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Privacy Policy

Eire Lottery Privacy Notice

 

About this Privacy Notice

At Eire Lottery we take the protection of Personal Data seriously. In this Privacy Notice we’ll explain what Personal Data we collect from you, how we use and share that data, how we keep your Personal Data safe, and how long we keep it for. We’ll also explain how we Process your data (and the Legal Basis for doing so) and help you to understand your Personal Data Rights.

Any questions

If you have any questions about this Privacy Notice or would like additional clarification, please contact our Customer Experience Team at info@eirelottery.ie or call on 01 5725775

What do we mean by Personal Data?

Personal Data is any information that could be used to identify you. That could be anything from your name and address, your bank details, your email address, an image or recording of you, your IP address or any other data that could be used to identify you. Occasionally we collect and process another type of Personal Data called Special Category Personal Data.

What do we mean by Special Category Personal Data?

Special Category Data is Personal Data of a sensitive nature. We only collect Special Category Data in specific circumstances. Normally this would be if you ask to self-exclude from gambling and where you choose to share information with us about your gambling habits. As a responsible lottery we use data about your exclusion status and play behaviour to make decisions about whether participating in the Lottery is in your best interests. If we have concerns, you will be unable to play.

What do we mean by Processing your Personal Data?

Processing Data simply means doing something with your Personal Data. That could be as straightforward as collecting it or sharing it, or as complex as modelling the data or appending values to the data. If a company or organisation does anything with your Personal Data, they are Processing it.

The Personal Data we collect

We collect your Personal Data when you register to play, when you contact us online through the “Contact Us form” on the website, through live webchat and where you interact with us on social media like Facebook.

The Personal Data we collect when you join

We collect the following Personal Data when you join the lottery:

• Your name

• Your date of birth

• Your email address

• Your full address

• Details of your chosen payment method and how many tickets you’d like to play with

• Any contact information you provide like your email address and phone number

We may ask you how you heard about us. This helps improve our marketing. If you tried to join online but didn’t complete the process, we may try and contact you by email for up to one month to see if we can help you sign up. We will keep your data for analytical purposes for twelve months, after which your Personal Data will be erased if you have not joined.

The Contact Us form

You can get in touch with us using our online Contact Us form. You can select a topic and write your comments on the form. To help us with your query we ask you for your name, email address and telephone number. If you tell us that you're a player, we'll ask you your security questions to ensure we’re talking to the right person.

If you’re an Eire Lottery player, we’ll keep a record of your query as part of your player records (see Correspondence). If you’re not a player (and never have been) we’ll erase your query after a maximum of twelve months unless we have a legal obligation to retain it.

Social media

We operate pages on Facebook, Instagram and Twitter. If you are a user of those services you can contact us publicly or in a direct message and share information with us on those pages if you wish to. We won’t ask you for any Personal Data on the open forums of any social media account or discuss details of your account but our team will be more than happy to call you back, send you a private message or email you. We use posts on social media to analyse customer service issues that may be affecting our customers and to ensure that we are dealing efficiently with such issues. We may also use pseudonymised individual comments in our reporting to highlight specific issues affecting our customers and our reputation. We will keep a record of that information for 12 months.

 You should be aware that this retention only applies to the records we keep it doesn’t apply to retention of the data on the social media platform which will separately apply retention to the data in line with its own policies.

If you’re an Eire Lottery player and you engage in a private discussion with us on or off social media, we’ll keep a record of your query as part of your player records (see Correspondence). If you’re not a player (and never have been) we’ll erase your query after a maximum of 12 months unless we have a legal obligation to retain it.

Where you interact with us on social media, Personal Data may be collected by the platform provider with whom you have an account who may use it independently from us. We have no control over, and accept no liability for, how they use your Personal Data. You can access more information about how they use data gathered from their websites here:

Competitions and Prize Draws

When you enter one of our draws online we will keep a record of your email address. When you enter a competition we keep a record of the information on the entry form. We store this data until the winners name is drawn or someone is identified as a competition winner. We use the details of those that enter only to administer their entry and distribute a prize if they are a winner. We do not share the details of entrants with third parties. Winner’s names may be used to make an announcement on Social Media at conclusion of the competition or draw.

We ask our winners to provide a postal address so that we can issue their prize to them. When using social media platforms, you should familiarise yourself with their Privacy Notices and how they use your data, for more detail see Social Media.

What do we do with your Personal Data?

In this section we'll explain how we Process your Personal Data and the Legal Basis for doing so. We'll also explain what a Data Controller and a Data Processor is. We have tried to use plain English wherever possible but it is important you understand what these legal terms mean.

What is a Data Controller?

Eire Lottery is a Data Controller. That means we're responsible for determining what happens to the Personal Data we collect, including how we Process it. As a Data Controller we're also responsible for monitoring and approving the Data Processors we pass your Personal Data to.

What is a Data Processor?

Eire Lottery Use Data Processors to provide Personal Data Processing services. A Data Processor carries out Processing on behalf of a Data Controller. We might employ the services of another company to carry out Data Processing for us. As an example we (the Data Controller) might ask another company (the Data Processor) to send you an email or letter. We’d need to give that company your contact details so they know where to send the letter.

What is a Legal Basis to collect and Process Personal Data?

Under GDPR (the General Data Protection Regulation) there are a number of Legal Bases that a Data Controller can use to Process or share Personal Data.

The Legal Bases Eire Lottery rely on to Process Your Personal Data Consent

Consent means you've given us clear and informed permission to Process your Personal Data. Consent is a Legal Basis to Process Personal Data. An example might be where you have asked us to send you promotional materials. Remember, you can withdraw your Consent at any time.

Our Contract with you

When you play the lottery you enter into a contract with us. A contract is a Legal Basis to Process Personal Data. As a player we have several contractual obligations to you. These include (but aren't limited to) processing your monthly payments, paying out prizes, and informing you of important news about our service and your account.

Legal and Regulatory

Sometimes we have a Legal or Regulatory obligation to Process your Personal Data. These are Legal Bases to Process Personal Data. That might include conditions relating to our operating licence (issued by the Gambling Commission) and to other relevant laws.

Legitimate Interest

Sometimes we have a Legitimate Interest to Process your Personal Data. Where we use Legitimate Interest to Process your Personal Data we'll ensure that our Legitimate Interests are proportional and the information contained in these documents is confidential and intended for the recipient only. 

We do not compromise your Personal Data rights. You can object to us Processing your data for Legitimate Interests at any time. In some circumstances we may continue to process your Personal Data using Legitimate Interests where we can demonstrate that our interests override your Right to Object to Processing.

How we Process the Personal Data we collect

Your name and contact details. You need a valid Irish Eircode to play Eire Lottery. You can read more about valid Eircodes in our T&Cs. We use your name and address for the following reasons.

Address verification

When you register we verify your address using a postcode validation tool provided by a third party Data Processor.

Managing your account

You’re playing Eircode is your ticket. We use your name and address and eircode to manage your account and conduct our lottery draws. We have a Contractual obligation to do this.

Correspondence

We use your name, address, email address and telephone number to communicate with you. We will only send you Service Messages (important messages that relate to your account). We may send other messages where you have actively given Consent for us to do so. Remember, where we use your Consent to send you messages you can withdraw that Consent at any time. We may also use your telephone number to contact you about your account. All players receive Services Messages as part of our Contractual obligation to manage your account. We also like to send our players free birthday ticket and messages. We use Legitimate Interest to send you these messages. You can ask us not to send you birthday messages by contacting our Customer Experience Team.

While you play

We will retain records of all correspondence we've had with you. This might include telephone calls, emails, letters, webchats, and chats via our social media channels. This helps us manage your account, improve our services, and deal with any queries or complaints that may arise.

If you’re a lucky winner

We may contact you to invite you to an event to celebrate your win. We use a third party Data Processor to help us prepare those invites and they keep those records for no longer than three weeks.

If you no longer play

We may contact you for up to 24 months after you cancelled to ask if you’d like to start playing again.

We use Legitimate Interest to Process your Personal Data in this way. You can get in touch if you'd prefer not to be contacted about re-joining and we’ll remove your details from our re-joining list. Please note that if you're removed from our re-joining list you may still receive marketing materials from us that is not targeted using Personal Data.

If you have been removed from our re-joining list or it has been more than 24 Months since you stopped playing, we have Legal Regulatory obligations to keep records of your account for seven years but all other Processing will be restricted.

We check to ensure you’re not an excluded player and undertake other related checks, some players choose to self-exclude from play for a time. You can read more about self-exclusion in the Self-exclusion section of our website or by calling our Customer Experience Team on 01 572 5775. We process data to check players’ exclusion status and we also process information to identify and protect potentially vulnerable people or people who can't play the lottery. We may check your details against a publicly available Government sanctions list and exclude anyone on the list from playing.

We have a Legal obligation to provide the Gambling Commission with information relating to exclusions, Duty-of-Care and those on our blocked play list which may include Personal Data. This is part of our commitment to Social Responsibility. We Process Personal Data to produce these statistics. Where necessary we will also process data on an ad hoc basis to respond to enquiries about our operations from the Gambling Commission.

Your age

You must be Eighteen years or over to play Eire Lottery. We may validate your age (along with your bank details) when you register to play. We submit a random selection of players’ Personal Data to a Data Processor for additional age verification checks. Taking steps to verify your age is a Legal and Regulatory obligation. We collect your payment details when you become an Eire Lottery player. Accountancy requirements and to allow us to deal with legal claims. Records of complaints by players are retained for 7 years from the date the complaint is resolved.

Other ways we use Legitimate Interest to Process your Personal data

We Process your Personal Data as part of our normal business functions. We have a Legitimate Interest in doing so. Those activities include:

• The operation and testing of our Information Technology systems.

• Admin functions and organisational processes including the provision of insurance for our activities.

• Analysis and monitoring for business planning.

• To meet our Corporate Social Responsibility obligations.

• Communications activity and events administration.

International transfer of your Personal Data

We may transfer some of your Personal Data outside of the EEA (European Economic Area). We will only do that where:

• A country is deemed adequate by the European Commission or it is covered by the Privacy Shield.

• We use standard European Commission approved contracts.

If you have any questions about this Privacy Notice or would like additional clarification, please contact our Customer Experience Team at info@eirelottery.ie or call on 01 572 5775.

Please note that where you interact with us or provide Personal Data to our social media pages using your social media accounts this may result in the processing of your Personal Data outside the European Economic Area by the relevant social media platform. The basis upon which any such Personal Data may be transferred outside the EEA is determined by the platform provider. You can access more information about how the hosts of our current social media accounts use data gathered from their websites here:

• Facebook

• Instagram

• Twitter

The Personal Data we collect and Process when you visit our website

The information contained in these documents is confidential and intended for the recipient only. If you have received this email in error, please advise the sender immediately and delete it. Email is not guaranteed to be secure and can be intercepted and amended. We do not accept liability for any changes to this email after it was sent or for any material transmitted through this email or any attachment. It is your responsibility to scan incoming emails and attachments.

How we monitor your activity on our website

It's important to us that we give our website visitors and players the best possible experience when they use our site. We use a number of tools to help us monitor activity on our website. We use consent as the Legal Basis to collect and Process this data.

How we use cookies on our website

We use cookies on our website. In this section we’ll explain what cookies are, what cookies we use, and how you can disable cookies (and the implications of doing so) should you wish to.

What are cookies?

Cookies are small data files that are downloaded to your computer when you visit our websites. Cookies help us manage how our website operates, understand how you use our websites, and to help us improve our marketing activity. The length of time a cookie is stored on your device can vary depending on the purpose of the cookie.

Functional cookies

Some cookies are necessary to enable our website to operate. These cookies do not rely on your Consent because they are required for the function of our website.

Session cookies

Session cookies are temporary cookies that are downloaded to your device’s temporary memory. They have no expiration date and are typically erased when you close your web browser but some can persist longer. When you continue to browse our website you are giving your Consent to the use of these cookies.

Persistent cookies

Persistent cookies are downloaded to your computer so that when you close your browser they remain on your computer. Persistent cookies have an expiration date. When you continue to browse our website you are giving your Consent to the use of these cookies.

Social media cookies

Where we use third party social media sites these sites may also set analytics cookies which can result in those sites processing data about your visit. How these cookies are set and what information they gather is determined by the social media platforms. They use the information from cookies to provide us with anonymous statistical information about visitors to our pages on their sites. Depending upon your browser settings these cookies may be set on your device this can occur regardless of whether you have an account on the platform or not. We have public pages on Facebook, Twitter and Instagram you can access more information about how they use data gathered from their websites here:

What type of cookies do we use?

Google Analytics

A Google tracking cookie that helps us understand the way visitors interact with our websites to improve our website and services. Provided by Google Analytics Persistent tracking cookie 5 years  https://tools.google.com/dlpage/gaoptout GoogleAnalytics

A Google advertising cookie to help us serve relevant online adverts and to report on our advertising activity. It helps us avoid showing ads to people who have already seen them. Further info Google Session advertising tracking cookie up to 90 days IDE https://tools.google.com/

Facebook Ads Manager

A third party cookie that helps us show Facebook adverts to prospective players and exclude current players from seeing those ads. Provided by Google Analytics Persistent tracking cookie 5 years https://tools.google.com/dlpage/gaoptout

GoogleAnalytics

A Google advertising cookie to help us serve relevant online adverts and to report on our advertising activity. It helps us avoid showing ads to people who have already seen them. Further info Google Session advertising tracking cookie up to 90 days IDE https://tools.google.com/

Google AdWords

This measures visitor behaviour and sales on our website and helps us attract new players using online paid search adverts via Google. Provided by Google Analytics Persistent tracking cookie 5 years  https://tools.google.com/dlpage/gaoptout

Google Analytics

A Google advertising cookie to help us serve relevant online adverts and to report on our advertising activity. It helps us avoid showing ads to people who have already seen them. Further info Google Session advertising tracking cookie up to 90 days IDE https://tools.google.com/

Twitter

A third party cookie that helps us show Twitter adverts to prospective players and exclude current players from seeing those ads. https://help.twitter.com/en/rulesand-policies/twitter-cookies

Reducing current players’ exposure to our online ads

To reduce our current players’ exposure to our Google ads (the promoted text ads you see when you search online), we upload encrypted player email addresses and phone numbers to Google so they can be excluded. That way you won't see ads asking you to play when you already do. We do the same using Facebook lookalike audiences. The Personal Data we send is encrypted before it is sent to Facebook. We also do this for Twitter by encrypting personal data and excluding tailored audiences.

We use Legitimate Interests to Process your Personal Data in this way. If you’d prefer us not to use your Personal Data for this purpose you can ask us not to by calling our Customer Experience Team on 01 572 5775 or by emailing info@eirlottery.ie

Disabling cookies

If you'd prefer not to allow cookies, you can choose to disable cookies via your web browser. Your experience of our website may be compromised if you choose to disable cookies. Disabling cookies varies from web browser to web browser but the links below have instructions for some common browsers.

Please be aware that disabling cookies will disable all cookies in your web browser. If you'd prefer to stop online advertising only you can use ad blocking in your browser. Many web browsers now come with this as standard.

Your Personal Data Rights

Under GDPR (the General Data Protection Regulations) you have a number of Personal Data Rights you can exercise over your Personal Data. We’ll explain those rights and how you can exercise them here.

Your Right to be Informed

We believe it is important that you fully understand what we do with your Personal Data. This is known as the Right to be Informed. This Privacy Notice gives detailed information about the type of Personal Data we collect, how we Process that data, and how we share that data with Data Processors and other Data Controllers. We'll inform you:

• Of your Data Protection Rights

• When we share your Personal Data with Data Processors or other Data Controllers

• If we send your Personal Data outside of the EU

• Of the purpose of and Legal Basis for our Processing

• About the implications of not providing Personal Data we have requested under a Contractual or Legal requirement

• How to withdraw Consent you have given previously

• About any Profiling activity we conduct which results in automated decision making. This is explained in more detail in Your Right to Object to Profiling

• About your Right to Complain to the Information Commissioner

• About the length of time we retain your Personal Data for and the reasons we do

• If we want to change the way we Process your Personal Data we'll inform you beforehand and give you an opportunity to object

If and how we obtained your Personal Data from a third party Consent can be withdrawn if you choose You can withdraw your Consent at any time by calling our Customer Experience Team on 01 5725775 or by emailing info@eirelottery.ie You can also unsubscribe from emails by clicking the unsubscribe link.

Your Right to Correct Personal Data we hold

Although we make every effort to ensure your Personal Data is complete, up-to-date and accurate we recognise that sometimes mistakes happen. You can ask us to correct your Personal Data at any time. This is known as the Right to Rectification. You can ask us to amend your Personal Data by calling our Customer Experience Team on 01 5725775 or by emailing info@eirelottery.ie

Your Right to Access your Personal Data

You have the right to ask for a copy of your Personal Data and any Special Category Data we hold. You can also request copies of any Personal Data and Special Category Data we have shared with our Data.

Personal Data:

  • You'd like to check the details we hold to correct any inaccuracies
  • To ensure we are processing your data lawfully
  • To make a Subject Access Request (SAR). This is a specific request to get a copy of the Personal Data we use, our Data Processors and any joint Data Controllers hold. Data will be provided in a user-friendly secure format.

You can ask us for a copy of your Personal Data by contacting the Lottery's Data Protection Officer at Granby Place, Dublin 1 or by email at info@eirelottery.ie You can also call our Customer Experience team on 01 572 5775 who are happy to help. The more information you provide when you make your request the sooner we'll be able to respond.

We aim to provide the data requested within thirty days but more complex requests may take longer (up to three months). We'll let you know if we believe your request could take longer to respond to than one month.

We won’t charge you for making an access request unless we've already provided the Personal Data you ask for. In those cases we'll provide new information only. We may decline excessive requests or unfounded requests (or charge a small fee to provide the information) but we'll always make it clear why we believe that to be the case. In unusual cases we may decline a request because the data requested contains Personal Data about someone else and we consider that their rights may be compromised by the request.

Your Right to Object to Processing

You might not want us to Process your Personal Data in a certain way or for a specific reason, and can ask us not to where we use Legitimate Interests as the Legal Basis for Processing. What does that mean in plain English? When we're using Legitimate Interests as the basis for Processing your Personal Data, you can ask us not to do this at any time. If we want to continue to process the data, we must be able to show that our continued processing is not detrimental to your interests.

Your Right to Object to Profiling

What do we mean by Profiling? Profiling is the way we use data to better understand our players. Some of this is carried out by us or by our Data Processors. This helps us to provide a better lottery experience and service for our players.

We use data supplied by a third party Data Processor to append data to your Personal Data when you join the lottery. We do this to better understand our players and improve our services. We may also use Profiling for matters such as checking our players are 18 years or over, the identity of our players, and that the bank details that have been provided are correct.

If you'd prefer us not to use your Personal Data for a specific Profiling activity, you can ask us not to by contacting our Customer Experience Team at info@eirelottery.ie or on 01 572 5775.

The more information you provide when you make your request the sooner we'll be able to respond. We aim to provide the data requested within one month days but more complex requests may take longer (up to three months). We'll let you know if we believe your request could take longer to respond to than one month.

Your Right to Access your Personal Data

You can make a Subject Access Request by calling our Customer Experience Team on 01 572 5775 or by emailing info@eirelottery.ie We may ask for additional Personal Data to verify your identity before we release your information depending on the nature of your request.

Your Right to Erasure

We recognise that sometimes you'd rather we erase some or all of the Personal Data we hold. This is known as the Right to Erasure. You might ask us to do this where:

• We no longer need the data for the purpose it was gathered

• You gave us Consent but want to withdraw that Consent

• You object to the automated Processing we carry out

• We have Processed your data unlawfully

• We have a legal requirement to erase your Personal Data

The more information you provide when you make your request the sooner we'll be able to respond. We aim to provide the data requested within one month but more complex requests may take longer (up to three months). We'll let you know if we believe your request could take longer to respond to than one month.

Note, however, that we may not always be able to comply with your request of Erasure for specific legal reasons which we will tell you about at the time of your request. For example, we may decline a request to delete your Personal Data where we still need to retain it to meet our regulatory obligations and we require to retain it in line with our regulatory retention periods.

Your Right to Restrict Processing

You have the right to ask us to restrict the way we Process your Personal Data. You can ask us to restrict the ways in which we Process your Personal Data because:

• You believe the Personal Data we hold is inaccurate and you'd like us to stop Processing your Personal Data until it has been corrected.

• You believe your Personal Data has been unlawfully processed and you would like us to restrict our Processing while we investigate.

• You may not need the Personal Data any more but you'd like us to retain it while a legal claim is in process.

You can ask us to restrict our Processing by contacting our Customer Experience Team at info@eirelottery.ie or calling us on 01 572 5775. The more information you provide when you make your request the sooner we'll be able to respond. We aim to provide the data requested The information contained in these documents is confidential and intended for the recipient only.

Your Right to Move your Personal Data

If you want a copy of your Personal Data that you'd like to give to someone else, you can ask us to give you that data in a common, user-friendly and secure format. We can send your Personal Data directly to you or to a third party you specify. This is known as your Right to Portability. You should be aware that asking for a copy of your Personal Data doesn't mean we'll erase that data unless you specifically ask us to. You can find more about on erasure in your Right to erasure. You can ask us for a copy of your Personal Data by contacting the Lottery's data protection team at Granby Place, Dublin 1 or by email at info@eirelottery.ie or call 01 572 5775.

The more information you provide when you make your request the sooner we'll be able to respond. We aim to provide the data requested within one month but more complex requests may take longer (up to three months). We'll let you know if we believe your request could take longer to respond to than one month.

Your Right to Complain

We pride ourselves on our high standards of customer service. Even with the best intentions and training we recognise that we may sometimes fall short of your expectations. If you are a player and want to complain about the way we undertake activities under our licence from the Gambling Commission, this may be dealt with through our Complaints Procedure, which can be found here.

If your complaint relates to your Personal Data you can contact our office at Granby Place, Dublin 1  or by email at info@eirelottery.ie. If you stop playing Eire Lottery, we will retain your account details for seven years including payment details, personal details, and any correspondence between us and you. This to ensure we have sufficient Personal Data to process regulatory and other complaints and to ensure we meet our legal record keeping obligations.

Your Right to be Informed if your Personal Data is Compromised

In the unlikely event that the Personal Data we hold is breached or compromised in a significant way that would be a high risk to your rights and personal freedoms, we'll contact you without delay to let you know:

• What happened and how it happened

• What data was affected and what that means to you

• What we're doing about it and how you can stay informed

• How you can contact our Data Protection Officer

How we keep your Personal Data safe

At Eire Lottery information security is very important to our business. We are fully committed to ensuring information security, confidentiality, and integrity and we undergo annual security audits by the Gambling Commission.

Our approach to Cyber Security

The exchange of confidential information must be secure in order to prevent access from unauthorized sources. HTTPS works with another protocol, SSL – secure socket layer. The SSL will transport the data safely and securely.

Keeping Card Payments Safe

The payment gateway and merchant services that Eire Lottery use “Authipay” is PCI (Payment Card Industry Data Security Standard) compliant and collect, store and process card information to the highest security standards.

The information you send us online

The methods we use to ensure data is safeguarded while being sent over the internet are industry standard. When information reaches us we store it securely and only provide access to authorised personnel or Data Processors

How we restrict access to your Personal Data

Eire Lottery maintains strict physical, electronic and administrative safeguards to protect your Personal Data from unauthorised or inappropriate access. Personal Data collected by us is stored in secure operating environments that are not accessible by the public. In the unlikely event that an employee or a Data Processor misuses that information they will be liable appropriate legal and disciplinary sanctions.