Privacy Policy

Effective as of 09 October 2024.

Lottomart is committed to the protection of your personal data and your rights to be informed and aware of how we process your information.

Who we are

Maple International Ventures Limited ("Lottomart") registered at Suite 23 Portland House, Gibraltar GX11 1AA will be what's known as the Controller of the personal data you provide to us. Depending on where you live, the privacy regulatory authority will vary:

• For players in the United Kingdom, the privacy regulatory authority is the Information Commissioner's Office (ICO)
• For players outside the United Kingdom, the privacy regulatory authority is the Gibraltar Regulatory Authority (GRA)

This privacy policy should be read together with our terms and conditions.

The information we collect about you

Personal data that we collect may include the following:

• Identity data: name, residential address, date of birth, sex, proof of address documents, proof of identity documents. This is provided by you during account registration, account updates, and identity verification.
• Contact data: email address and mobile number. This is provided by you during account registration and account updates.
• Communication data: correspondence records via in-app messaging, email, text messaging, live chat, and phone calls. These are generated when we interact together. Communication data may also include interactions you have with us on our social media presences or via third-party review sites like app stores and Trustpilot.
• Account data: player ID (or account ID) and credentials. You select your credentials to access your account when registering. Your player ID is generated and assigned to you when you successfully create your account.
• Payment data: payment methods and financial transaction activity. Payment details are provided by you to process your payments, deposits, and withdrawals. The transactional activity arises as you request payment transactions.
• Gaming data: game transaction activity. By placing bets and making purchases, you will generate game lines and transactions.
• Access data: IP address, device hardware and software attributes, cookies, and tracking information where you have permitted it. This is collected by us when you access and connect to our site to use our services.
• Public data: information about you that is publicly available. This may have been posted by you or otherwise published in the public domain.
• Verification data: identity checks and financial checks. This is collected from reputable, lawfully-acquired third-party databases as part of your account verification at the beginning and during the course of our business relationship.
• GAMSTOP data: for customers in Great Britain only, this is a check to ensure that you haven't excluded yourself from all gaming operators nationally. This is collected by us when you register and on an ongoing basis.
• Other data: other information or documentation. This may be captured by us if you volunteer/disclose to us as part of our interactions or if we request more information from you that you then provide.

Legal basis for using your personal data

We must have a valid legal reason for using your personal data. Our legal basis will be one of the following:

• Consent: where you've agreed to us collecting and using your personal data a certain way.
• Performance of contract: to carry out our obligations to you for the products and services you use.
• Legal obligations: in many cases, we have a legal and/or regulatory obligation to collect and store your personal data. For example, anti-money laundering laws are very specific about the kind of information we need to maintain for our records.
• Legitimate interests: personal data may be collected and used because we have a legitimate reason to use it and this is reasonable when balanced against your human rights and freedoms.

How we use your personal data

Lottomart uses your personal data to allow us to offer our services while remaining compliant with the legal and regulatory requirements as an online gambling operator. Outlined below are details of how and when we make use of your personal data and the legal basis for doing so.

We respect your choice to provide your personal information to us however, if you do not supply your personal data to us, or do not agree to this privacy policy it would be impossible for us to provide our services to you and we would not be able to accept your registration as a player.

Checking your identity & address

When you sign up to Lottomart and use our services on an ongoing basis, we'll use your personal data to check that you are of legal gambling age and that your identity and address details match the registration data you provided.

Our legal basis for using your personal data:

• Legal obligations
• Legitimate interests

Providing our products and services

When you opt to use one of our products or services, we'll use your personal data to meet our contractual and legal obligations relating to any products or services you use, such as:

• Depositing funds into your Lottomart account
• Withdrawing funds from your Lottomart account
• Participating in a promotion and claiming a reward
• Placing a lottery bet or purchasing a lottery ticket
• Buying and playing scratchcards
• Playing our casino games

Our legal basis for using your personal data:

• Performance of contract
• Legal obligations
• Legitimate interests

Providing you with support

We use your personal details to provide support during your journey with us, protect vulnerable or potentially vulnerable customers, and to help resolve any queries you might have.

The type of personal data we use varies with the nature of the contact and who initiated it. For example, if you are inquiring about a failed deposit, the data will likely be predominantly payments-related.

Because we monitor and record our interactions, we may use the personal data captured in these to maintain records, check your instructions, analyse and assess ways we can improve our services, training, and for quality control purposes.

Our legal basis for using your personal data:

• Performance of contract
• Legitimate interests
• Legal obligations

Meeting our safer gambling obligations

We are committed to preventing and minimising gambling-related harm. We use your personal data to help us detect early signs of harm and to help you either manage your play with the use of our Play Sense tools or imposing specific time, product, or spending restrictions designed to help protect players from harm.

We actively monitor transactional activity throughout the system and, wherever possible and appropriate, we may share your personal information with trusted suppliers to better help us evaluate player risk and vulnerability.

Our legal basis for using your personal data:

• Legal obligations - we have very high regulatory standards that govern how we treat vulnerable and potentially vulnerable players

Protecting against fraud

Your personal data is used to check your address and identity, ensure you're eligible to use our products and services, keep crime out of gambling, and protect against fraud.

Our legal basis for using your personal data:

• Legitimate interests
• Legal obligations - keeping crime like fraud out of gambling is one of the fundamental principles of regulation in our space

Meeting our legal and regulatory obligations, protecting our business, and other legal uses

Your personal data may be used in the following circumstances:

• If it's necessary to satisfy legal or regulatory obligations
• To share it with other organisations when necessary - for example, law enforcement
• To protect ourselves, rights, property (including intellectual property), staff, and products
• In connection with legal claims
• To help detect or prevent crime

Our legal basis for using your personal data:

• Legitimate interests - for example, to protect ourselves in the event a legal dispute arises
• Legal obligations

Marketing products and services that might interest you

We use your personal details and information related to your account activity to:

• Ask your opinion about our products or services
• Personalise your in-app experience to provide a better, more tailored view of products and services you enjoy
• Invite you to take part in competitions we think might be relevant to you
• Inform you about promotions or updates to products or services which may be of interest to you
• Measure and understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you

Please keep in mind that you are able to opt out of receiving marketing information at any time by adjusting your settings. Please see the "How is your data used for marketing" section below.

Our legal basis for using your personal data:

• Consent
• Legitimate interests to understand our customer's views and encourage greater interaction with our customers

Running and improving our services

We may use your personal details and information related to your account activity to:

• Authenticate and authorise you to use our services
• Ensure that content from the site is presented most effectively for you and for your devices
• Maintain and improve our products and services through data analysis, troubleshooting, testing, and research
• Tell you about changes to our products and services

Our legal basis for using your personal data:

• Consent
• Performance of contract
• Legitimate interests - to ensure that our interaction with customers is appropriate, working and efficient

Do we make automated decisions?

We may make automated decisions about you. We use technology to predict risks and outcomes by analysing player behaviour. Automated decisions are predominantly used to protect players as part of our safer gambling obligations and to flag anti-money laundering (AML) risks.

For example, we may make automated decisions based on:

• GAMSTOP national exclusion database checks (Great Britain only)
• Financial data we may receive about you from credit reference agencies or via Open Banking services
• Know your customer (KYC), anti-money laundering (AML), politically-exposed persons and close related associates (PEP & CRA), and sanctions checks
• Identity and address checks
• Payment, loss, time spent playing, and play/betting patterns

Our legal basis is one or more of the following:

• Legitimate interests
• Legal obligations

Do we run credit checks?

We don't run credit checks on you.

We may; however, run a "soft footprint" search as part of our verification procedures. A soft footprint check is a common practice that will show that we have queried your data, but it has no impact on your credit rating. These searches appear on your own credit file so you can keep track of who has done these searches and can also remove them by contacting the appropriate credit reference agency if you wish.

We use reputable agencies to:

• Verify the details you have provided
• Look for potential vulnerability markers that are part of our safer gambling obligations
• Determine and set limits for you where we believe it is necessary or to comply with specific regulatory obligations

If you give us access to other accounts you hold with financial institutions through Open Banking, we may use the available information to carry out similar checks for the same reasons.

Our legal basis is one or more of the following:

• Legal obligations

How is your data used for marketing?

By signing up and using our services, we will want to keep informed about your account and, where permitted, about our products, services, and promotions.

We only send you promotional communications once we have received your express permission, which is clearly indicated when initiating the registration process. To do this, we use the contact details you have provided.

We do not sell your information nor do we allow any third parties to market to you through us. Your personal data will only be used to personalise marketing messages about our products, services, and promotions so they are relevant to you. This may include analysing how you use our services and your transactions.

If you do not want to receive marketing messages, you can simply opt out at any time. This is possible by any of the following:

• Using the unsubscribe option in any marketing communication you receive (usually at the end of the email or message)
• Changing your preferences on your account settings
• Contacting our Player Experience team

You can change your preferences or contact our Player Experience team to opt back in at any time.

Please note that opting out will not prevent all communications. You may still be contacted for limited essential service information relating to your account.

Our legal basis is one or more of the following:

• Consent
• Legitimate interests

Who do we share your data with?

We outline when, how, and with whom your personal data may be shared below.

Suppliers & partners

We may need to share your personal information with other organisations to help us provide our services to you, ensure that we meet our contractual obligations to you, and that we meet our legal obligations:

• Business partners and subcontractors: to help us provide our services to you.
• Banking and financial services partners and payment networks: to help us provide our services to you, such as receiving your deposits and making payouts back to you.
• Analytics and search engine providers: to help us improve our website and app.
• Identity verification & due diligence service providers: to help us verify your identity and assist with ongoing customer due diligence so we can provide our services to you.
• Credit reference agencies: to help us verify that your details are correct and to assist us with our safer gambling obligations.
• Communications service providers: to help us send you emails, text messages, and push notifications.
• Fraud prevention service providers: to help us prevent, detect, and stop fraudulent activity.
• Games, lottery betting, and lottery ticket purchasing service providers: to help us provide our gaming, lottery betting, and lottery ticket purchasing services to you. In cases where players hit a jackpot or substantial prize, we may need to disclose your identity to our service providers as part of the claim process.
• National self-exclusion service providers: in Great Britain only, we work with GAMSTOP to help us identify and, where appropriate, restrict accounts that have opted to self-exclude from gambling operators nationally.
• Legal partners: to help protect our business and enforce our rights (and those of customers or others).

Some of our partners have their own privacy notices that explain their activities. Links to their websites are shown below:

• TransUnion: https://www.transunion.co.uk/legal-information/bureau-privacy-notice

Government, law enforcement, and tax authorities

We may share your personal data with government agencies and authorities, as part of our regulatory and legal obligations. This may include disclosures:

• As part of any regulatory assessment or claim
• For the purposes of investigating any actual or suspected criminal activity
• In connection with criminal or fraud investigations
• In connection with legal claims
• To enforce our rights (and those of customers or others)

Independent adjudication entities

In cases where a complaint is escalated to a third party, such as an alternative dispute resolution entity (ADR), we may share your information with that third party. Typically we receive the request from the ADR for further information only once you have submitted your complaint to them and provided them with your version of the events and consent.

Authorised third parties

We may share your information with a third party when you ask us to. For example, if you've authorised someone else to act on your behalf, we will need to ask for proof that they've been authorised and check both your and their identity details.

Social media and advertising companies

To ensure that our advertising is as effective as possible, we may share limited personal data with third party advertising platforms, such as Meta, to:

• Send our adverts to you because you may be interested in a new product, service, or promotion of ours.
• Not to send our adverts to you because you already use one of our products, services, or promotions.
• Find other prospective customers with a profile similar to yours. This is commonly known as custom or lookalike audiences.

Local emergency services

If we have reason to believe you are a threat to yourself or others, we may contact your local emergency services and provide your personal data to respond with the appropriate measures.

Others

We may also disclose your personal information to third parties in the following circumstances:

• In the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers 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 about our customers will be one of the transferred assets; and
• To protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, and fraud protection.

Where is my data stored?

The overwhelming majority of our services where personal data is stored and used are in the UK, Gibraltar, and the European Economic Area, which are all subject to robust data protection legislation.

From time to time; however, we may need to transfer your personal data outside these zones to help us provide our services. Other countries may not have the same data protection; however, we will always use every reasonable effort to ensure sufficient contractual protections are in place to safeguard your personal data.

How is my data protected?

Lottomart is committed to ensuring your personal information is held securely and in strict adherence to legal and regulatory requirements.

We use reasonable organisational, technical, and administrative measures to protect customer personal data from unauthorised access, alteration, disclosure, or destruction of personal data that we hold.

Furthermore, we are selective as to which third party services and technology companies we engage to provide services we offer you where your personal data may be processed. We respect your privacy and demand that all suppliers that serve our business meet strict standards of security over your data.

While we take all reasonable steps to ensure your data is safe from unauthorised access, we can't guarantee the transmission from you to us is totally secure. We use encrypted communication protocols like HTTPS (HTTP Secure) to ensure all transmissions are secure between us and our suppliers.

You must also take care to ensure that you protect your data:

• Keep your Lottomart account login credentials confidential. You should never share it with anyone, including our staff. Lottomart staff and suppliers will never ask you for your password.
• Ensure any devices that you use to access Lottomart are locked when not in use.
• Don't share any personal information when interacting with us publicly. This might include third-party review sites or social network accounts that are visible to everyone.
• Be vigilant and wary of any suspicious emails that may "look" like Lottomart:
  • Emails will always direct you to go to our official app or website located at lottomart.com.
  • We will never send you an urgent request, particularly if that urgent request is asking for money.
  • Always check that communications come from emails ending in @lottomart.com and that the reply-to field is the same recipient, also ending in @lottomart.com.

How long we retain your data

We keep your data for as long as it is necessary to achieve the original purpose we originally collected it for and to adhere to applicable laws. Your personal data is generally retained for 7 years from the date your account is closed.

We will only continue to hold personal data relating to your account as permitted under data protection legislation:

• Where we are under a legal requirement under gambling or tax legislation to retain your data;
• To exercise or defend our legal rights;
• To investigate a crime; or
• To handle a claim.

Do we use cookies?

Cookies are small text files placed on your device's storage by websites that store small bits of information, usually unique identifiers. For example, cookies can help us recognise you each time you visit our websites or apps.

We use the following type of cookies:

• Strictly necessary cookies: these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site. We do not require your consent to place these cookies.
• Analytical and advertising cookies: they allow us to recognise and count the number of visitors and see how visitors move around our site when using it. This helps us to continuously improve our website. We may share this information with other organisations, such as Meta and Google, so we can provide more relevant ads to prospective customers.

These are the analytics and advertising cookies we use:

• Google Ads - we use this to measure and optimise campaigns we use to advertise to people using Google products. This may include an extra cookie for Doubleclick, which was acquired and merged into Google's advertising platform.
• Google Analytics - allows us to see the number of visitors that have used our website and the areas of the website they visit.
• Google Tag Manager - this controls other cookies in our app.
• YouTube - we use this to measure and optimise advertising campaigns on YouTube.
• Meta (Facebook) - we use this to measure and optimise advertising campaigns on Meta.
• Yahoo - we use this to measure and optimise advertising campaigns on Yahoo.
• Amplitude - a digital analytics partner used to monitor on-site activity.
• BING Ads - we use this to measure and optimise advertising campaigns on Microsoft's BING search engine.
• Twitter/X - we use this to measure and optimise advertising campaigns on Twitter/X.
• Snapchat - we use this to measure and optimise advertising campaigns on Snapchat.
• Adalyser - we use this to measure response to our TV and broadcast video on demand (VOD) advertisements.
• Taboola - we use this to measure and optimise advertising campaigns run on the Taboola display network.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If; however, you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. For instance, our site, like most websites, includes functionality provided by third parties.

More information about cookies, including how to block them or delete them, can be found at https://www.aboutcookies.org.

What are your rights?

Below we have outlined your rights to promote transparency, accountability, and ethical treatment of the personal data you have entrusted to us:

• You have the right to be informed: this policy provides clear, transparent, and easily understandable information about how we use your personal data and your rights.
• You have the right of access: if you ask, we will provide you with a copy of the personal data we hold about you.
• You can ask us to correct your personal data if you think it's wrong: if you've noticed that a personal detail we hold about you is incorrect, you can request that we correct it. You can do this yourself via the app or by contacting us; however, we may need to check the accuracy of the new personal data you have provided.
• You can ask us to delete your personal data: we can look into it; however, we are generally unable to agree to erasure requests. As a regulated gambling operator, we are obliged to keep certain customer data. In this case, legal and regulatory conditions take priority over this right.
• You can ask us to restrict how we use your personal data: you can ask us to suspend using your personal data if: you dispute the accuracy of the personal data held by us; where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for dealing with legal claims; our use of personal data is unlawful but you don't want us to delete it; or you have objected to us using your personal data but we need to check if we have an overriding reason to use it.
• You can ask us to transfer your personal data: if the destination supports the use of your personal data, if we can, and we are allowed to do so under regulatory requirements, we'll provide your personal data in a structured, commonly used, machine-readable format.
• You can object to us processing personal data: you may object to our processing of personal data held by us about you where the processing of such data is necessary for our legitimate interests unless we can demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
• You can ask us to manually review an automated decision: if we make an automated decision about you that significantly affects you, you can ask us to manually review the decision.
• The right to withdraw consent: you have the right to withdraw your consent, where we rely on it to use your personal data. This, for example, applies to withdrawing consent for us to provide you with marketing information about our products and/or services. Please note that the use of your personal data will have been lawful up to the point you withdraw your permission.

How do you exercise your rights?

To exercise any of your rights set out in this policy or for more information, you can contact us via the app or by emailing [email protected].

For security reasons, we may ask for proof of identity that you are the true account holder. If a third party exercises an aforementioned right on your behalf, we may also need to ask for proof that they've been authorised to act on your behalf and also ask for proof of their identity too.

Your ability to exercise these rights will depend on the circumstances. Please note that all rights are not absolute and will not apply when legitimate and overriding reasons apply. This includes but is not limited to legal and regulatory requirements.

Generally, we will not charge you a fee when you exercise your rights; however, we are allowed to charge a fee, ask about the scope of your request, or refuse to act on your request if it is considered manifestly unfounded or excessive.

If you're unhappy about how we've handled your request, you have the right to complain to the appropriate supervisory authority:

• For customers in the United Kingdom, you will need to contact the Information Commissioner's Office (ICO) at https://ico.org.uk.
• For customers outside of the United Kingdom, you will need to contact the Gibraltar Regulatory Authority (GRA) at https://www.gra.gi.

Changes to this policy

We may need to change and update this policy from time to time.

If we make any material changes, we will notify you before those material changes come into effect the next time you access our services.

The most up-to-date version of this policy will always be available on our site. If any change is unacceptable to you, you should cease using our services and/or close your account.