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Racehorse Lotto Privacy Policy

INTRODUCTION

Racehorse Lotto is an associated brand of, and operated by, Furlong Gaming Limited (registered in England & Wales, company number 11906850) (also referred to as "we" or "us"). Furlong Gaming Limited is the controller for your personal data.

Furlong Gaming Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the "Your Legal Rights" section.

Contents

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW AND WHY WE USE YOUR PERSONAL DATA
  4. COOKIES
  5. DISCLOSURES OF YOUR PERSONAL DATA TO THIRD PARTIES
  6. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
  7. YOUR LEGAL RIGHTS
  8. CONTACT DETAILS
  9. CHANGES TO THIS PRIVACY POLICY

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This website is not intended for children and we do not knowingly collect data relating to children.

Please read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

INFORMING US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Personal and contact information when you open a Racehorse Lotto account online (or update that information in your account), including your name, email address, phone number, and date of birth.
  2. Details of any conversations that you have with our customer support team or otherwise, including by email, telephone (voice recordings), post and online via webchat, the feedback button or on our social media channels.
  3. Address details for the delivery of any prizes won by you that require physical delivery, or where there is a legal reason to request this from you.
  4. Copies of government issued identity documents you provide to prove your identity (including driving licence and passport) when you are claiming a prize, or where there is a legal reason to request this from you.
  5. Transaction details including payments from you for Racehorse Lotto Prize Draw entries, payments to you (for example prizes) and details of which Prize Draws you have entered and the outcome of those entries.
  6. Payment card information when you make a purchase. Note that your full payment card details are never stored or processed on our servers but only with our fully PCI compliant payment processor.
  7. Personal and contact information, including your image, voice, footage (and any other information that identifies you) when contributing to our advertising and/or media content, assuming you have signed an appropriate consent/release form.
  8. Information about how you use and interact with our website, and which website(s) you came to the Racehorse Lotto website from.
  9. Technical information about your device or browser when you use our website, including geolocation data to determine what country you are accessing our website from, your internet protocol (IP) address, device ID, browser type and version and time zone setting, which may in some circumstances be personal data.
  10. We may also receive personal data directly from you or from various third parties and public sources, such as social media channels (if you interact with us through those channels), or other third parties used to verify age/identity. In particular, we receive information about your social media handle on Facebook.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW AND WHY WE USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

How we use your personal dataWhy we use your personal data

We use your personal and contact information to register you as a new customer.

We collect financial information if you register payment card information to your account to facilitate faster subsequent payments or to set up a subscription. Note that your full payment card details are never transferred or stored by our systems, only by our fully PCI compliant payment processor.

Performance of a contract with you.

We may use technical information such as the location or time zone from which you access our website, the personal details you provide at account set up and, where relevant, any identity documents you have provided to check whether you are eligible to enter our Prize Draws.

When you set up your account we may use an automated process to verify that the details you provide are correct and to verify you are over 18, and that you are a UK resident.

Necessary to comply with a legal obligation.
We may require copies of documents to verify your identity where we are required by law to provide assistance or in order to comply with any request you may make regarding a Racehorse Lotto account.Necessary to comply with a legal obligation.
We use the personal and contact information provided by you and the transaction details about your purchases, to provide our prize competitions, games and other services to you.Performance of a contract with you.
We use your personal and contact information, financial information, and transaction details about your Racehorse Lotto purchases, to manage your Racehorse Lotto account, to contact you if you've won a prize, and to pay those prizes.Performance of a contract with you.
We use your personal and contact information to contact you if you've won a prize, and to pay (or facilitate payment of) those prizes.Performance of a contract with you.
We use the personal and contact information provided by you, copies of your communications with us and, in some circumstances, transaction details, to manage our relationship with you.

Performance of a contract with you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to keep our records updated and to study how customers interact with our prize competitions).

We may use the personal and contact information you have provided to ask you to take part in market research or a survey in order to improve our website and service.Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).
We may use your personal and contact information, transaction details, and financial information as part of a Prize Draw or competition (including to enter, take part and pay any prizes due as part of that Prize Draw or competition).Performance of a contract with you.
We use information about your use of our website, together with technical information about your device and (in some circumstances) your personal and contact information, and other relevant information that we receive from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant website content and other direct marketing to you on various channels, including on social media platforms, and to manage the delivery of that content.

Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our website).

Your consent.

We use information about your use of our website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising and its relevance).
We use information about your use of our website and technical information, including about your device or where you are accessing our website from, to optimise our service and to improve our website, games, services, direct marketing, customer relationships, behaviour profiling and experiences.Necessary for our legitimate interests (to measure the interactions with our website, to define types of customers of Racehorse Lotto prize competitions, how customers interact with the prize competitions, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
If you win on a Racehorse Lotto prize competition, we may use your personal and contact information to contact you to arrange support.Necessary for our legitimate interests (to manage our winner services).
We may use your personal and limited contact information in any publicity materials or events, provided that you have given your consent.Your consent.
We may use your personal data in marketing and/or media content where you have agreed to and signed a consent form, including in advertisements, customer communications and in any other marketing content, across all media.Necessary for our legitimate interests (to consider and/or to publish your use of our website).
We may use your personal and contact information, financial information, information about any transaction between you and us, copies of your communications with us (including voice recordings), information about your use of the website, or technical information, in order to undertake analysis for the purposes of identifying and dealing with any fraud or fraudulent activity.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent).

We may use your personal and contact information, financial information, information about any transaction between you and us, copies of your communications with us (including voice recordings), information about your use of the website, or technical information for the purpose of dealing with any request, complaint or query from you.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests (to respond to you and to deal with any request you may have).

We may share your personal and contact information, information about any transaction between you and us, information about your use of the website, or technical information with our partners subject to your consent.

Your consent.

We may share your personal and contact information, including name, address, phone number, email address and copies of government issued identity documents, information about any transaction between you and us, information about your use of the website, or technical information with our prize indemnity insurance partners to ensure that you are a legitimate winner. This will only be required if you win the Jackpot prize.

Performance of a contract with you.

Necessary to comply with a legal obligation.

We use your personal data to create aggregated data sets. You are not identifiable from that aggregated data and it is not considered personal data.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

MARKETING

We will ask for your consent before sending you any marketing messages via email, SMS or other communication methods when you create your Racehorse Lotto account. You have the right to withdraw consent to marketing at any time by contacting us at the details provided below or by following the opt-out links on any marketing message sent to you.

You can also ask us to stop sending you marketing messages by logging in to your Racehorse Lotto account and modifying your contact preferences.

4. COOKIES

We use cookies and similar technologies to recognise you, your browser and your device. A cookie is a very small text document, which often includes an anonymous unique identifier. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server. Find out more about the use of cookies on www.allaboutcookies.org.

We also use other forms of technology (such as pixels and web beacons) which serve a similar purpose to cookies and which allow us to monitor and improve the website and our email communications. We use these in connection with cookies to help operate our websites and email communications and collect information about online activity. When we talk about cookies, this term includes these similar technologies.

We also allow carefully selected third parties to use cookies while you are browsing our website.

There are four main types of cookies and technology. Here's how and why we use them:

Strictly necessary cookies

These are cookies that are required for the operation of our website. Without these cookies, you will not be able to use some functionality on our website, such as signing into your account.

Performance cookies

With your consent, we use these cookies to collect information about how you use our website and help us improve the way our website works by making it easier for you to navigate to and complete various tasks.

Functionality cookies

These cookies allow us to identify whether you are logged into your Racehorse Lotto account and to remember choices you make and your preferences, in order to improve your experience of our website. We use these cookies with your consent.

Advertising cookies and pixels

Our carefully selected media partners place third party cookies, pixels and ad tags onto our website on our behalf, where you have consented. These cookies record your visit to our website, the pages you have visited, the links you have followed and actions you perform on the site. We use this information to make our website, and the content displayed on it, more relevant to you. They are also used to limit the number of times you see certain content, as well to measure the effectiveness of our digital advertising campaigns. We may share this analytics information with third parties for these purposes. You can opt out of these cookies and still continue to use the website using your browser settings.

Below is a list of our main partners that may place cookies, pixels or other similar technology on your browser or device when visiting our website:

Partner nameWhat their cookies are used for
GoogleGoogle Analytics is a web analytics platform that allows your interactions with the website to be measured. The cookies are used to identify you as a distinct user.
FacebookThe Facebook cookie allows us to record your actions after you have seen or clicked on an ad in order to measure its effectiveness and to serve you with targeted ads based on your visits to our website.

5. DISCLOSURES OF YOUR PERSONAL DATA TO THIRD PARTIES

We sometimes share the data we collect from you with the following trusted third parties:

  • Banks and payment providers – to set up a recurring payments on your account, to pay prizes to you and to obtain payment of any amounts due to us.
  • Prize indemnity insurers – for the verification of your eligibility to win any prize for which we have prize indemnity insurance. This only applies if you win the Jackpot prize. This may entail your information being transferred outside of the EU. This will be made clear to you at the time.
  • Our IT system providers – in order to provide software to set up your player account, to communicate with you via webchat and other communications providers and to provide our systems to us, including for the purposes of hosting, support and software licensing.
  • Marketing service providers – to allow us to send email communications and notifications.
  • Marketing agencies – for the purposes of providing you with relevant advertising or marketing on our website or on social media, including for the purposes of undertaking behavioural modelling for that purpose.
  • Social media platforms – for the purpose of targeted advertising.
  • Online survey companies and market research agencies – to undertake surveys and other market research and to analyse the results.
  • Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.
  • Public relations agencies – for the purposes of managing external communications about us and our winners.
  • Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.
  • Police or other such regulatory authority – as part of an investigation or otherwise for legal or regulatory purposes.
  • Dispute Resolution agencies – for the purposes of dealing with any complaints.
  • Credit reference agencies – for the purpose of checking the details that you have provided us with are correct.
  • Security companies and research institutions – for the purposes of security, including prevention and detection methods, for the protection of Racehorse Lotto.
  • Auditors – to audit our systems and transactions for the purposes of ensuring efficiency, or regulatory or contractual compliance.
  • 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.
  • In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
  • We will also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety or of our players, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

7. YOUR LEGAL RIGHTS

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don't have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with us – or our data protection officer – using the details set out below. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

8. CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our data protection officer DPO in the following ways:

Full name of legal entity: Furlong Gaming Limited

Email address: dpo@racehorselotto.com

Postal address: Elsley Court, 20-22 Great Titchfield Street, London, W1W 8BE

9. CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review. Any changes that we may make to our Privacy Policy in the future will be posted on our website. Where appropriate, we will notify you of the changes when you next visit our website, or via email.

This Privacy Policy was last updated on 9th March 2020.