About make a smile lottery

Privacy Policy

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 hello@makeasmilelottery.org.uk

Who are we?

We are make a smile lottery, 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.

What is personal data?

We may collect personal data about you when you join our lottery, when you contact us, or otherwise give us personal data. We may also receive your data from your cause partner, or third parties engaged by us to contact our current and potential supporters.

What type of information is collected about you as a player?

  • This might include your name, address, email address, phone number, date of birth, I.P. address, photo or video image (e.g. CCTV at partner sites), video recording and financial information such as credit card details (“Personal Data”).

  • We will ask for your date of birth when joining with make a smile lottery, as we are unable to offer a lottery product to anyone under the age of 18.


Why we process your personal data?

We will only collect, use, and process your personal information where we have a legitimate purpose for doing so. This includes using 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) and to provide you the information, support and products that you request.

  • To make you aware of other lottery products or details of more chances to win.

  • To provide you with lottery news and service information.

  • We may also use your Personal Data for administrative purposes, to let you know about changes to our services or policies.

  • To create a profile of your interests and preferences.

  • To send you communications about our work and the work of our partners and how you can help them to help you, for example, information about their campaigns, volunteering and fundraising activities.

  • 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 together with 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 respect your rights of privacy and are happy to provide further information about any Personal Data 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 Personal Data information that we may hold about you and/or update your preferences in relation to communication of direct marketing or fundraising.

  • 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.

  • We will not transfer your information outside the European Economic Area without your prior consent.


Our lawful basis for processing your personal information

When we process your data in order to provide you with lottery services, our lawful basis is the UK General Data Protection Regulation (GDPR) Article 6(1)2, ‘contract’. When we send you electronic marketing, we will do so using consent under Article 6(1)1. If we market to you by post, our lawful basis will be Article 6(1)6, ‘legitimate interest’. We may also rely on Article 6(1)3, ‘legal obligation’ when we process information under tax or employment law or to comply with the requirements of our regulators.

Where our lawful basis for processing your information is consent, you have the right to withdraw that consent at any time.

If you are an employee and we process your medical information, we will do this on the basis of (UK) GDPR article 9(2)b, ‘… obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law…’ or 9(2)h, for the purposes of ‘preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems…’.

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.

  • The right to be informed about the collection and use of your personal data (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 of your information erased.

  • The right to request the restriction or suppression of your personal data.

  • The right to data portability (allowing you to obtain and reuse your personal data for your own purposes across different services).


You have the right to object to us processing your personal data.


Volunteering with us

If you volunteer with us, we will collect your name and contact details. We may also collect medical information where required. We may also take still images of you or video footage using Closed Circuit Television (CCTV) on some hospice sites for security purposes.

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, any criminal record, and certain medical information. You may appear in still images or video footage using Closed Circuit Television (CCTV) that is used on some hospice 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.

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 website not managed by us.

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?

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. Examples of these sub-processors include canvassers, marketing companies, software providers, website providers and so on.

  • The cause you have chosen to support with your lottery membership, and they will notify you of their data protection arrangements.

When we engage third party service providers in connection with our legitimate business purposes set out above, in providing them with your data we will enter into data processing agreements to ensure the data is only processed in accordance with our instructions and on a confidential and secure basis.

We may change our suppliers of IT solutions, and this may involve transferring all or some of the data we hold from one IT system to another, which means the data may pass via a third party or be held or stored on our behalf by a new third-party provider.

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.

When you join, make a smile 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 contact you by mail and phone about new products, more chances to win or lottery news and services. We would prefer to send some of this information by email or SMS text, as it is more cost effective, we will therefore ask for your permission to send this information by email and SMS text. 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.

The cause you are supporting will contact you by mail with updates and news on their work. We will ask you to give consent to receive this information by email and SMS text. You may change your communication preferences for this charity at any time by contacting 0300 303 4500, sending an email to - hello@makeasmilelottery.org.uk; or by logging onto ‘My Account’ on the make a smile website.

Data retention

We will retain your information for such time as is reasonably required to enable us to fulfil the purpose for which it was collected and associated purposes (including dealing with future related follow up or complaints against us) or as long as the law requires. In some circumstances we may retain and process limited information in order to ensure ongoing compliance with your request to remove you from our databases.

Please contact us on 0300 303 4500 or hello@makeasmilelottery.org.uk, if you would like a copy of the 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 Data 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 Data, make a smile lottery cannot guarantee the security of any information you transmit to us and you do so at your own risk.

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

If you're under 18

In some circumstances we may need to know if you are aged under 18 and may refuse certain services, products or events.

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 4, 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/email/

Changes to this policy

We may amend our privacy policy from time to time, so please check back every so often for updates.
This policy was last updated August 2021.