Privacy Policy

Introduction

We are committed to protecting your privacy and keeping you informed about how we use your data. This Privacy Policy includes details of how we collect personal data from you and how we use it to provide a personalised service to you.

It includes details on Cookies and their use. It also details rights to control how your personal information is processed under data protection.

If you continue to use this Website you are agreeing that you understand and accept the use of your personal information as set out in this Privacy Policy. If you do not agree with any of the terms in the Privacy Policy you should cease to use the Website.

Please note if you choose to restrict the processing of your personal data we may not be able to provide you with the requested services.

Who We Are

We are Annexio Limited, a company incorporated in the Isle of Man (Company Number 124709C) Fort Anne South Quay Douglas Isle of Man IM1 5BU. We are the data processor for the purposes of data protection legislation.


Why and How We Protect Your Data

Your personal information is not just protected by Annexio Limited’s high standards, it is also protected by law. The Data Protection Act 2018 and General Data Protection Regulations (GDPR) detail the steps that must be taken to protect personal data and the rights which individuals can exercise to protect their personal information. This Privacy Policy details the steps we take to make sure our high standards meet those of the data protection law.

To adhere to the data protection law and the principles of data protection we confirm that without your consent we will:

  • only use your personal data for any purpose that is incompatible with this Privacy Policy (as amended if necessary).
  • only collect personal data that is required for the uses in this Privacy Policy.
  • use our best efforts to keep your personal data accurate and up to date.
  • not retain any personal data longer than is necessary for the purposes in this Privacy Policy, unless we are required to do so by law.
  • always operate our business processes to protect your personal data from unauthorised or unlawful access or processing and against accidental loss or deletion.
  • Not transfer your personal data outside the European Economic Area unless we ensure that contracts are in place to ensure your personal data is protected to a level approved by the European Union.


Information We Collect About You

We may collect and process the following personal information about you:

  • Information you provide when registering for our services.
  • Information you provide to us in any contact with us, including telephone or email.
  • Information you provide when you complete surveys or enter competitions.
  • Information on details of transactions you carry out through our site, by telephone or any other means including your bank account and card details.
  • Information about your use of our services including your preferences.
  • Information about any possible fraudulent, criminal or anti-money laundering our systems may detect.
  • Information about your betting history and patterns.
  • subject to data protection principles we may receive personal information from third parties.


Processing Your Personal Information

Our commitment to protecting your privacy means that in accordance with data protection laws we will only process your personal information if we have a genuine reason to do so. The data protection legislation identifies the following as reason to process:

  • It is necessary to perform any contract with you.
  • We have a legal obligation.
  • We have your consent to the processing.
  • Where we have a legitimate interest.
  • Where the processing is in the public interest.
  • If it is in your vital interests.

In accordance with the above we may disclose your personal information to any member of our group and to third parties providing services to us and to any member of our group.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, in which case personal data held by us and our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements between us and you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of anti-money laundering, the prevention of terrorist financing, fraud protection and credit risk reduction.
  • To comply with any law applicable to us.
  • That are a regulatory body.
  • That provide services to us including but not limited to payments, software provision or marketing.


Information We Get From External Companies

To help us comply with our legal and regulatory obligations, when you fund your account (in the UK) we share information with a Credit Reference Agency called Experian Limited who process your data in accordance with their Credit Reference Agency Information Notice (CRAIN - available here) and will provide us with data and insight that is based on your outstanding credit commitments – in short, we will received your EDI (Estimated Disposable Income).

Whilst we will receive your EDI we do not receive data about your credit standing or ‘credit score’ and the check we undertake WILL NOT affect your credit score.

To comply with our various regulatory requirements, we carry out checks during account funding and throughout the life of your account to ensure our customers bet/play responsibly and legally. Depending upon the level of activity on your account we may refresh our checks multiple times within a year.

Sometimes we need to undertake additional checks to verify information or, once an account is active, to investigate activity that could indicate a risk. To do this we use organisations and databases which collate information and make it commercially available for use in crime prevention and detection, the promotion of safer gambling and ensuring the fair use of services.

We also look at publicly available information to verify things like occupation status or property ownership, and at social media. For UK based customers, we use data you provide to us to enquire whether you have self-excluded from using gambling services by checking the national scheme run by GAMSTOP. We run this check on a daily basis so we can ensure any self-exclusion request is picked up and then applied across our service.

We may in future subscribe to similar national self-exclusion schemes in any of the countries in which we operate, and we will update this policy to let you know.

Like many companies, from time to time we may supplement the information we hold about you with data from companies such as Experian that collate and update address and household information from a range of sources and make it commercially available. This helps us keep our records up to date, fill gaps in our data, complete affordability checks and learn more about our customers so we can continue to improve our products and services.

We will only work with reputable organisations that obtain their data legally in accordance with data protection law.


Your Rights

The data protection legislation also gives you rights over how your personal information is processed see below:

  • The right to be informed about the collection and use of your personal data.
  • The right of access to all personal data we hold on you.
  • The right to rectification – in other words correcting any mistake in personal data we hold. Please remember the personal information we hold is the information you have supplied. If you spot an error in the personal information we hold on you please update your information on our site in "Account Settings" > "My Details", or let us know immediately via email to [email protected] and we will update it.
  • The right to erasure – in other words you can request that we delete all personal information we hold on you – however we may have to retain certain information for legal and regulatory purposes – The DPO will explain this to you.
  • The right to restrict processing – you can control how we use your personal information.
  • The right to data portability – you can request that the personal information we hold is transferred to you so that you can reuse the information.
  • The right to object – in other words you can object to the processing of your personal data.

If you wish to exercise any of these rights please contact [email protected].


Facebook Log-In Verification

Our site may offer Facebook log-in verification which gives the benefit of a simplified account registration.

• Be aware that if you choose to log in via Facebook verification, your data will be shared between Facebook and a third-party data processor.

• The link will allow you to identify the information/data that will be shared between Facebook and the third-party data processor.

• You may limit the information shared however this may impact your ability to use Facebook verification to register your account.

Please remember the personal information we hold is the information you have supplied if you spot an error in the personal information we hold on you please let us know immediately and we will update it.

If you have any queries or would like a copy of the personal data we hold on you, please request it through Live Chat or by emailing our Data Protection Officer on: [email protected], and we will provide you with a form to complete. The form is not compulsory but helps us to provide you with the information you are looking for in a timely manner.

We will ask you for valid proof of identity to ensure the security of your personal information, and once we've received it we will provide our response within one month. If your request is unusually complex and likely to take longer than a month, we will let you know as soon as we can and tell you how long we think it will take. Such request may also incur an administration cost.


Legal and Regulatory Requirements

We need to comply with a range of legal and regulatory requirements, some of which involve the use of personal information and/or set out timescales for which we need to keep that information.

As a licensed provider of betting and gaming services, we are regulated by the UK Gambling Commission, the Jersey Gambling Commission, the Isle of Man Gambling Supervision Commission, and the Irish Revenue.

To comply with our various regulatory requirements, we carry out checks during account opening and throughout the life of your account to ensure our customers bet/play responsibly and legally.

We are also subject to laws and regulations relating to other aspects of our business, such as payment processing or complaint handling and some of these too involve the use of, or set timescales for holding, your personal information.


Fraud, Money Laundering and Other Illegal Activity

When you set up an account with us, place bets or play our games we carry out identity verification, fraud prevention and anti-money laundering checks, validating the information you give against third party crime prevention databases and information from publicly-available sources.

We share your personal data with organisations that verify details and transactions and identify potential indicators of illegal activity, which they make available to other organisations using their services. Where necessary, we share your data with Credit Reference Agencies or fraud prevention agencies, which keep a record of that information and make it available to other organisations for use in credit decisions, identification checks and fraud detection and prevention.

Where appropriate, we pass information to our regulators, the police and other law enforcement agencies.

It is important that operators work together to prevent illegal activity and promote safer gaming.

If you are an Annexio customer, we may carry out verification checks using publicly available information, to verify your age. In addition, we may also carry out full identity, fraud prevention and anti-money laundering checks, at our discretion.


Cookies

Like most Websites that you may access, we use cookies to allow us to give you a personalised service and improve your experience. Below are some questions you might have about our use of cookies.

Please be aware that you can manage our use of cookies as detailed below.

What are Cookies?

A cookie is a tiny little file that’s stored on your computer. It contains the address of the Web site and codes that your browser sends back to the Web site each time you visit a page there. Cookies don’t usually contain personal information or anything dangerous.

When you browse the Web, the Web server needs to know who you are if you want to do things that require logging in or completing any other process that requires that the Web site remember information about you as you move from page to page. The most commonly used trick that allows websites to keep track of what you’re doing is called setting cookies.

Cookies only collect information that the browser tells them about.

If you want to delete any cookies already stored on your computer or stop cookies that keep track of your browsing you can do so by activating the setting on your browser which allows you to disable cookies or change your privacy settings.

Please be aware that deleting or disabling cookies may prevent you accessing some areas of our Website.

Why Do We Use Cookies?

We use cookies to personalise the service you receive and improve the website. The following are some of the reasons we use cookies:

  • To estimate our audience size and usage pattern.
  • To store information about your preferences, and to allow us to customise our site according to your individual interests.
  • To speed up your searches.
  • To recognise you when you return to our site.

In addition to cookies that improve your website experience, some cookies are strictly necessary for the Website to operate. These include:

  • Performance cookies which collect information which are used to track visits to the Website.
  • Functionality cookies these allow the Website to remember choices you make and provide enhanced, personal features.
  • Targeting/advertising cookies used to deliver adverts and offers that are personalised.
  • Fraud Prevention.

It is important to remember that if you access a third party website, they may use cookies over which we have no control. Please ensure you read the Privacy and Cookie Policy for each third party website you visit.


Marketing Communication

We may also use your data to provide you with information about goods and services which may be of interest to you, and we may contact you about these by post, telephone, text or e-mail.

Your details may also be used to send you information about our other websites that we feel are relevant to your registration . Upon registering you will be given the option to “opt-in” to any Marketing Communications by us or third parties in relation to goods and services that may be of interest. If at any time you wish to change your opt-in status, you can do on our site by heading to your LottoGo Account Menu, tapping "Account Settings", then "Marketing Communication".

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.


Data Retention

We will retain your personal data for a period of five years after the closure of your account or your last transaction with us. We will delete any personal information which is no longer required. However, we may have to retain personal data for legal and regulatory requirements. Our Data Protection Officer will advise you of any requirements.


Changes To Our Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on this page. We reserve the right to make changes to this Privacy Policy. Changes will come into effect immediately upon such change being notified on our site by a prominent notice. Your continued use of our site following such notification constitutes your acceptance of the changes.

For the avoidance of doubt, we have notified the Information Commissioners Office in the Isle of Man, that we control and process personal data to enable us to provide our services, to maintain our own accounts and to support and manage our staff.

If you are unsure about your rights or are concerned about how your personal data may be processed you should contact: