Data Privacy Statement of PLI

Last updated 26.05.2022

Update to allow for the sharing of customer contact details with research companies for the purposes of conducting surveys relating to responsible play and gambling awareness. Updates regarding our responsible play programme and play pattern profiling. Addition of Bank of Ireland Payment Acceptance (BOIPA) for the purposes of processing card payments. Addition of Mkodo for website development and design services.

Who are we?

Premier Lotteries Ireland DAC (PLI) is the operator of the Irish National Lottery. PLI was awarded a 20-year licence to operate the National Lottery by the Irish Government in February 2014 and commenced operations in November 2014. PLI is based in the National Lottery headquarters building on Abbey Street Lower, Dublin 1.

About this statement

PLI is the controller of personal data collected and processed from visitors and players using the National Lottery’s website and apps.

This Data Privacy Statement is designed to demonstrate our firm commitment to privacy and to inform you of the personal data that we collect and process in connection with your use of the National Lottery website and apps.

It also sets out details of what personal data we process, why we process it, with whom your personal data is shared, and a description of your rights with respect to your personal data.

This Data Privacy Statement will be reviewed from time to time to take into account changes in the law and the experience of the Data Privacy Statement in practice.

What personal data do we process?

To comply with our obligations under the National Lottery Act 2013, which includes an obligation to prevent underage or problem play, we will collect and process information about you referred to in this Data Privacy Statement as ‘personal data’.

This personal data will include your account registration details and your on-site activity including transactional details. If you become a player and you later close your account, we are required by our licence to maintain a record of your account so we can meet our legal and regulatory obligations.

Your personal data is primarily obtained directly from you at the point of player registration or while you browse the website and when you play.

In addition, our website uses cookies to distinguish you and your preferences from other users of the site. This helps us to improve your experience when you browse our website and also allows us to improve the website. Follow this link to our Cookie Policy to find out more. The Cookie Policy should be read in conjunction with this Data Privacy Statement as the same data protection rights apply to cookies.

The categories of personal data we process, and the lawful bases for doing so, are set out in detail at the end of this Data Privacy Statement.

How do we use your personal data?

The personal data we hold, process and retain will be used for the management of your account, for administrative purposes, for meeting our legal and regulatory obligations, for ensuring responsible play, and for marketing. We hold it and use it to protect your rights and interests and to manage our relationship with you appropriately, effectively and lawfully. At the same time, it enables us to run our business.

This includes using your personal data to enable us to manage your registration, comply with our legal obligations, pursue our legitimate interests and protect ourselves in the event of legal proceedings.

The uses we make of each category of your personal data, together with the lawful bases we rely on for those uses are set out in more detail at the end of this Data Privacy Statement.

Where there is a need to process your data for a purpose other than those set out at the end of this Data Privacy Statement, or otherwise outlined to you, we will inform you of this and, if required, we will seek your consent.

If you do not wish to open an online account, but wish to participate in retail promotions which require you to enter limited personal data online, this data will be treated in the same manner as set out in this Data Privacy Statement.

If you do not wish to share the personal data required during the registration process, unfortunately you will not be able to use the online services to play National Lottery games.

Premier Lotteries Ireland are certified to the ISO 27001 standard for Information Security Management Systems, and to the World Lottery Association (WLA) Security Control Standard, for the purpose of protecting the confidentiality, integrity and availability of your personal data.

How is your personal data shared?

Your personal data may be disclosed to third parties where we are legally obliged to do so.

It will also be disclosed during activities where we have lawful contractual agreements in place that enable us to operate the National Lottery.

Your personal data will also be disclosed to third parties where we have a lawful legitimate interest to share your data, such as in marketing campaigns, provided that you have agreed to receive marketing information.

Your contact details will also be shared with research companies for the purposes of conducting surveys relating to responsible play and gambling awareness.

Again, you will find more detailed information on how we share your personal data with third parties, and who they are, at the end of this Data Privacy Statement.

Will your personal data be transferred abroad?

The main storage location for your personal data is in Ireland.

We will transfer your personal data to other companies within the EEA for purposes connected with the enhancement of your online experience.

Your personal data will be transferred outside of the EEA during the provision of certain services which are managed and provided by third parties. Recognised data protection safeguards are in place to ensure the security of your personal data where it is transferred outside of the EEA.

Further details are provided at the end of this Data Privacy Statement.

How long do we keep your personal data?

Any personal data that we collect, process and hold about you is retained only for as long as it is required.

However, under the licence to operate the National Lottery, PLI is required to keep certain records, such as financial transactions and the personal data associated with that, for a period of two years after the end of the licence agreement.

For further information regarding mandatory data retention periods, please refer to our Abridged Data Retention Policy at the end of this Data Privacy Statement.

Will you be subject to profiling?

In line with the interests outlined in the information at the end of this Data Privacy Statement, or to comply with the legal obligations of our licence, we carry out profiling and analysis based upon your location data, age, gameplay activity, interests and behaviours for the following purposes:

  • To offer you tailored products and services, and more relevant marketing, such as bringing to your attention similar games to the ones you like to play.
  • To comply with our legal and regulatory obligations such as preventing underage or problem play, prevention of money laundering, prevention of fraud and to ensure the integrity and security of the National Lottery.
  • As part of our programme to ensure responsible play and to protect our players from problem play, your patterns of play and your expenditure will be compared to broad profiles of player types.

What are your rights under data protection law?

You have the following rights under data protection law, although your ability to exercise these rights may be subject to certain conditions and where we are permitted to do so under the terms of our licence to operate the National Lottery.

  • Information Request. The right to receive a copy of and/or access the personal data that we hold about you, together with other information about our processing of that personal data.
  • Update Data. The right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update your data such that it is complete.
  • Data Deletion. The right, in certain circumstances, to request that we erase your personal data.
  • Restrict Processing. The right, in certain circumstances, to request that we no longer process your personal data for particular purposes.
  • Object to Processing. The right to object to our use of your personal data or the way in which we process it.
  • Data Portability. The right, in certain circumstances, to transfer your personal data to another organisation.
  • Review Automated Decisions. The right to object to automated decision making and/or profiling.
  • File a Complaint. You have the right to complain to the Data Protection Commissioner. You also have the ability to complain to us via our Data Subject Access Request link – choose option ‘File a Complaint’.

 

You can contact PLI’s Data Protection Officer at DPO@lottery.ie or by calling the National Lottery on (01) 836 4444.

PLI uses a secure system for handling access rights requests, which is provided by a specialist service provider called OneTrust. If you would like to exercise any of these rights, please contact us via our Data Subject Access Request link.

Details of Processing Activities

Player Registration

Personal data processed

Gender, name, preferred greeting, address, email address, phone number, date of birth, proof of ID, IP address, date and time of registration, payment card, browser, mother’s maiden name, place of birth, emailing preferences, URLs visited, referral URLs, biometric facial image scan versus supplied ID including temporary capture of all fields of the supplied ID.

Purpose for processing and uses of the data

To register a National Lottery Player in compliance with legal & regulatory requirements (living in Ireland, over 18 and responsible player).

To enable your ability to play, PLI requires the storage of your payment card with a nominated third party.

To compare your facial image versus a supplied ID, where you choose to use the ID Scan feature, or if you open an account from 06.12.2021 when it may be mandatory for all new account holders to verify their identity via this means, and after which date current players will be called upon, on a gradual basis, to verify their identity on a mandatory basis.

To send weekly results, inform of large jackpots, to receive information about offers and promotions.

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to complete the player registration.

Consent:

Direct marketing activity is subject to player consent. The player has the clear option to opt-in to receive marketing communications at registration time and then to opt-out any time.

ID Scan facility. Where you choose to use the ID Scan feature to compare your facial image versus a supplied ID, or where you are mandated to do so from 06.12.2021, you do so by first giving your consent. This is a process for ID Verifying your account which new players from 06.12.2021 may be required to undertake, and which current players will be called upon to complete on a gradual basis after this date. Your ID image is deleted within days of the verification process.

If you do not provide your consent for the processing of an ID when you are opening a new account, you may not be permitted to complete the set-up of your account and play online. If you already hold an online account and do not wish to provide your consent to undergo the ID verification process when asked to do so, you will no longer be permitted to access your account and play. Your account may be closed after a period of time.

Legitimate interest (prior to registration):

  • To personalise the website and apps and suggest relevant marketing content, PLI uses your visit history, time of visit, device used and location.
    Balance of data subjects’ interest: PLI uses pseudonymisation and data minimisation.
  • To provide general statistics, PLI uses your visit history, time of visit, browser and device used and location.
    Balance of data subjects’ interest: PLI uses pseudonymisation and data minimisation; reports are generalised and do not identify specific individuals. Logical access controls prevent the identification of individual players.

 

Sharing of personal data

PLI shares personal data with:

  • Camelot Lottery Services (CLS): management of PLI Gaming Infrastructure and 2nd Line Support Services in relation to applications, networks and security.
  • Global Payments (formerly Realex Payments) to process your payment card on behalf of PLI. Global Payments fully comply with the PCI/DSS 3.2 security requirements. Please note that PLI does not store your payment card data. Global Payments’ privacy statement may be found here: https://www.globalpayments.com/en-gb/privacy-statement
  • Bank of Ireland Payment Acceptance (BOIPA) to process your payment card on behalf of PLI. BOIPA fully comply with the PCI/DSS 3.2 security requirements. Please note that PLI does not store your payment card data. BOIPA’s privacy policy may be found here: https://www.boipa.com/privacy-policy-html/
  • Adobe Campaign for marketing campaigns. Adobe Campaign stores personal data in Ireland. See here for an overview of privacy at Adobe.
  • Adobe Analytics to measure the traffic on the National Lottery’s websites. See here for an overview of privacy at Adobe.
  • Adobe Target to run onsite A/B testing and personalisation. See here for an overview of privacy at Adobe.
  • Adobe Launch - The information collected by Adobe Launch is used within our analytics tools to enrich the data we’re collecting about your visit in order to help us understand our visitors’ usage of the site so as to provide a better user experience. See here for an overview of privacy at Adobe.
  • Intralot Ireland Limited (Intralot): maintenance of PLI’s players and retailers handling platforms and retailer terminals. Intralot support engineers are based both on PLI’s premises and in Greece from where they can login using an encrypted VPN channel. All Intralot access is monitored.
  • Cloudflare to protect the National Lottery’s websites against DDoS attacks (Distributed Denial of Service, a type of hacking). This requires personal data to transit through Cloudflare’s infrastructure. This takes place in multiple locations both inside and outside the EEA. The traffic through Cloudflare is fully-encrypted.
  • GBG PLC for comparing a biometric facial image scan versus a state-issued ID document uploaded by the online account holder. GBG will hold an image for a maximum of 31 days if not set to a shorter timeframe by PLI. (https://www.gbgplc.com/uk-privacy-policy/)
  • Google Analytics to measure the traffic on the National Lottery’s websites. See here for an overview of privacy at Google.
  • Firebase to measure the traffic on the National Lottery's app. See here for an overview of privacy at Google.
  • Mkodo (a Pollard Banknote company) for website development and design services.
  • Display Media - DoubleClick (a Google product) offers technology products and services that are sold to Core Media (a nominated third party advertising agency) to allow the National Lottery to deploy, target, deliver, and report on interactive advertising campaigns.
  • Google AdWords - Google AdWords' system is based on cookies and keywords determined by advertisers. Google uses these characteristics to place National Lottery advertising on pages where they think it might be relevant. PLI pays when users divert their browsing to click on the National Lottery advertising.
  • Bing - which is a web search engine owned and operated by Microsoft. Similar to Google AdWords Bing system is based on cookies and keywords determined by advertisers.
  • In case of a complaint, the information may be shared with organisations who provide services to the company such as legal advisors.
  • Office of the Regulator of the National Lottery – the Regulator may access parts of this data in order to assess whether PLI is meeting its obligations to prevent underage or problem play.

 

Ongoing Player Interaction

Personal data processed

Gender, name, preferred greeting, address, email address, date of birth, proof of ID, IP address, date and time of visit, payment card, browser, mother’s maiden name, place of birth, emailing preferences, URLs visited, referral URLs, games played, number played, amounts played, amounts added, amounts withdrawn, wallet amount, page, length of visit, cookies, biometric facial image scan versus supplied ID including temporary capture of all fields of the supplied ID.

Purpose for processing and uses of the data

To play any National Lottery game in compliance with legal and regulatory requirements (living in Ireland, over 18 and responsible player).

To give you access to our website and to distinguish you and your preferences from other users of the site, our website places a combination of Strictly Necessary cookies and other cookies (that first require your consent) on your PC or mobile device.

To compare your facial image versus a supplied ID, where you choose to use the ID Scan feature, or if you open an account from 06.12.2021 when it will be mandatory for new account holders to verify their identity via this means, and after which date current players may be called upon, on a gradual basis, to verify their identity on a mandatory basis.

To enable your ability to play, PLI requires the storage of your payment card with a nominated third party.

To tailor your experience on our digital channels.

To provide weekly results, inform players of large jackpots, and to provide information about offers and promotions.

To conduct player satisfaction and market research surveys.

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to allow the player to play any National Lottery game online.

Consent:

Direct marketing activity is subject to player consent. The player has the clear option to opt-in to receive marketing communications at registration time and then to opt-out at any time.

ID Scan facility. Where you choose to use the ID Scan feature to compare your facial image versus a supplied ID, or where you are mandated to do so from 06.12.2021, you do so by first giving your consent. This is a process for ID Verifying your account which new players from 06.12.2021 may be required to undertake, and which current players will be called upon to complete on a gradual basis after this date. Your ID image is deleted within days of the verification process.

If you do not provide your consent for the processing of an ID when you are opening a new account, you may not be permitted to complete the set-up of your account. If you already hold an online account and do not wish to provide your consent to undergo the ID verification process when asked to do so, you may no longer be permitted to access your account and it may be closed after a period of time.

Deployment of cookies other than those deemed ‘Strictly Necessary’ for the delivery of the requested service, such as access to our website. Follow this link to our Cookie Policy to find out more.

Legitimate interest:

  • To prevent problem-play and personalise the website and apps accordingly, PLI uses recent play history, frequency of play, last win dates, type of games played.
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; ability to object and opt-out of problem-play personalisation.
  • To improve your play experience and personalise the website and apps accordingly, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county).
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; does not use the data of self-excluded players; ability to object and opt-out of personalisation.
  • To improve direct email marketing activity and to suggest relevant marketing content, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county).
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; does not use the data of self-excluded players; ability to object and opt-out of personalisation.
  • To produce statistics, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county), player visit history, time of visit, browser and device used, gender.
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; reports are designed not to include data at individual player level; logical access control prevents access to the data at individual player level.
  • To conduct player satisfaction and market research surveys, PLI shares email address, first name, surname, telephone number, age and gender with third party market research companies who carry out player surveys on PLI’s behalf.
  • To conduct surveys relating to responsible play and gambling awareness, your contact details – first name, surname, telephone number, email address – will be shared with research companies, such as RED C Research, who carry out player surveys on PLI’s behalf.
  • Balance of data subjects’ interest: The personal data supplied will be the minimum possible for each survey; you do not have to take part in such surveys, if you are contacted by the research company; you can choose to opt out of being contacted again regarding similar surveys; if you choose to take part, your responses will be pseudonymised by the research company prior to being supplied to PLI; third party research companies will only hold personal data shared with them for six months; at PLI, the database containing your responses will only be accessible to a very small number of IT specialists where your personal data will be masked at all times; PLI will ensure that appropriate technical and organisational measure are in place so that no unauthorised individuals within PLI will have the capability of linking your responses to your main customer account; your responses and your pattern of play and expenditure will be anonymously added to other similar respondents to create broad profiles of customers and their attitudes and feelings with respect to responsible play and gambling; once broad profiles are created, PLI’s research database will be fully anonymised or deleted; players can review PLI’s Data Privacy Statement prior to responding to a survey. Unless you opt out of future contact, you may be contacted again in the future regarding a similar survey.

 

To Opt-Out of Responsible Play Surveys please email opt_out@lottery.ie

Sharing of personal data

Personal Data is shared with the same organisations as outlined in the Player Registration section above.

PLI shares email address, first name, surname, telephone number, age and gender with third party research companies, such as RED C Research, who carry out player satisfaction surveys, market research surveys, and surveys relating to responsible play and gambling awareness on PLI’s behalf.

Third party research companies will only hold your personal data for six months.

RED C Research’s privacy notice may e viewed here: https://redcresearch.ie/privacynotice/

 

Android and iOS Apps

Personal data processed

Geo-location, name, IP address, phone device ID, device IMEI, platform, purchase total, device OS version

Purpose for processing and uses of the data

Location is required to comply with legal requirements (living in and playing from Ireland).

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to allow the player to play any National Lottery game online.

Consent: Direct marketing activity is subject to player consent. The player has the clear option to opt-in to receive marketing communications at registration time and then to opt-out at any time.

Push Notifications are messages which are sent from the National Lottery mobile app to users who have downloaded the National Lottery App and opted to receive notifications. These notifications can be considered to be both service and marketing in nature. You have the ability to enable or disable push notifications from the National Lottery mobile app on your phone or device at any time. Here’s how:

  • If you are using the National Lottery mobile app on an iOS device, you will be automatically prompted to opt in or to opt out of push notifications when you install the app.
  • If you are using the National Lottery mobile app on an Android device, you will be automatically opted-in to receive push notifications when you install the app. This is normal for Android devices.
  • You can disable notifications by changing the settings for the App on your mobile device.
  • Android Phones: Go to settings and select 'Apps'. Tap on the National Lottery App and then select 'Notifications'. You will be given the option to block all notifications from the app.
  • Apple Phones: Go to Settings, tap on Notifications and select the National Lottery App. You will see the option to allow or disable notifications for the app.

 

Legitimate interest:

  • To prevent problem-play and personalise the website and apps accordingly, PLI uses recent play history, frequency of play, last win dates, type of games played.
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; ability to object and opt-out of problem-play personalisation.
  • To improve your play experience and personalise the website and apps accordingly, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county).
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; does not use the data of self-excluded players; ability to object and opt-out of personalisation.
  • To improve the direct email marketing activity and to suggest relevant marketing content, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county).
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; does not use the data of self-excluded players; ability to object and opt-out of personalisation.
  • To produce statistics, PLI uses recent play history, frequency of play, last win dates, type of games played, location (county), player visit history, time of visit, browser and device used, gender.
    Balance of data subjects’ interest: PLI uses pseudonymisation, data minimisation and limits the data to 18 months of sales history; reports are designed not to include data at individual player level; logical access control prevents access to the data at individual player level.

 

Sharing of personal data

Personal Data is shared with the same organisations as outlined in the Player Registration section above.

 

Customer Support

Personal data processed

Name, email, twitter account, Facebook Messenger account, Instagram account, telephone number, telephone call recordings, instant messages, web chat.

Purpose for processing and uses of the data

To provide assistance to players and to monitor quality of services.

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery.

If the player does not provide the requested data, PLI will not be able to provide player support.

Sharing of personal data

PLI shares personal data with:

  • Camelot Lottery Services (CLS): management of PLI Gaming Infrastructure and 2nd Line Support Services in relation to applications, networks and security.
  • Intralot Ireland Limited (Intralot): maintenance of PLI’s players and retailers handling platforms and retailer terminals. Intralot support engineers are based both on PLI’s premises and in Greece from where they can login using an encrypted VPN channel. All Intralot access is monitored.
  • PLI uses Sprinklr to centrally manage social media interaction with players. Sprinklr is a provider of social customer service software which is used to manage the flow of customer service inquiries and discussions on the National Lottery’s social media channels such as Facebook, twitter, Instagram and YouTube.
  • Zendesk for Contact Centre call management and call recording.
    https://www.zendesk.com/company/privacy-and-data-protection/#gdpr-sub
  • Zendesk uses Twilio Inc for the storage of telephone call recordings. Zendesk Talk lawfully transfers recordings to the USA to a Twilio Inc. data centre hosted by Amazon Web Services (AWS).
    https://www.twilio.com/legal/privacy

 

Winners

Personal data processed

Data collected on the claim form: name, address, date of birth, telephone number, proof of ID (type and expiry date) and signature.

Data collected on a voluntary basis: gender, occupation, and consent for publicity (photographs, video, name, address and any other information as agreed in writing).

Purpose for processing and uses of the data

To comply with legal and regulatory requirements (over 18 and responsible player).

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to pay the player.

Consent: Publicity material is processed on the basis of consent. If consent is subsequently withdrawn, PLI will cease to process this information. However, if this information has been shared with third parties (i.e. the press), PLI will no longer be in control of this data and cannot restrict further processing which is already in the public domain.

Gender and occupation information is gathered on a voluntary basis and used purely for statistical purposes.

Sharing of personal data

Personal data is not shared with third parties.

The form is kept in secure storage for a duration specified in the Data Retention Policy.

If the player, or syndicate, consents to publicity, the name, winnings and imagery may be published on the National Lottery website, via email and social channels and shared with the media (newspapers, radio and/or television stations) as agreed in writing. It will also be archived for future “throwback” marketing purposes.

Once the information has been shared with the media, the information will be in the public domain and PLI will not be able to enforce deletion.

 

Scratch Card Draw Entries & TV Game Show

Personal data processed

Scratch card draw entries: name, address, email address, telephone number and signature.

TV Game Show participants and proxy participants: name, address, date of birth, phone number, signature and type of ID; proxy participant’s name, address & phone number; photographic and TV broadcast imagery.

Beneficiaries of National Lottery funding: video footage of Good Cause funding recipients and their projects.

Purpose for processing and uses of the data

To claim scratch card prizes above a certain value as described in the Game Rules.

To participate on the TV Game Show, or to allow a nominated proxy to participate instead, and for winners to receive prizes.

To publicise the benefits and beneficiaries of Good Cause funding raised by the National Lottery.

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to pay the player. If a potential participant of the TV Game Show does not provide the requested data, the potential participant will not be able to take part in the TV Game Show.

Consent: Publicity material is processed on the basis of consent. Once the information has been released to the media, PLI would not be able to fulfil requests to withdraw consent.

Sharing of personal data

PLI shares personal data with:

  • RTÉ for TV Game Show production purposes
  • KPMG during independent observation of draws
  • General and selected media and press for publicity purposes
  • The public, where limited personal data is publicly announced on the website, and also on the TV Game Show, where the participants drawn for next week’s show are announced.

 

Second Chance Database

Personal data processed

Name, address, date of birth, telephone number, email address, IP address

Purpose for processing and uses of the data

To register a retail or online National Lottery Player’s entry into a second chance draw in compliance with legal requirements (over 18 and responsible player).

To send information about offers and promotion.

The information is used internally by the National Lottery's digital marketing team.

Lawful basis for processing the data

Contractual and legal obligations: The processing of data is necessary to enter into a contract with PLI and to meet the legal and regulatory requirements of the National Lottery Act and the Licence to Operate the National Lottery. If the player does not provide the requested data, PLI will not be able to complete the player registration for the relevant second chance draw.

Consent: Direct marketing activity is subject to player consent. The player has the clear option to opt-in to receive marketing communications at registration time and then to opt-out any time.

Sharing of personal data

PLI shares personal data with:

  • Action Point, who create the website in a National Lottery controlled Microsoft Azure server located in North Europe
  • Google Analytics is used to measure the traffic on the second chance website.

 

National Lottery Good Causes and Awards

The National Lottery was set up with the express purpose of raising funds for Good Causes, with almost 30 cent of every €1 our players spend on National Lottery games going back to Good Causes.

Funds raised by the National Lottery are transferred to the Exchequer and are used to part-finance expenditure by various Government Departments on projects in these categories – Sport, Health, Community, Children & Youth, Arts, Heritage & Irish Language.

Each Government department or body accepts applications for funding on an annual basis and disperses grants accordingly. Each Government department then shares this information with the National Lottery so that we can inform our Players as to what organisations, clubs, voluntary groups etc have received National Lottery Good Causes funding.

Personal data processed

In addition to the name of the voluntary organisation / group, the grant amount and grant purpose, the following personal data is processed: name, address, landline and mobile telephone number, email address, IP address.

Purpose for processing and uses of the data

The data will be used to contact and seek permission from certain organisations, groups and sport clubs all over Ireland to enable the National Lottery to create and produce video stories that will recognise the inspiring and innovative work being carried out.

These stories may be used, with the consent of those involved, as part of our marketing activities and promoted across our consumer touchpoints e.g. Social, Online, National Lottery App, TV, Radio, Retail & PR communications.

The data is also used to contact and respond to Good Cause Awards entrants as appropriate.

The data is also used to enable the National Lottery to print and distribute personalised signage to Sports Clubs and organisations around the country, to acknowledge funding received through the Sports Capital Programme Grant, which is part-funded by National Lottery Good Causes..

Lawful basis for processing the data

Legitimate interest: To inform and educate our players as to where the Good Causes funding goes and highlight the impact this funding has on the various voluntary groups and communities. Also, the processing of data is necessary to enter the Good Cause Awards competition which the company has a legitimate interest in promoting.

Balance of data subjects’ interest: Recognition and awareness of the work being carried out by Good Cause beneficiaries; data subjects have the right to opt out and not take part in promotion of good causes and do not have to enter the Good Causes Awards competition; data subjects have the right to be removed from data bases relating to these promotions.

Sharing of personal data

PLI shares personal data with:

  • Third-party content production companies and creative advertising agencies.
  • Connector, who create and host the website where the competition entries are made. The server is located in North Europe.
  • Third-party market research companies who carry out surveys on PLI’s behalf relating to Good Causes awareness and benefits.

 

Win Awareness – Real Winners’ Stories

For Lottery winners who agree to take part in advertising and promotional campaigns, telling their personal stories.

Personal data processed

Name, address, landline and/or mobile telephone number, email address, IP address, social media accounts, imagery – both photographic & video, voice recordings, video recordings.

Purpose for processing and uses of the data

The data will be used by the National Lottery to create and produce real winners’ stories, including individuals, groups and syndicates from all over Ireland.

The stories will be used as part of the National Lottery’s marketing activities and will be promoted across a variety of media and consumer touchpoints. Examples of these consumer touchpoints include but will not be limited to TV, Radio, Outdoor, Online, Social, Retail, PR.

Winners’ stories will also be used internally by the National Lottery in communications such as our internal newsletters. They will also be included on our Retailer portal, the National Lottery access point for our retail partners.

Lawful basis for processing the data

The processing of this data will be on a contractual basis allowing PLI to use winners’ stories in advertising and promotional campaigns. If a person does not want to provide the requested data, they cannot enter into the contract and their story will not be used for this campaign. If they do provide the requested data, they will enter into a contract permitting the National Lottery to use their story in current and future campaigns.

Sharing of personal data

PLI shares personal data with:

  • Third-party content production companies.
  • Third-party research companies, employed via our creative advertising agency.
  • Creative advertising agencies.
  • Connector, who create and host PLI’s website. The server is located in North Europe.

Abridged Data Retention Policy

Information Type

Retention Period

   

Good Cause Photos/Images

Duration of Licence + 2 years after termination in accordance with Clause 15.3 of Licence

Winning Streak - Winners Bio's

1 year

Winner Images

Duration of Licence + 2 years

Winning Streak PR Release Forms;

Duration of Licence + 2 years

Winner’s information and prize values

Duration of Licence + 2 years

General online player information (including name, address, date of birth, email, phone)

Duration of Licence + 2 years

Online Player Transactions

Details of transactions:
Duration of Licence + 2 years

Users who sign up for promotion / competitions but never play online; (name, email address and phone number)

Delete within 3 months after promotion/competition ends

Customer Care interactions

Open Account: Indefinite

Closed Accounts:
Duration of Licence + 2 years after termination in accordance with Clause 15.3 of Licence, but subject to Data Minimisation

Call recordings Customer Care interactions

7 years

Emails Customer Service contact for Players

Delete within 12 months on closure of account.

Sprinklr Customer Support tool

12 months

Biometric facial image scans and copies of supplied IDs

31 days max

Daily check for duplicated accounts

Duration of Licence + 2 years

Good Causes Awards entrant information

13 months

Win Awareness – Real Winners Stories

Duration of Licence + 2 years

Second Chance Database

12 months