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SCOTTISH CHILDREN’S LOTTERY PRIVACY POLICY

Introduction

Welcome to the Scottish Children’s Lottery (the “Lottery”).  The Scottish Children’s Lottery operates as a series of society lotteries for certain charities under the Gambling Act 2005.  Each of the Scottish Charitable Incorporated Organisations listed below (the “Charities”) participates in the Lottery:

  • Chance to Flourish - SC046177
  • Chance to Study - SC046178
  • Chance to Succeed - SC046179
  • Chance to Connect - SC046173

The Charities have appointed STV ELM Limited (“STV ELM” or “we”) to promote and manage the Lottery.  STV ELM is the data controller under the Data Protection Act 1998 for the purposes of this Privacy Policy.  

We are committed to ensuring your privacy and protecting the data we hold about you for the purposes of managing the Lottery. 

This Privacy Policy sets out

  • why we collect data;
  • what data we collect;
  • when we collect data;
  • what we do with the data; and
  • how you can manage and control your data.

By using the Lottery services, including the website, mobile app and by phoning the customer service centre (the “Lottery Services”), you are understood to have read this Privacy Policy and agreed to us using your data in accordance with this Policy. 

Please note that we update our Privacy Policy from time to time, so we recommend that you take a fresh read through every so often.

1. Why we collect data

The main reasons we collect and use data are:

  • to provide the Lottery Services (for example, to enable online purchase of lottery tickets, to set up and operate the player accounts and to process payments);
  • to comply with our legal and regulatory responsibilities. Examples of these are:
    • verifying the accuracy of the data collected from you, including checking that, as a participant in the Lottery, you are 16 or over;
    • checking that the debit or credit card linked to your player account is being used by the authorised account holder;
    • monitoring your participation in the Lottery and paying out prizes;
    • deliver responsible gambling;
  • to carry out research, conduct surveys and obtain feedback from you;
  • to help optimise your use of the Lottery Services, to give you a good user experience and to personalise your use of the Lottery Services, and our communications to you;
  • to help us monitor and improve our Lottery Services (by analysing your use and experience of the Lottery Services);
  • to help us understand more about you and the products and services you are interested in by building up a picture about you from your account information and your use of our Lottery Services.
  • to tailor the communications you receive; and
  • to send you product information, offers and promotional messages about the Lottery and our Lottery Services.

Knowing more about you helps us to understand our consumers better, and means we can tailor our communications with you accordingly.

2. What data do we collect?

We collect:

  • your name, email address, address (including postcode) date of birth and telephone number;
  • your debit or credit card or bank account information;
  • information that you add to your profile page (such as gender);
  • details about your use of our Lottery Services, including for example, the frequency of your visits, the time you spend on our Lottery Services;
  • your IP address;
  • location data from your IP address,
  • browser type, operating system and platform and location data; and
  • information and communication on social media or other forums about the Lottery Services.

3.When do we collect data about you?

We collect personal data and other information about you when:

  • you register and access the Lottery Services;
  • you access your player account; and
  • you correspond with us on social media, via phone, email or otherwise.

We also combine information that you give us (and that we collect from time to time across different parts of our Lottery Services) with information that is publicly available and/or that we receive from other reputable sources who have obtained your permission to do so.

4. What we do with the data

4.1       Security

The security of your player account is important to us. We have technical and operational security policies in place to protect the data we collect, use and store, against unauthorised access or disclosure, improper use, alteration, unlawful or accidental destruction or loss. 

Any data on our Lottery Services that identifies you will be encrypted at all times whilst in transit over the internet. We use Secure Sockets Layer (“SSL”) technology, a special protocol that automatically encrypts any data sent by you on our secure pages.  Our server then reads the data using a private key.  This means that your data, be it debit or credit card data or any other personal details, is turned into a code that can only be decoded with the private key or password.  If your browser is suitably configured, you will receive a warning message when you first access any secure page on the Lottery Services.  This is simply information to advise you that the website is protecting your data.

Please be aware that the sending of information through the internet is not completely secure.  We do not guarantee the security of your data transmitted to and from the Lottery Services over the internet, and you accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have been negligent.  For your own privacy protection, we encourage you not to include sensitive information (such as financial information) in any email or text communication you may send to us.  

It is your responsibility to keep your login details secure.  If you suspect or know that someone else has had unauthorised access to your player account, you must tell us promptly and change your user ID and/or password.  

4.2       Sharing of your data

We share your data in the following circumstances:

  • when we carry out identity and due diligence checks as required by law. The credit reference agency we use is Callcredit Limited PO Box 491, Leeds LS3 1WZ;
  • when we engage data processing companies, from time to time, to help manage your data. These companies must comply strictly with our instructions and we do not permit them to further use or share your data.  We also require them to have appropriate technical and operational security measures in place;
  • when you register for, and otherwise access our Lottery Services we share your data with STV Central Limited, one of our group companies, who delivers digital media services (“STV”). STV will store and use your personal data on our behalf, and in accordance with our instructions, for lottery advertising activity as well as for its own purposes.  We and STV will share data to enable profiling of users and to provide more relevant advertising and other customised communications across our respective services.  A copy of STV’s privacy policy is available here: scottishchildrenslottery.com/privacy-policy;
  • to process your financial transactions and pay any prize winnings.
  • if you enter or take part in one of our competitions we will share some of your details with the prize donor or competition sponsor where we have your permission to do so;
  • where we are required by law or regulation to do so, and/or to protect the rights, property, or safety of the Lottery, STV ELM, our customers, or others (which may include steps taken arising from a breach of our Terms of Use);
  • with the Charities for the purpose of facilitating the Charities’ compliance with any regulatory reporting requirements around promotion of the Lottery;
  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

4.3       Marketing & other communications

When you register with our Lottery Services you will receive service emails about your player account, together with any important information about the Lottery Services.

Where you have agreed, we will also send you promotional messages about the Lottery.  We will keep you up to date by sending you emails and e-newsletters from time to time.  We may also communicate with you by phone, text or post.  All communications from us will be clearly marked as being sent by STV ELM on behalf of the Lottery and will include information that will enable you to stop the promotional communications at any time, if you wish to do so.

Where you have agreed, STV will also send you marketing emails (which may include ads) featuring information about STV programmes and services. These emails will be clearly marked as being sent by STV. 

You have the right to ask STV and/or STV ELM not to process your personal data for marketing purposes. Please see the paragraph below titled “How you can manage and control your data” for details of how you can opt-out of this process.

4.4       Cookies

Our Lottery Services use cookies and similar tracking devices to operate, personalise and enhance their performance and to distinguish you from other users.  

There are three main types of cookies.  Some cookies are necessary to allow us to provide our Lottery Services, other cookies enable specific functions, for example, recognising that you are already logged in, and other cookies are known as targeting cookies. Targeting cookies collect behavioural information that we combine with other data we hold about you, which we could use to serve adverts and marketing communications which are likely to be of interest to you.  

We will provide a list of all cookies we apply to our Lottery Services on request, and for more information on the types of cookies we use, what we use them for and on how to manage your cookies, see our Cookie Policy:  www.scottishchildrenslottery.com/cookie-policy.

4.5       Telephone calls

If you phone our customer service centre, your call may be recorded. We use these recordings for training and quality assurance purposes. Recordings can also help us to resolve queries quickly.

5. How you can manage and control your data

You can manage your privacy settings, email preferences, update your personal details and change your password at any time through your player account.

Incorrect information:  You should ensure the data we hold about you is accurate and up-to-date.  If you believe it isn’t, please send an email to us at contactus@scottishchildrenslottery.com, together with details of the current data and the updated data.  We may ask you to provide sufficient proof of your identity before we can make the requested changes.  If your sensitive data (such as financial information) is not up-to-date then please make the relevant changes to your player account. We recommend that you never send financial information to us by email.

Marketing:  You can update and change your e-newsletter subscription selections and opt-out of receiving marketing communications from us and or STV at any time by going to your player account and updating your profile page.

You can also opt-out of receiving our and or STV e-newsletters or other email communications by following the link contained at the bottom of the relevant emails or by contacting us at contactus@scottishchildrenslottery.com.  You should note that even if you opt out of marketing communications, we still need to be able to contact you with customer servicing information, or operational information about your player account or the Lottery.  This means that you will not be removed completely from our mailing / contact lists.

Cookies:  When you access our Lottery Services you are asked to give permission for cookies.  To find out more about how you can change and manage cookie settings at any tim, go to www.scottishchildrenslottery.com/cookie-policy.  Please note that some of the system functionality will not work if you disable cookies that are strictly necessary. To find out more about how to manage and delete cookies, visit www.allaboutcookies.org.uk.   To opt out of being tracked by third party advertising, otherwise known as online behavioural advertising, visit: www.youronlinechoices.com/.

Record keeping:  We will hold your personal data on our systems for as long as you use the Lottery Services and for a reasonable length of time after you close your player account.  The law requires us to keep financial information for seven years.

Subject Access Requests:  You can ask us whether we hold personal data about you at any time, and can request a copy of it.  Please contact our Customer Service team to get a copy of the Data Access Request Form.  Please send the completed form, along with the required proof of identity (detailed in the form), and a £10 administration fee to us at:

e-mail: contactus@scottishchildrenslottery.com

6. Links to Other Sites

To enhance your experience when you are using our Lottery Services, we may provide hyperlinks to third party websites with their own privacy policies.  When you click on a hyperlink and go to another company’s website, you should be aware that it will be their privacy policy that will apply to their use of your data, and not ours. We have no control over their websites or applications and do not accept any responsibility or liability for these policies.  Please check the policies before you submit any information to them.

7. Contact Details

e-mail: contactus@scottishchildrenslottery.com






Issue date: October 2016