We are committed to protecting the privacy of everyone who joins our lottery. This statement explains what personal data we collect and process, how we collect it, whom we share it with, and why we do so. It also explains the steps we take to keep data secure. If you have any questions about this privacy statement or our privacy and data processing in general, please contact us on 0300 303 4500 or at firstname.lastname@example.org
Who are we?
We are make a smile lottery, owned and administered by St Helena Hospice (Charity No. 280919), a charity that supports people with incurable illness in the north Essex area. Our registered office address is: Myland Hall, Barncroft Close, Highwoods, Colchester, CO4 9JU
What is personal data?
By personal data we mean any information that might allow you to be identified, such as your name, address, date of birth, postal address, email address, credit card or bank account details, I.P. address, photo or video image or voice recording.
We may collect personal information about you when you join our lottery, when you contact us, or otherwise give us personal information. Our current lawful basis for collecting personal information is contained within Schedules 2 and 3 to the Data Protection Act (1998).
What type of information is collected about you as a player?
- We use your personal information to give you the information, support and products that you ask for. This might include your name, address, email, phone number, date of birth, I.P. address, photo or video image and financial information such as credit card details.
- We will ask for your data of birth when joining with make a smile lottery, as we are unable to offer a lottery product to anyone under the age of 16.
- We may also use your information for administrative purposes, to let you know about changes to our services or policies, to create a profile of your interests and preferences and, if you agree, we may also use your information to send you communications about our work and the work of our charity partners and how you can help them to help you, for example, information about their campaigns, volunteering and fundraising activities.
Volunteering with us
If you volunteer with us we will collect your name and contact details. We may also take still images of you or video footage using Closed Circuit Television (CCTV) on some charity sites.
Working for us
If you apply for or take a job with us, we will store your contact information, bank details, and keep records of your employment history. You may appear in still images or video footage using Closed Circuit Television (CCTV) that is used on some charity sites for security purposes.
Using our website
If you use our website, we will store data about your internet browser, I.P. address, the timings of your visits, and a record of which pages you looked at.
Use of 'cookies'
Like many other websites, the make a smile lottery website uses ‘cookies’. Cookies are small files stored on your computer that allow websites to recognise you when you visit. They store data about your browsing history but will not identify you as an individual. This helps us to improve our website and deliver a better more personalised service.
By using our website and services you agree to be bound by the terms of this statement.
Links to other websites
The make a smile lottery website may include links to other sites, not owned or managed by us. We cannot be held responsible for the privacy of information collected by website not managed by us.
How we use your information
We may use your information for any of the following:
- To process and provide the lottery product you have purchased (we will only collect information from you that we need to in order to process your lottery membership)
- We may occasionally use desk research and profiling to identify potential lottery players and help us better understand our lottery players. Such information is compiled using information you have provided and publicly available data. External sources could include Companies House, social media platforms, and newspaper articles
- We always seek to ensure that any research or profiling is done in a way that does not unreasonably or unexpectedly intrude on an individual’s privacy. We also endeavour to make sure that in accordance with fair and lawful processing requirements under current legislation, individuals are made aware of the purposes for which we may collect and process their personal data at the earliest reasonable opportunity.
- We respect your rights of privacy and are happy to provide further information about any Profile details that we may hold about you in accordance with your data subject access rights under current legislation.
- In accordance with those rights, you may also at any time request that we update, correct or delete any Profile information that we may hold about you and/or no longer use it for direct marketing or fundraising purposes.
- We collect personal data about job applicants and employees for administrative purposes and in order to comply with employment and safeguarding legislation, such as referrals to the Disclosure and Barring Service.
- We collect personal data from our volunteers for administrative purposes and to comply with safeguarding legislation, such as referrals to the Disclosure and Barring Service.
Who has access to your information?
We will never sell or swap your details with third parties unless you agree. We may share the data that you provide, with trusted third parties, for the purposes of carrying out the lottery operation and who are authorised to act on our behalf. These include subcontractors and agencies, our regulators and law enforcement authorities, who are themselves bound by the relevant Data Protection legislation- the Data Protection Act (1998). We share your data with the charity you have chosen to support with your lottery membership if you agree. In these circumstances we always require strict compliance with our instructions and, in the case of third party organisations, require that your personal information is not used for their own business purposes.
Your consent is important
When you join make a smile lottery will contact you via post, email or telephone with regards to ‘administering’ your lottery membership. This may be a welcome communication, welcome call to check your details, and any reason we need to contact you with regards to processing your membership, and processing/sending you any prizes.
We will ask you what types of communication you would like and how you would prefer to be contacted and you may withdraw at any time by contacting us on 0300 303 4500 or email@example.com.
We will also ask you if you are happy to hear from us about how your lottery membership is helping to support the charity and for direct marketing consent in either of the following ways (post, email, text, phone). This could include a thank you call with information about how your lottery membership is helping your chosen charity, we may ask if you would like to take out a second lottery number or we may try and reinstate your lottery membership if you have lapsed or cancelled. For direct marketing communications like this, we collect data only with your explicit consent, which you may withdraw at any time.
We will also ask you if you give consent for us to pass your details to the charity you are supporting with your lottery membership, and if they can contact you by email, post, text or telephone, with your consent. The types of communication you may receive will be updates on the charity news, fundraising events and newsletters and you may withdraw at any time.
In the case of sensitive personal information, we will ask you to indicate your express consent in allowing us to use it, which may involve one of the following methods: giving us your permission verbally; ticking a box; clicking an icon; sending an email; submitting a form; or subscribing to a service. When we seek your consent to using your personal information, we will tell you what we want to use it for and, other than as described in this policy, we won’t use it for any other purpose.
You have the right to withdraw your consent at any time by contacting us on 0300 303 4500 or email firstname.lastname@example.org
Accessing and updating your information
We care about the accuracy of the information we hold about you. You can ask us what information we hold about you by contacting us If you believe any information about you is incorrect or out of date, please contact us on 0300 303 4500 or email us at email@example.com
make a smile lottery takes your security and privacy seriously. When we collect your personal information we use a variety of technical processes to prevent unauthorised access including firewalls, digital surveillance, and encryption. Any sensitive information you send to us (such as credit card details) will be encrypted. Non-sensitive details (such as your email address or your image) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we try to protect your personal information, make a smile lottery cannot guarantee the security of any information you transmit to us and you do so at your own risk.
If you're 16 or under
In some circumstances we may need to know if you are aged 16 or under and may refuse certain services, products or events unless we have your parent/guardian’s permission.
Your right to lodge a complaint with a supervisory authority
If you believe that we breached your privacy in any way, we urge you in the first instance to contact our Data Protection Officer at:
Data Protection Officer
Make a smile lottery (owned by St Helena Hospice)
9 The Courtyards
If you remain unsatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office at the address below:
Information Commissioner’s Office
Tel: 0303 123 1113 (local rate)
01625 545 745 (national rate)
Changes to this policy
This policy was last updated September 2017.