email marketing)
Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.
Public relations agencies – for the purposes of managing external communications about us and our winners.
Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.
The Jersey Gambling Commission and other regulatory authorities – for legal and regulatory purposes as required under our licence to operate Islands Lotto.
Police or other law enforcement agency – as part of an investigation or otherwise for legal or regulatory purposes.
Dispute Resolution agencies – for the purposes of dealing with any complaints.
Credit reference agencies – for the purpose of checking the details that you have provided us with are correct and to comply with our regulatory obligations.
Security companies – for the purposes of security, including prevention and detection methods, for the protection of Islands Lotto.
Auditors – to audit our systems and transactions for the purposes of ensuring efficiency, or regulatory or contractual compliance.
Third party security companies – for the purposes of ensuring that we comply with the law and have adequate security measures in place.
We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety or of our players, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Back to Contents 6 How we protect your personal data

We have put various measures in place to protect your personal data:

Our online security controls maintain confidentiality at all times. Our payment providers are certified to the payment card data security standards (PCI-DSS) and Islands Lotto never process or store card details.
Our entire site is accessed using https rather than http, meaning that all information that is sent and received is encrypted for additional security. You can see this in the address bar of your browser.
As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. Where we do, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, and have limited control over how it is protected by that party.

Your personal data may be processed outside the European Economic Area (EEA) and the Channel Islands (C.I.) – including by staff operating outside the EEA or C.I. who work for us or for one of our third parties mentioned. That includes to digital marketing or social media agencies for the purposes of providing relevant marketing or advertising to you, market research or survey providers and email marketing services, for the purposes of processing any payments that you may make to us, communicating with players delivering dynamic content to web browsers or for the purposes of reporting and tracking web performance.

Where your personal data is transferred outside of the EEA or C.I., we require that appropriate safeguards are in place. To find out more about the appropriate safeguards that we have in place, please contact us.

Back to Contents 7 How long we keep your personal data

We will only keep 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.

We may keep your personal data for as long as is necessary to implement any self-exclusion you have imposed, but during that time it will not be used to allow you to play any games.

At the end of that retention period, your data will either be deleted or anonymised (so that it can no longer be associated with you) for research or statistical purposes.

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.

In some circumstances you may be entitled to ask us to delete your data: see ‘Your rights’ below for further information.

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.

Back to Contents 8 Your rights

You have the right:

to ask us not to use your personal data for direct marketing. To do so, click 'unsubscribe' in any email communication we send you;
to ask us not to process your personal data where it is processed on the basis of legitimate interests, if there are no compelling reasons for that processing;
to request from us access to personal information held about you (see Contact us section below);
to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
to ask that we stop any consent-based processing of your personal data after you withdraw that consent;
to ask, in certain circumstances, to delete the personal data we hold about you;
to ask, in certain circumstances, for the processing of that information to be restricted; and
to ask, in certain circumstances, for data portability.

Back to Contents 9 Contact us

If you have any questions about our Privacy Policy, including any requests to exercise your rights, please contact us using the details set out below:

By post to:
1 Jubilee Promenade
La Route Du Port Elizabeth
St Helier, Jersey
JE2 3NW

By email to:
[email protected]

You can access your personal information through the website, simply log in and go to Account menu. If you cannot find the data you are looking for or have a specific request about the personal data that Islands Lotto holds about you, please send your request in writing the above address. To enable us to verify your identity and process your request, you must include all of the following information and documentation with your request:

your full name;
the email address registered to your account;
a description of the data that you are requesting, including a date range;
a copy of your current and valid photo ID (e.g. passport photo page);
proof of your address in the form of a photocopy of a utilities or service provider bill; and
the date of the request.

Islands Lotto reserves the right to refuse to comply with a subject access request if it is manifestly unfounded or excessive, taking into account whether the request is repetitive in nature.

If you are unhappy with our processing of your personal data, you have the right to complain to the Office of the Information Commissioner at any time. Their contact details are available here: https://oicjersey.org/online-enquiry/#/complain/form. We would, however, appreciate the chance to deal with any concerns before you approach them, so please contact us by email to [email protected] in the first instance.