MYRAFFLES365 PRIVACY POLICY

This Privacy Policy sets out how we collect and use your personal information and what your individual data protection and privacy rights are.

This Privacy Policy was last updated on 1st May 2018 and is version 9.0

 

Who is Responsible for Processing Your Personal Data

MyRaffles365 is the online trading name of Fieldgate Solutions Ltd which is the Data Controller. This is the legal entity responsible for how your personal data is collected, stored and processed.

Managing Your Personal Data

When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Therefore, it is our responsibility to manage your personal data that you provide to us with care and in accordance with all data protection legislation and industry best practice.

Whether you have supplied your personal details online, by phone, by email or in a letter, we will never use them without a lawful reason to do so. We will use your personal data for the purposes for which they were initially requested and as fully explained in this Privacy Policy.

It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, if you need to update any other personal details, by ringing our contact centre on 01282 685400.

Using Your Personal Data to Open Your Online Account

When you apply for an online account with us, we will use your personal data to make a decision as to whether or not we will accept your application.  Without this data, we are unable to perform the services under this contract i.e. to ensure we are acting in accordance with the Gambling Act 2005, and in accordance with relevant guidelines and regulation.

When you register to open a personal account, we will hold your personal data which you have provided to us.  When you make a card payment to purchase Raffle Tickets from us, we will not hold any of your card information to process the order. We use PayPal to process your payments.

We will hold your personal data (in terms of transactions on your account) for 6 years, plus the current financial year, after the date of your last transaction on your personal account.

Automated Decisioning -

To make a decision with regards to your application, we use automated decision making based upon your date of birth at the time of application.  By proceeding with your application, you agree to the use of this automated process and acknowledge that without it we are unable to proceed with your application. 

Data security

We take appropriate steps to maintain our contact information in a secure environment to prevent unauthorised use and have an extensive Data Protection Plan in place.  Our developers are bound by contract to do the same.

These steps include regular updates of information, password changes, limited access to our server, anonymising data where possible and reviewing these steps regularly.

In case of a data breach or a high risk of a data breach on our server, we will contact the affected data subjects immediately. We will also notify the data protection authority within 72 hours if there is a likelihood of a risk.

If you have any questions or comments about our Data Protection Plan, please contact our Data Protection Officer at admin@myraffles365.co.uk

Using Your Personal Data to Operate Your Account

We will collect and use the contact details that you provide to us to communicate with you about your account and in relation to the products we provide to you. 

We will use your personal data to operate your Account in the following manner:

  • Your personal data, such as name, postal address and email, will be transferred to our third party processors so they can process and distribute your prizes on our behalf.
  • Details of prizes that you have won will be sent to the email address you provided.
  • Your prizes will be available to view when you log in to your Account online.

It is important that the contact information on your Account is accurate and up to date at all times. If you need to amend any of your details, you can do this online via your Account or by calling us.

If you have opted out of receiving email marketing from MyRaffles365 when registering your Account, or at any other time, you will not receive any email notifications about any new or existing Raffles available to you.  You can still be a part of MyRaffles365 and view all available draws online. You can change your email preferences at any time if you wish to opt back in - see Email Marketing.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your personal credit and cash account.

Newsletters-

Subscriber activity is stored in a database for future analysis and evaluation. Such tracked activity may include but is not limited to; the opening of emails, the clicking of links within the email content, times, dates and frequency of activity.

This information is used to refine future email campaigns and supply the user with more relevant content based around their activity. Subscribers are given the opportunity to unsubscribe at any time through an automated system. This process is detailed at the footer of each email.

Delivering Your Prizes-

We will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering prizes to you.  We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive. 

Processing Refunds-

We use your customer account and contact details to verify any refunds that we.  We will attempt to make refunds by PayPal.  Alternatively we will send a cheque to the address registered on the Account.

Operating Your Account-

We use your personal contact details such as name, postal address, phone number and email address to notify you about any updates, changes or issues with your account.  We may also send you notifications via SMS to notify you if you have limited or no funds in your account.

Links-

If you follow links to other sites from our website your data will be subject to the privacy policies of those sites. You should refer to these policies before providing your data.

Making Payments to Your Account-

We currently use PayPal to process card payments for the MyRaffles365.co.uk site and do not hold any card details. 

Documents via Email-

We will use the email address that you provide to us to communicate with you about your account and in relation to the Raffle tickets we provide to you.  We will send other account information and documentation to you electronically using your email address.  We will hold your transaction data for 6 years, plus the current financial year, after the date of your last transaction.

Enquiries and Complaints-

If you have any complaints with regards to the operation of your Account, please contact us on 01282 685400 so we can deal with your complaint as quickly as possible.  We will need to access your personal data and account history to verify your identity for security reasons and deal with the details of your complaint.  Details of any complaints received will be logged and recorded so they can be dealt with accordingly.

General Service Communications-

We will use your personal data for all general service communications including sending your raffle ticket receipts, statements, notifying you of new raffles, updating you on prize winnings, or any issue to do with your account.  We need to do this for the performance of our contract with you, and the terms and conditions that you have agreed to.

Using Your Personal Data for Direct Marketing Purposes

We use your email address to send you details of our latest products and promotions and do not share them with any third parties.

We hold your personal data for the purposes of direct marketing to you for a period of two years from the date of your last transaction unless you have an outstanding credit balance or have updated your marketing preferences in which case you will continue to receive marketing information unless you tell us otherwise. If you have only ever registered an account but never bought from us, we will stop marketing to you after a period of six months unless you ask to be contacted by updating your marketing preferences.

Obtaining Your Consent-

We will obtain your consent to send you details of new products via Email Marketing at the time you register your details with us.  However, we believe we have a legitimate business interest to keep you informed of our latest promotions, new raffles and prize winners.  You can change your email preferences at any time - see Changing Your Marketing Preferences.

Email Marketing-

We would like to keep you informed about our latest products using the email address you provide to us.  We will also use your date of birth to confirm your eligibility.  To do this, we will ask you to opt-in to receive marketing emails when you first register an account with us.  You can opt out of email marketing at any time - see Changing Your Marketing Preferences.

Social Media-

We use Social Media to keep you informed about our product offers and. We will also use Social Media to promote winners.  Occasionally, we may contact you if we would like to share your comments or pictures with other customers or publish them in our marketing materials.  We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.

Third Party Marketing-

We will not share your personal data with third party companies for the purpose of them marketing their products and services to you.

Changing Your Marketing Preferences-

You can change your marketing preferences for Email Marketing at any time by Clicking unsubscribe in the body of the email sent to you;

You can exercise your right to object to Email and Social Media at any time by:

Please allow 48 hours for your changes to be processed.  You may still receive direct marketing materials that are already processed before we received your request for up to 2 months.

Using Your Personal Data to Improve Your Online Experience

We want to make sure that we only contact you with online content that you will find relevant and interesting.  However, we do not use any aggregated or anonymised data obtained via Cookies and other data sources to help us provide you with relevant product marketing -  we do it all manually!

Cookies

Cookies are small text files that are placed on your computer, with your permission, in order to let websites do important things, including remember what’s in your shopping basket and which pages you have visited.  MyRaffles365 uses only strictly necessary cookies: These do not require consent and are vital to make the website work properly. This category of cookie include those which allow online shopping baskets to function.

Using Your Personal Data for Fraud Prevention

If we identify fraud, we will pass data relating to the fraudulent activity such as name, address and email address to Credit Reference Agencies and other external agencies that are involved in fraud detection to help protect individuals and other businesses from the threat of fraud in the future.

We will hold your personal data for 6 years, plus the current financial year, after the date of your last transaction on your account.

Using Your Personal Data to Improve Our Services

As a valued customer, we may use your personal data to contact you by phone, SMS, letter or email to ask you to participate in one of our service improvement programmes.  We will share your personal contact details with our chosen third party partners and service providers who may carry out these service improvement programmes on our behalf.  We will always make you aware of how we will use the information that we gather from you at the time of contacting you for any specific service improvement programme.  We have a legitimate business interest in contacting our customers in this way and will always treat your involvement in any service improvement programme, and associated personal data, in confidence.

Should you not wish to participate in our service improvement programme, you can simply decline to participate at the point of contact or, should you wish never to be contacted for the purpose of market research, you can tell us at any time by ringing us on 01282 685400

Surveys-

From time to time, we will contact you to take part in a customer satisfaction survey.  We sometimes use third party partners to collect this information on our behalf.  We will share your basic personal data - name, address, phone number and email - for them to contact you to ask if you wish to participate in such surveys. We, or our third party partners, may sometimes follow up on surveys with you to get more information from you regarding specific complaints or feedback.  You can choose not to participate in such surveys should you not wish for your personal data to be shared in this way by ringing us on 01282 685400.

Social Media-

We actively use social media platforms as a way of connecting, and getting closer, to our customers to hear and understand what our customers think about us and our raffles.  Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials.  We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.

Sharing Your Personal Data with Third Party Processors & Partners

As part of delivering our products to you, we will share your personal data with carefully chosen Third Party Processors and Partners who carry out a number of services on our behalf.  Should you wish to obtain a list of our latest Third Party Processors and Partners, you can request this at any time by contacting our Data Governance team.

Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services.  If you have any concerns about any of our third party processors and partners, please contact our Data Governance team.

Acting as a Data Processor for Our Marketplace Partners

We will sometimes act as a data processor for other Lottery Owners whose Raffles are registered on our site.  In these instances, they are the Data Controller.  We may pass your personal data to the Data Controller on request .  When purchasing a Raffle ticket from our Lottery Owners, you will be agreeing to their terms and conditions and their privacy policy.  Please contact the relevant Lottery Owner should you have any questions, comments or complaints about how your data is used.

Your Personal Data Rights

Right of Access-

You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request.  You can do so by ringing, writing to or emailing the Data Governance team. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days.  However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity.

Right of Rectification-

If you believe we have made an error as to the personal data we hold about you, please speak to one of our team on 01282 685400 who will be able to process the correction for you.  Alternatively, you can visit My Account to update your contact details online.  Should you wish to discuss this matter further, please contact the Data Governance team. 

Right of Erasure-

You have the right to request your personal data to be permanently deleted from our records and systems to avoid any further communication with you.  Your request will always be considered in light of the legal bases that we hold, store and process your personal data and the purpose that we collected your data.  Where the legal bases permits, we will carry out your instruction without undue delay.  Please note, however, that where we have a legal or contractual obligation to hold your personal data, we may not be able to carry out your request but we will explain this fully to you.  Please address any request to delete your data to the Data Governance team.

Right to Restrict Processing-

Should you believe that we are processing your personal data in a way that you did not understand or agree to and wish to restrict such processing, please speak to the Data Governance team who will be able to assist you.

Right to Object to Processing-

You have the right to object to certain types of processing of your personal data.  We will always make it clear at the outset of any new arrangement with you how we are going to process your personal data.  Should you wish to object to such processing we will be unable to provide you with the services you require.  For more information, please contact the Data Governance team.   

Right to Portability-

In the event that you wish to move your personal data that we hold on you to another organisation in the form of an excel or csv format, please contact the Data Governance team who will be able to assist you.

Right to be Informed-

You have the right to be informed about the collection and use of your personal data. This is commonly known as a 'privacy statement' or 'privacy policy'. We will provide you with the information about how we collect and use your data in various means, such as by 'just in time' notice provided to you at the time of collecting your personal data and via this Privacy Policy.  Our Privacy Policy is regularly reviewed in line with our business processes.  Any changes to this Privacy Policy will be communicated via email and account statements to all active customers.  You can ask for a printed copy of this Privacy Policy by contacting the Data Governance team.

Right to Complain to the Information Commissioner's Office (ICO)-

You have a right to lodge a complaint with the Information Commissioner's Office (ICO) if you have a complaint with how you believe your personal data has been handled.  For more information, please visit https://ico.org.uk/concerns

Changes to our Privacy Notice

Changes can be necessary to this policy to reflect legal or data processing developments. If we change the policy, we will provide information via email so that users can review the changes.

Any significantly different use of your data will be communicated to you and you will be able to choose whether you agree to the new use.

How to Contact Us

If you have any questions, comments or complaints about this Privacy Policy or our use of your personal data, please contact us at:

Data Governance Team

MyRaffles365, Fieldgate Solutions Ltd

c/o KM Accountants, 1st Floor, Block C

The Wharf, Manchester Road

Burnley

Lancashire

BB11 1JG

admin@myraffles365.co.uk

Tel: 01282 685400

If you are at all dissatisfied with the information provided by the Data Governance Team, please address any complaints to the Data Protection Officer at the same address.

It is a criminal offence to play in any Lottery if you are under 16 years.   Players must be aged 18 or over to participate in Prize Draws.  All advance paying customers funds are protected.

 

www.gamblingcommission.gov.uk                       www.begambleaware.org                     www.ibas-uk.com                           www.gamcare.org.uk

 

Click to download this document in PDF format