Last updated: 21.04.2021 Version: 2.1
1. Data controller and data protection officer
2. Categories of information and the purpose of our processing
2.1. Information you provide
2.2. Information necessary for you to be able to use our services
2.3. Information used for marketing
3. Information sharing
3.1 Sharing your personal data within the group
3.2 Sharing your personal details with third parties
4. Transfers of personal data outside the EU
5.1. Social media
5.2. Links to other websites
5.3. Surveys and competitions
5.5 Winner notifications and leaderboards
6. Data retention
8. Your rights
10. Contact details
2.1.Information you provide
We may process information that you provide us with to fulfill our legal obligations, including, but not limited to, the General Data Protection Regulation 2016/679 and the 5th Anti-Money Laundering EU Directive 2018/843. This type of processing is necessary for us to comply with the law. The following types of personal data may be processed:
- Your personal number;
- Contact information such as name, date of birth, address, email address, phone number;
- Official documents such as passport or ID, these may include a photo of you;
- Communication history, for instance, your communication with our customer service through email or live chat;
- We may also process anonymized behavioral data and provide it to third party research organizations with the aim of preventing gambling-related issues; and
- Other information needed for us to comply with our legal obligations.
We reserve the right to confirm your personal data without prior notice and without giving any reason. This is due to regulatory obligations that require us to confirm your identity and is done by collecting your personal number through a third party, unless you have provided it yourself. You have the right to oppose such verification. This can be done by contacting our customer service via live chat or [email protected]. Your account will then be closed in accordance with our general terms and conditions.
2.2.Information necessary for you to be able to use our services
We may process information that we need in order to provide you with our services. Our lawful basis for the processing of this personal data is to fulfill our contract with you regarding the delivery of our services. The following types of personal data may be processed:
- Username, IP address, browser type, demographic information and geo-location information from your device and/or hardware, referring/exit pages, and operating system;
- Device ID, installed software, cookies and in-game information;
- Financial information and billing information such as credit card number, name of credit card holder, expiry date on credit card, billing address, bank name and bank account number; and
- Other information needed to deliver our services.
2.3.Information used for marketing
We may also process information in order to provide marketing material. Our lawful basis for the processing of this personal data is our legitimate interest in marketing our products and services for the pursuit of our commercial and business objectives. The processing will not take place in a way that violates your personal rights or freedoms. The following types of personal data may be processed:
- Information linked to your subscription to our email list such as name, surname and email address; and
- Information linked to your subscription to our phone list such as name, surname and phone number.
Opt-out from marketing: You may at any time choose to update your preferences and options in "Newsletter settings" under "My account" on our website, or contact our customer service on live chat or [email protected].
We may share your personal data with other companies that are within the same group as EuroLotto, with companies that provide services to you on our behalf, help us deliver our services and/or help us with our business operations and with other parties in the course of complying with our legal obligations. Furthermore, we may share personal data if we enter any kind of merger, acquisition or business sale, as customers' personal data generally is included in the sale or transfer. In this case, you will be notified via email and/or through a clear announcement on our website. We have a contractual relationship with all of these companies to ensure that your personal data is always treated as confidential, protected with appropriate security measures and prevents these companies from using your personal data for their own purposes.
3.1 Sharing your personal details within the group
We may share your personal data within the group for the following puposes:
3.2 Sharing your personal data with third parties
We may share your personal data with third parties for the following purposes:
• Provide you with products and/or services;
• When required by law, such as following a court order or similar legal process;
• To fulfill our legal obligations to the licensing and regulatory authorities, as well as to fulfill our obligations in accordance with applicable legislation and relevant authorities in other jurisdictions;
• When we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or obey an authority request;
• In order to establish, exercise or defend our legal rights;
• To provide you with our services;
• With external auditors;
• When we work with third party organizations to identify cases of match-fixing;
• If it has been preceded by your consent, or if we deem it reasonable and necessary. In this case, the lawful basis for the processing is legitimate interest and the processing will not take place in a way that violates your personal rights or freedoms; and
Your personal data may be disclosed to countries outside the EU/EEA . In these cases, we take all reasonable legal, technical and organizational measures to ensure that the level of protection for your personal data is at the same level as in the EU/EEA. This is done by, among other things, using standard contractual clauses or binding corporate rules. We only enter into contractual relationships with third parties that guarantee a comparable standard of data protection to EU/EEA countries.
5.1 Social Media
If you choose to communicate via social media, the information you provide is linked to your personal social media account. These social media platforms have their own privacy policies, you must contact them directly in order to exercise your rights or request the deletion of communication between you and us on the platform in question.
5.2.Links to other websites
5.3.Surveys and competitions
We may periodically offer you the opportunity to participate in competitions or surveys on our website. If you participate, we may, in some cases, ask you for certain personal data. Participation in these surveys or competitions is completely voluntary and it is up to you if you choose to disclose any personal data.
We post customer testimonials/comments/reviews on our website, these may contain personal data. We collect consent via email prior to the posting of the testimonial. To request removal of your personal data from testimonials, comments or reviews, please contact us at [email protected].
5.5. Winner notifications and leaderboards
We may post winner notifications, leaderboards and similar notices on our site. For anonymity purposes, your name will be censored. These notifications and messages may be connected to specific games and/or campaigns, please see our Terms and Conditions and/or the campaign specific Terms and Conditions for more information. If you would like to object to this or reduce the amount of information posted, please contact us at [email protected]
We store your personal data for as long as we need it to fulfill the purpose of the processing, or for as long as we have to store the data according to the law. When your personal data is no longer needed to fulfill the purpose or when the statutory time has passed, we will delete your personal data. However, we may process personal data for statistical purposes. In these cases, we anonymize the data, which means that the information can no longer be linked to you.
If you would like us to close your account, please contact us at [email protected]. Upon the closing of your account, we will only retain and use your personal data if necessary to fulfill our legal obligations, resolve disputes or enforce our agreements.
We aim to achieve the highest possible level of security and privacy and we take the security of your personal data seriously. For us, it is very important that you feel secure in our processing of your personal data and we take appropriate measures to protect your personal data from unauthorized access or other undue processing. To achieve a high level of security, we apply appropriate organizational, technical and physical measures.
You have the following rights with respect to the processing of your personal data:
- Right of access: you can request to know if we are processing personal data relating to you and request a copy thereof;
- Right to rectification: you can request to have your personal data corrected. The easiest way to do this is to make the necessary changes in the "My Account" section;
- Right to object: you can object to our processing of your personal data.
- Right to restriction of processing: you may, in some cases, request a restriction on the processing of your personal data.
- Right to withdraw your consent in cases where we process your personal data based on your consent;
- Right to data portability: you can request that we transfer your personal data to another data controller. You will then receive your personal data in a structured, commonly used and machine-readable format.
- Right to erasure: you can request that we delete your personal data. Although you have the right to have your personal data deleted, in some cases we cannot delete the data in its entirety, due to legal requirements to retain certain personal data for a specific period.
- Right to lodge a complaint with a supervisory authority.