Fortunate Partners Ltd. (“The Company”, “we”, “us”, or “our”) is committed to protecting your privacy and ensuring that your personal data is handled responsibly. This Privacy Policy explains how we collect, use, store, disclose, and safeguard your personal data when you use our lottery software and related services (“Software” or “Services”). Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
1. Data Controller
The Company is the data controller responsible for the processing of your personal data. If you have any questions or concerns about our data practices, please contact us using the details provided in Section 13.
2. Information We Collect
We may collect and process various types of personal data about you, including:
- Contact Information: Such as your name, email address, phone number, and mailing address.
- Account Information: If you register for an account, including your username, password, and other profile details.
- Usage Data: Information about your interactions with our Software, such as IP address, browser type, device details, and usage patterns.
- Transaction Data: Data related to lottery transactions, payments, and related financial information.
- Technical Data: Log files and data collected through cookies and similar tracking technologies to help us enhance and personalize your experience.
3. How We Collect Data
We collect personal data through the following methods:
- Direct Interactions: When you register for an account, fill out forms, or communicate with us.
- Automated Technologies: Through cookies, web beacons, and similar technologies when you use our Software.
- Third Parties: From partners, service providers, or regulatory bodies as necessary to support our services or comply with legal obligations.
4. How We Use Your Data
We use your personal data for purposes including, but not limited to:
- Providing Services: Delivering and maintaining our Software and ensuring smooth operation of lottery services.
- Account Management: Managing your account, processing transactions, and providing customer support.
- Communication: Sending you updates, service-related notifications, and marketing communications (where permitted).
- Improvement and Security: Analyzing usage data to improve our Software, enhance security, and prevent fraud.
- Compliance: Meeting legal, regulatory, and contractual obligations.
5. Legal Basis for Processing
We process your personal data based on the following legal grounds:
- Contractual Necessity: To perform our obligations under any agreements with you.
- Legal Obligation: To comply with applicable laws and regulatory requirements.
- Legitimate Interests: To improve our services, ensure security, and manage our business, provided your rights are not overridden.
- Consent: Where applicable, we may process your data based on your consent, which you can withdraw at any time.
6. Data Sharing and Disclosure
We may share your personal data with:
- Service Providers: Trusted third parties who perform services on our behalf (e.g., payment processing, data analytics, IT services) under strict confidentiality agreements.
- Regulatory Authorities: Where required by law or to protect our legal rights.
- Business Transfers: In connection with a merger, acquisition, or sale of all or part of our business, provided appropriate safeguards are in place.
- Other Parties: With your explicit consent or as otherwise permitted by law.
7. International Data Transfers
If your data is transferred or stored outside the UK or EU, we will ensure that appropriate safeguards are implemented to protect your personal data in accordance with applicable data protection laws.
8. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Once the data is no longer needed, it will be securely deleted or anonymized.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. While we strive to secure your data, please be aware that no method of transmission over the internet or electronic storage is 100% secure.
10. Your Rights
Under applicable data protection laws, you have certain rights regarding your personal data, including:
- Access: The right to request a copy of the personal data we hold about you.
- Rectification: The right to have inaccurate or incomplete data corrected.
- Erasure: The right to request deletion of your personal data under certain conditions.
- Restriction: The right to request limitation of processing where applicable.
- Data Portability: The right to request your data in a structured, commonly used, and machine-readable format.
- Objection: The right to object to certain types of processing, including for direct marketing purposes.
- Withdrawal of Consent: Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us using the details provided in Section 13. We may need to verify your identity before processing your request.
11. Cookies and Tracking Technologies
Our Software uses cookies and similar tracking technologies to enhance your experience and to gather information about your usage of our services. You may adjust your browser settings to manage your cookie preferences; however, please note that disabling cookies may affect the functionality of our Software.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technological advancements. Any updates will be posted on our website with a revised “Effective Date.” We encourage you to review this Privacy Policy periodically.
By using our Software, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your personal data as described herein.