Last updated 24.07.2020
Addition of ID Scan capability, by consent, in new version of the app. Addition of market research with respect to Good Causes
Last updated 24.07.2020
Addition of ID Scan capability, by consent, in new version of the app. Addition of market research with respect to Good Causes
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.
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.
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.
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.
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 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 for the purpose of protecting the confidentiality, integrity and availability of your personal data.
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 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.
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.
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.
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.
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:
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.
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 Subject Access Request link.
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.
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, you do so by first giving your consent. This is a voluntary process for ID Verifying your account. Your ID image is deleted within days of the verification process
Legitimate interest (prior to registration):
Sharing of personal data
PLI shares personal data with:
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 compare your facial image versus a supplied ID, where you choose to use the ID Scan feature.
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, you do so by first giving your consent. This is a voluntary process for ID Verifying your account. Your ID image is deleted within days of the verification process
Legitimate interest:
Sharing of personal data
Personal Data is shared with the same organisations as outlined in the Player Registration section above.
In addition, PLI shares email address, first name, surname, age and gender with third party market research companies who carry out player satisfaction and market research surveys on PLI’s behalf.
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.
Legitimate interest:
Sharing of personal data
Personal Data is shared with the same organisations as outlined in the Player Registration section above.
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:
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.
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:
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:
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, TV (via Winning Streak/Lotto Draws), retail & PR.
The data will also be used to contact and respond to Good Cause Awards entrants as appropriate.
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:
Note: The EU-US Privacy Shield imposes obligations on U.S. companies to protect Europeans’ personal data. The Privacy Shield requires the U.S. to monitor and enforce data protection measures, and to cooperate with European Data Protection Authorities.
| 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 |
| Second Chance Database | 12 months |