We are dedicated to protecting the privacy of everyone who joins our lottery. This statement explains what personal information we collect from you, how and why we process it, whom we share it with, and how long we keep it. It also explains the steps we take to keep data secure and your rights. 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 hello@makeasmilelottery.org.uk.

Who Are We?

We are make a smile lottery (MAS), owned and administered by St Helena Hospice Limited (Company No. 1511841) (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.

Your personal information will be jointly controlled by MAS and your Chosen Good Cause. Should they terminate our contract to provide their lottery service, we will transfer your personal information to them; however, we will offer you the opportunity to opt out of this if you wish. You should also consult their Privacy Notice for more information.

What is Personal Information?

We may collect personal information about you when you join our lottery, when you contact us, visit our website, or otherwise give us personal information. We may also receive your data from your Chosen Good Cause, or third parties engaged by us to contact our current and potential supporters.

What Type of Information is Collected About You as a Player?

• Personal and contact information when you open an account with us or update it, including your name, address, email address, phone number, date of birth, photo.
• Financial information, such as bank and credit card details.
• Details (and copies) of your communications and interactions with us via letter, email, telephone, or online webchat.
• Transactions details, such as number of tickets purchased, and prizes won.
• With your consent, your image (including video) or voice and correspondence if you consent to take part in our promotion of the mas lottery.
• If you visit our website, we may record your device Internet Protocol address, browsing history, usage of our website, browser type and version, country, and time zone.
• If you visit our offices, we may record your image via CCTV.

Why Do We Process Your Personal Information?

We will always process your personal information in line with data protection legislation and only for the purposes of running our Lottery. These purposes are:

• To verify your identity and age and check your eligibility to play our lottery. This is necessary for compliance with a legal obligation.
• To supply the lottery products you purchase and provide you with support and information about your account and our service to you. This is necessary for the performance of our contract with you.
• To process your financial information. This is necessary for the performance of our contract with you.
• To communicate with you about other, similar lottery products or details of more chances to win. We rely on your implied consent to do this, and you may opt out of these communications at any time.
• To create a profile of your interests and preferences. This is necessary for our legitimate interests (to understand our customers’ behaviour, and improve our games, service, and business).
• To send you communications about St Helena’s work and that of your Chosen Good Cause, and how you can help them; for example, information about their campaigns, volunteering, and fundraising activities. We will only do this with your explicit, prior consent and you can opt out at any time.
• We may occasionally use desk research and profiling to identify potential lottery players and help us better understand our current lottery players. Such information is compiled using information you have provided together with publicly available data. External sources could include Companies House, social media platforms, and newspaper articles. We will always ensure that any research or profiling is done in a way that does not unreasonably or unexpectedly intrude on your privacy. This is necessary for our legitimate interests (to understand our customers’ behaviour, and improve our games, service, and business).
• We may use your personal and contact information, financial information, transaction information, website usage data and technical information to deal with complaints or for fraud detection and prevention. This is necessary for our legitimate interests (to respond to complaints) and to comply with a legal obligation.
• We may use copies of your communications with us to train our staff. This is necessary for our legitimate interests (to ensure that we can provide the best service to you).
• If you contact us about a technical issue with our website, we may use your information for troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data. This is necessary for our legitimate interests (for running the Lottery, maintaining administration and IT services, security, and fraud prevention) and to comply with a legal obligation.
• We may use your image, video recordings of you or personal information given in an interview to promote our lottery. We will only do this with your prior consent.
• We may use your personal and contact information, financial information, account information, website usage information or communications with us to comply with our legal and regulatory obligations, including reporting aggregated data to the Gambling Commission. This is necessary to comply with a legal obligation.

Your Data Protection Rights

Under (UK)GDPR, you have the following rights, which may be subject to exemptions and limitations depending on our lawful basis for processing a particular piece of information. You can exercise any of these rights by contact MAS using the contact details given at the bottom of this notice.

• The right to be informed about the collection and use of your personal information (through this Privacy Notice).
• The right to know what information we hold about you (via a subject access request).
• The right to correct inaccurate information (rectification).
• The right to have some or all your information erased.
• The right to request the restriction or suppression of your personal information.
• The right to data portability (allowing you to obtain and reuse your personal information for your own purposes across different services).

You have the absolute right to ask us not to use your personal information for direct marketing.

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.

You can switch off cookies in your browser preferences but doing so may result in a loss of functionality when using our website. To see how we use cookies, and what they are please see our Cookies Policy page. This page also includes instructions on how to disable cookies if you don’t want them to be used.

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 websites not managed by us and you should consult their terms and conditions for more information.

Social Media

You may be able to share content on social media channels via our website; e.g. Facebook, LinkedIn etc. The respective social media provider will directly gather any personal information provided and you will need to refer to the privacy policy of the social media provider to find out about what information is collected and how it is used.

Who Has Access to Your Information?

MAS and your Chosen Good Cause will have joint control of your personal information. We will only share your personal information, in compliance with data protection legislation, with the following:

• Payment providers – for taking payments and prize disbursement.
• IT system providers – to provide the electronic systems to us that we use to run the lottery and manage your account with us.
• Marketing service providers – to allow us to send email communications and notifications and conduct promotional campaigns.
• Social media and video streaming platforms – for the purpose of targeted advertising.
• Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.
• Professional advisers including lawyers, bankers, auditors, and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.
• The Gambling Commission – for legal and regulatory purposes as required under our licence to operate our Lottery.
• UK law enforcement agencies and 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 other third parties to comply with any legal or regulatory obligation or request. We do this to protect our rights, property or safety of our players, or others.

Whenever we engage a third party to process your data, we ensure they are bound by a data processing agreement, so your personal information is processed only on our instructions and for no other purpose We update our processors from time to time but will update this notice when we do.

We may disclose your information to a person to whom we propose to transfer our rights and/or responsibilities under any contract with you or to whom we transfer our business or a relevant part of its business, for example: to a separate subsidiary company. Such a person shall be entitled to process your data in the same manner set out in this policy.

Marketing

Make a smile lottery and your Chosen Good Cause may contact you with information about more ways to win and different lottery games. You can opt out of these communications at any time.

Make a smile lottery and your Chosen Good Cause may want to contact you with opportunities to donate, fundraise, get involved in events or receive e-newsletters. We will do this only with your explicit consent.

You may of course change your communication preferences at any time by contacting us on 0300 303 4500 or hello@makeasmilelottery.org.uk. Or by logging onto ‘My Account,’ on the make a smile website.

Data Retention

We will only keep your personal information 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. Full details are provided in our Data Retention Policy, which is available on request.

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) and used for research or statistical purposes.

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

Please contact us on 0300 303 4500 or hello@makeasmilelottery.org.uk, if you would like a copy of our Data Retention Policy.

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 hello@makeasmilelottery.org.uk.

Security

Make a smile 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 debit 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, MAS cannot guarantee the security of systems not administrated by us, and you use them at your own risk.

All our staff have regular training and have signed confidentiality agreements.

To keep your information safe, we are accredited with Cyber Essentials, a Government backed scheme protecting against cyber-attacks, and submit to an annual independent external audit to ensure we comply with the Gambling Commission’s Remote gambling and software technical standards.

If You Have Any Concerns or Complaints

You have a right to log 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 (owned by St Helena Hospice)
Unit 6, The Atrium
Phoenix Square
Colchester
Essex
CO4 9AS

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
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate)
https://ico.org.uk/global/contact-us/

Changes to this Privacy Notice

We may amend our privacy policy from time to time, so please check back every so often for updates. We will also make good faith efforts to notify our users of important changes.

This policy was last updated November 2023.