Privacy Policy

We (Islands Lotto Limited, operator of Islands Lotto) are committed to protecting your privacy and promise to collect, process and share your data safely and securely when you use 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 May 2018.

Contents
  1. 1 Our principles of data protection
  2. 2 Information we collect about you
  3. 3 How and why we use your personal data
  4. 4 How we use your personal data for direct marketing
  5. 5 How we share data with third parties
  6. 6 How we protect your personal data
  7. 7 How long we keep your personal data
  8. 8 Your rights
  9. 9 Contact us

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.

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.

Back to Contents 2 Information we collect about you

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 that you are a Channel Islands or Isle of Man resident.

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.

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.

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).

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, player protection measures, and to allow us to provide any information to the Jersey Gambling Commission as we are required to.

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.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent).

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 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.

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 of 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:

Back to Contents 6 How we protect your personal data

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

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.

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 rightsbelow for further information.

Back to Contents 8 Your rights

You have the right:

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:
Islands Lotto Limited
22 Hill street
St Helier, Jersey
JE2 4UA

By email to:
dataenquiries@islandslotto.com

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 for 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:

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 dataenquiries@islandslotto.com in the first instance.