- the types of information we collect and how we collect it;
- the ways in which we use, share and protect that information;
- the choices you have in controlling the collection of your information; and
- your ability to access and update your information.
Information Collection and Use
There are two types of information that we obtain from you, and then store and use:
- non-personal information that’s collected automatically; and
- personal information that you voluntarily provide to us.
We do not collect any personal information from you when you visit our site or our authorized features and apps, unless you expressly and voluntarily participate in an activity that asks for it and you voluntarily provide it. To put it another way, FOR US TO HAVE ACCESS TO YOUR PERSONAL INFORMATION, YOU HAVE TO MAKE A CHOICE TO KNOWINGLY GIVE IT TO US.
Nothing Personal: Automatically Collected Information
When you visit or use our services or interact with us, basic information is passively collected through various means, including through your web browser via use of tracking technologies such as “cookies”, “web beacons,” “clear gifs,” and the like, that utilize, among other means, simple text files sent from our servers to your device. The information we collect through these means is not personal information and does not individually identify you. It includes things like:
- the domain name and IP address from which you accessed our site.
- the type of browser and operating system you use.
- the date and time and length of your visit.
- the specific page visited, graphics viewed and any documents downloaded.
- the specific links to third party content you accessed from our website.
- the specific links from other sites you used to access our site.
Uses of Information
We use voluntarily provided personal information, for example, to answer questions or respond to requests; to conduct promotions; to send news and marketing messages; to comply with our legal obligations; and for any other lawful purposes. We do not sell or rent your personal information.
We use non-personal information to administer and improve our site, and to make business decisions about what content our players and Retailers might like.
Now it’s Personal: Voluntarily Submitted Information
If you participate in certain activities through our website, then you may need to provide us with information about yourself. For example, if you choose to send us an e-mail, enter a promotion, fill out an on-line form (such as a request to have customer service speak to you, or a request for more information about becoming a retailer), or participate in a player survey or fill in job application form, then you are voluntarily providing personal information to us. In doing so, you are giving us your consent to collect, retain, use, and disclose that information in the ways we describe in this policy.
We may use voluntarily provided personal information (such as e-mail addresses, the content of e-mail, text messages, and phone numbers) to communicate directly with you on a one-to-one basis; to operate a promotion, giveaway, and to contact the winners; to verify information, such as age eligibility; to customize our promotional and giveaway pages with more relevant news and information; for our internal marketing and product development purposes; and for any other lawful purpose.
We may also use personal information as otherwise described to you at the point of collection, pursuant to your consent. We do not sell, rent, or trade personal information with third parties. If you don’t want us to collect your personal information, then don’t provide it! This means you shouldn’t participate in the activities offered through our website that request or require it. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the website, but it will not affect your ability to access important information.
Your Privacy Choices
You do not have to provide personal information to enjoy most of the contents/features of our sites. You also can opt-out of certain activities like newsletters and announcements by sending us an opt-out e-mail.
A Choice you can make: Opt Out
If we are using personal information you provided to receive materials from us, such as newsletters, promotions, and program announcements, via text or e-mail, and you decide you don’t want to receive such materials, then you may opt out by sending an e-mail to us with your name, e-mail address, and/or mobile phone number (as applicable) to [email protected]. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. This information remains part of our records and may be available even after you opt out.
Please understand that communications may not stop immediately. Additionally, if you continue to separately submit forms to us or take surveys after you opt out, then you will be voluntarily submitting your personal information through those separate means.
Things Happen: We do what we can to ensure Information Security
We will take all reasonable security precautions to protect your personal information provided through our services. Due to the inherently open and somewhat risky nature of the Internet, however, we cannot guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction or alteration will not occur. We disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. You should also note that third party companies that help us operate and maintain both our services and our corporate technology environment (for example, a service provider that sends e-mails on our behalf) will have incidental access to your information, including your personal information, as part of the work they perform, and we cannot guarantee or be responsible for their practices.
Data collection, retention & disclosure
You understand and agree that Lottotech Ltd including its clusters shall, for the performance of its obligations hereunder, collect and where necessary or required, process and store personal information which the you hereby voluntarily discloses to it (the “Personal Data”) for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. Lottotech Ltd has a legal obligation to store basic information about its customers. Lottotech Ltd undertakes to treat the Personal Data confidentially and securely in line with the provisions of the Data Protection Act 2017, (DPA) as amended from time to time.
We will only retain your information for as long as is reasonably necessary to carry out the purposes outlined above and to satisfy our legal obligations.
As an existing customer, we will need to retain your information to meet our legal and contractual requirements. However, when you stop using our services, it is necessary to retain your personal information for a minimum length of time required to:
· Comply with legal obligations under local laws (for example, Gambling Regulatory Act and Anti-Money Laundering regulations).
· Establish or defend legal claims (for example negligence claims) which could be made against us.
Any information will be stored for a period of up to five (5) years as per requirements of the Gambling Regulatory Act.
Certain data relating to financial transactions can be stored for a maximum period of seven (7) years from when you stop using our services based on other relevant laws.
Lottotech Ltd undertakes not to reveal or otherwise disclose the Personal Data to any external body, unless:
- it obtains your consent or;
- to comply with our legal and regulatory obligations and commitments, including those relating to responsible gaming and anti-money laundering;
- the Personal Data is disclosed to any agent, service provider, professional adviser or any other person under a duty of confidentiality towards Lottotech Ltd.
- you expressly acknowledge and agree that the Personal Data may be shared with its clusters to provide you with information about products that may be of interest to you.
Pursuant to the provisions of the DPA, you acknowledge that you have in relation to your Personal Data which is in the custody or control of Lottotech Ltd, the right:
- to access to, to request rectification and erasure;
- to object to the processing;
- to withdraw consent at any time, without affecting the lawfulness of processing based on the consent which you had provided prior to your withdrawal.
Data Sharing and Transfer
By voluntarily submitting information through the website, you consent to Lottotech Ltd to disclose your personal data to:
a) its clusters (whether within or outside Mauritius) and other parties which intervene in the business relationship.
b) subcontractors, suppliers or agents on the understanding that they will keep your personal data Confidential.
c) any person who may assume or acquire our rights; or
d) where required by law or regulation.
You expressly acknowledge and agree that the foregoing disclosures may require that the Personal Data be transferred to parties located in countries which do not offer the same level of Data Protection as in Mauritius.
Where you have consented to receiving marketing materials from us, Lottotech Ltd or any other entity within the group may use your information to inform you by telephone, text message, e-mail, SMS or other electronic messaging services or letter of any products or services which may be of interest to you.