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, 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?
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. We may also receive your information from your charity 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 hospice sites), video recording and financial information such as credit card details (“Personal Data”).
• 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.
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 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. 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.
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 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 charity 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.
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.
- The charity 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 transfers our business or a relevant part of its business, e.g. to a separate subsidiary company. Such a person shall be entitled to process your data in the same manner set out in this policy.
Your email and/or SMS text consent is important
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 email@example.com.
The charity 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 or firstname.lastname@example.org.
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.
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 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 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 Data, 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 (owned by St Helena Hospice)
Unit 6, The Atrium
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 May 2018.