Northern Management Solutions Ltd ("Victory Lotto Club", "we" or "us") are committed to protecting and respecting your privacy.
This policy (together with our Terms and Conditions accessed at https://www.victorylottoclub.com/terms and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Information we collect about you
The information that we collect, and process may include:
- Information you give us. This is information about you that you give us by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Site, join our syndicates and syndicate plans on our Sites and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photographs.
- Information we collect about you. We may collect the following data about you when you visit the site or that we obtain from third parties:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, and other location information, your login information and mobile phone number, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform,];
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any email address used to contact customer services.
Uses made of the information and legal basis for such use
We use information held about you in the following ways:
- to carry out our obligations arising from any contracts entered into between you and us, for example if you join one of our syndicates or syndicate plans. This may include verifying your identity, communicating with you, managing our syndicates and processing your membership;
- as required by Victory Lotto Club to enable our business and pursue our legitimate interests, in particular:
- to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Sites safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to contact you with regard to your use of our Sites and, at our discretion, changes to any of our policies;
- for compliance with applicable laws and protection of our legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).
In addition, with your consent, we may send you direct marketing in relation to our relevant promotions, products and services, or other promotions, products and services provided by us, our Affiliates and carefully selected partners. Although these will only be sent where you have given your consent, or (where permissible) you have been given an opportunity to opt out, you will be able to opt out of electronic direct marketing by following the instructions in the communication.
Disclosure of your information
We may also share your personal information with:
- Companies and brands in the Victory Lotto Club group ("Affiliates"), so that those Affiliates can: (i) assist us with fulfilling your requests or improving our products, content, services or advertising; and/or (ii) contact you about products, content, services or other offerings that may be of interest to you. Those Affiliates currently include the following companies, but these may change from time to time and you should contact us if you wish to receive an up to date list of our Affiliates: Votesnapper.com, Lottolout.com, Jackpot Hunter Lotto
- When You Consent To Have Your Personal Data Shared or Otherwise Request That We Share Your Information. We may offer you the opportunity to consent to the sharing of your information with third parties, including for marketing purposes. Additionally, you may request, sometimes through your use of an interactive feature or third- party application, that we share personal data about you with a third party. If you consent or request to receive communications from third parties, you will need to communicate with them directly if you later decide that you no longer wish to receive their communications. Any information collected directly from or about you by such a third party is subject to their own privacy notice.
- Third-Party Service Providers Providing Services On Victory Lotto Club’s Behalf. We may from time to time employ third parties to perform functions on our behalf, and as a result we may also share your personal data with third party service providers that assist us with providing content, fulfilling your requests, improving our products, content, services or advertising, or otherwise performing services for Victory Lotto Club. For example, we may share your information in order to host or operate the Sites, for data analysis purposes, and for the administration of our competitions, such as in connection with winner selection and prize fulfilment.
- Business Transactions. We may share your personal data with other entities and advisors for internal reasons, primarily for business and operational purposes including any corporate reorganisation, restructuring or other corporate change or business advice. In addition, Victory Lotto Club or any of its assets, including the Sites, may be sold, or other transactions may occur which result in your data being transferred to the purchaser of Victory Lotto Club or its relevant assets.
- Legal Protections and Law Enforcement. We may transfer and disclose information, including your personal data, (including Usage Information and Device Identifier (including IP address)), to third parties: (i) to comply with legal obligations; (ii) at the request of governmental authorities conducting an investigation; (iii) to verify or enforce our Terms & Conditions or other applicable policies; (iv) to respond to an emergency; or (iv) to otherwise protect the rights, property, safety or security of third parties, visitors to the Sites or the public. Such disclosures may be carried out without notice to you.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Where information is transferred outside the EEA, and where this is to entity that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a supplier's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review using the contact details set out below.
How long do we keep your data?
Where you sign up for an account with us on our Sites, we will keep your information for the length of any contractual relationship you have with us, and, to the extent permitted, after the end of that relationship for as long as necessary to perform the purposes set out in this notice. Laws may require us to hold certain information for specific periods. In other cases, we may retain data for an appropriate period after any relationship with you ends to protect us from legal claims, or to administer its business.
You may be entitled to ask us for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing, such as profiling we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
Where we require personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional.
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of marketing, you can get in touch at firstname.lastname@example.org.
If you are not satisfied with how we have responded to and/or handled any concern you have raised with us, please contact the applicable supervisory authority, being at present the Information Commissioner's Office (or ICO) at: https://ico.org.uk/global/contact-us/
Third Party Websites
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Web beacons (also known as image tags, pixel tags, GIFS or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many sent e-mails were actually opened or to determine whether content sent was actually viewed.
Embedded script is programming code that is designed to collect information about your interactions with the website, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third party service provider, is active only while you are connected to the website, and is deactivated or deleted thereafter.
The Sites use the following types of cookies: Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Sites and use their features, such as accessing secure areas of the sites. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.
- Performance Cookies: These cookies collect information about how visitors use the Sites so that we can analyse traffic and understand how our visitors use our Sites. We may use third party service providers for this purpose who may use their own cookies. These cookies don’t collect information that identify an individual visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Sites work.
- Functionality Cookies: These cookies allow the Sites to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
- Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
- Advertising Cookies: The Sites may also use a third party advertising network to deliver targeted advertising. These may also have the capability to track your browsing across different sites and apps. If you would like more information on targeted advertising and how to opt out of it, please visit www.youronlinechoices.com.
If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings or mobile device settings. The procedure for doing so varies from one browser application to another. If you wish to reject cookies from the Sites, but wish to accept those from other websites, you may be able to choose the option in your browser settings to receive a notice before a cookie is stored on your device. Please consult the “Help” section of your browser or device for more information.
If you would like to opt out of third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
By disabling cookies, you may be prevented from accessing some features of our sites or certain content or functionality may not be available.