Privacy and GDPR Policy
We UK Raffles 2019 Ltd, operator of UK Raffles are committed to protecting your privacy and
promise to collect, process and share your data safely and securely when you use UK Raffles
as the data controller.
Our Privacy Promise to you
Transparency – We will always inform you about the data we are collecting about you and how we
use it. We will never sell your data.
Security – We are committed to following industry best practices to ensure your data is stored
safely and securely. We will protect the confidentiality, accuracy and availability of the information
Control – We will always give you control over the marketing you receive from us. You can choose
the types of messages you receive and whether you want to stop receiving marketing
Personal and contact information including your name, address, email address, telephone
number(s), social media username(s), title, date of birth and gender. We may collect some of that
contact information when you interact with us through our website.
• Copies of documents you provide to prove your identity (including driving licence and passport)
when you are claiming a prize, or where there is a legal reason to request this from you.
• Transaction details including payments from you for UK Raffles games via Paypal, payments to you
(for example prizes), details of UK Raffles games played and the outcomes of those games.
• Information about how you use our website
• Technical information about your device or browser when you use our website, including
echolocation data to determine what country you are accessing our website from, your internet
protocol (IP) address, device ID, browser type and version and time zone setting, which may in
some circumstances be personal data.
USES MADE OF YOUR PERSONAL INFORMATION
UK Raffles may use information about you for purposes described in this Policy or disclosed to you
on our Website.. For example, we may use information about you for the following purposes, all of
which we believe to be in our legitimate business interests:
• to operate competitions promoted on the Website;
• to respond to and/or deal with any request or enquiry you may raise;
• to improve our products and services and to ensure that content on the Website is
presented in the most effective manner for you and for your device;
• to administer the Website;
• for internal record keeping;
• to contact you (directly, by UK Raffles) by e-mail or phone for the above reasons;
• subject to your consent where required under applicable laws, to carry out direct marketing
and/or e-mail marketing that you have requested;
• to perform any contract UK Raffles has with you; and
• for compliance with legal, regulatory and other good governance obligations.
HOW WE SHARE YOUR DATA WITH THIRD PARTIES
• Banks and payment providers – to set up a payment via Paypal, to pay prizes to you and to obtain
payment of any amounts due to us.
• Annuity policy providers and financial brokers – for the purposes of arranging payment of annuity
• Our IT system providers – to provide our systems to us, including for the purposes of hosting,
support and software licensing.
• Marketing service providers – to allow us to send email communications and notifications.
• Marketing agencies – for the purposes of providing you with relevant advertising or marketing on
our website or on social media, including for the purposes of undertaking behavioural modelling
for that purpose.
• Social media platforms – for the purpose of targeted advertising.
• Online survey companies and market research agencies – to undertake surveys (including for
example, our website satisfaction survey) and other market research and to analyse the results.
• Digital analytics companies – for the purposes of website analytics and reporting in respect of our
analytics and marketing.
• Public relations agencies – for the purposes of managing external communications about us and
• Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of
providing consultancy, banking, legal, insurance and accounting services.
• The Gambling Commission – for legal and regulatory purposes as required under our licence to
operate UK Raffles.
• Police or other such regulatory authority – as part of an investigation or otherwise for legal or
• Dispute Resolution agencies – for the purposes of dealing with any complaints.
• Reasonable management, planning, analysis and decision making, including in relation to taking
decisions regarding the expansion and promotion of our service offering and for use by UK Raffles
for the other purposes described in this Policy.
• We may disclose specific information upon lawful request by government authorities, law
enforcement and regulatory authorities where required or permitted by law and for tax or other
purposes. Personal information may also be released to external parties in response to legal
process, and when required to comply with laws, or to enforce our agreements, corporate policies,
customers, and others, as well as to parties to whom you authorise UK Raffles to release your
• We will disclose your personal information to third parties if we are under a duty to disclose or
share your personal data in order to comply with any legal or regulatory obligation or request. We
do this in order to protect our rights, property or safety or of our players, or others. This includes
exchanging information with other companies and organisations for the purposes of fraud
protection and credit risk reduction.
UK Raffles will not sell your personal information to any third party other than as part of any
restructuring of UK Raffles sale of the business.
WHAT CHOICES DOES UK RAFFLES OFFER YOU WITH REGARD TO DIRECT MARKETING?
UK Raffles may wish to provide you with information about new products, services, promotions
and offers which may be of interest to you, and may invite you to take part in market research or
request feedback on our products and services. This communication may occur by e-mail,
telephone, post, social media or SMS. We will obtain your consent and advise you of how to optout
of receiving such communications where we are required to do so in accordance with
WHAT SAFEGUARDS ARE IN PLACE TO PROTECT YOUR PERSONAL INFORMATION?
UK Raffles takes reasonable steps to maintain appropriate physical, technical and administrative
security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal
information. While we take these reasonable efforts to safeguard your personal information, we
cannot guarantee the security of any personal information you disclose online. You accept the
inherent security implications of dealing online and will not hold us responsible for any breach of
security unless such breach has been caused by the specific negligence of UK Raffles, or our
HOW LONG DOES UK RAFFLES STORE YOUR PERSONAL INFORMATION?
UK Raffles will only store your personal information for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, or reporting
At the end of that retention period, your data will either be deleted or anonymised (so that it can
no longer be associated with you) and used for research or statistical purposes.
To determine the appropriate retention period for personal information, we consider the amount,
nature, and sensitivity of the information, the potential risk of harm from unauthorised use or
disclosure of your personal information, the purposes for which we process your personal
information and whether we can achieve those purposes through other means, and the applicable
In some circumstances you may be entitled to ask us to delete your data: see below for further
WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND YOUR PERSONAL INFORMATION?
You have the right to review and access your personal information held by UK Raffles.
You also have the right to ask us to rectify, block, complete and delete your personal information,
to restrict its use, and to 'port' your personal information (that is, to ask us to provide it to you in a
structured, commonly used and machine readable format and to transmit it directly to another
In addition, you have the right to request further information about the handling of your personal
If you wish to do so, or to notify UK Raffles of a change in your details, please contact
email@example.com and/or post to UK Raffles 2019 Ltd, Kemp House, 160 City Road, London,
There are exceptions to these rights, however. For example, access to personal information may be
denied in some circumstances if making the information available would reveal personal
information about another person, or if we are legally prevented from disclosing such information.
In addition, we may be able to retain data even if you withdraw your consent, where we can
demonstrate that we have a legal requirement to process and store your data.
If you have a question about the use of your personal information, or wish to file a complaint
about it, please contact us using the contact details set out above.
Finally, if you have unresolved concerns, you also have the right to complain to the data protection
drive by a website. Cookies help us improve the Website, and your experience of them. We use
cookies to see which areas and features are popular and to count visits to our website, to
recognise you as a returning visitor and to tailor your experience of the Website according to your
preferences. Overall, cookies help us provide you with a better Website, by enabling us to monitor
advertising purposes. We may use Web beacons on our Website, or in our e-mails. Web beacons
are electronic images that may be used to deliver cookies, count visits, understand usage of group
websites and to tell if an e-mail has been opened and acted upon. Further details about cookie
purposes and types are below. To delete or block cookies through your browser settings at any
time, and for more general information about cookies including the difference between session
and persistent cookies, visit www.allaboutcookies.org.
We also use Google Analytics on the Website to collect information about your online activity on
the Site, such as the Web pages you visit and the links you click on the Website. We use the
information to compile reports and to help us improve the Website. The cookies collect
information in an anonymous form, including the number of visitors to the Website, where visitors
have come to the Website from and the pages they visited.
For more information about the information gathered using Google Analytics please visit
http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by
selecting the appropriate settings on your browser. If you do this you may not be able to use the
full functionality of this Site. You may download and install the Google Analytics Opt-out Browser
Add-on available here: http://tools.google.com/dlpage/gaoptout.
We only use category D cookies as defined in the international chamber of Commerce United
Kingdom Cookie Guide:
• "Targeting or advertising" cookies used to deliver adverts relevant to an identified machine
or other device (not a named or otherwise identifiable person) which are tailored to
interests associated with the website activity tied to that machine or device. For example, if
a cookie on a third party website recognises that a particular product was purchased from a
particular device, that cookie may “talk to” marketing cookies on the Website to ensure
advertisements about similar products displayed on the Website are accessed from that
device. These cookies are also used to limit the number of times a user sees an
advertisement, as well as to help them measure the effectiveness of an advertising
campaign. They may also remember that the Website has been visited from a device and
share that information with marketing organisations. The marketing cookies on the Website
are operated by third parties with our permission. Marketing cookies are used to monitor
from which advertising source a user was directed towards the Website, so that we know
whether it is worth us investing in that particular advertising source.
Website, and if we introduce any new cookies to the Website. When you first visit the Website a
box/banner will appear asking you to agree to the cookies that we set on the Website.
You can usually choose to set your browser to warn you when a cookie is being sent or to remove
or reject cookies. Each browser is a little different, so look at your browser Help menu to learn the
correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect
many features or services on our Website.
If you agree to cookies from our Website by clicking on the "I agree" button, we will set cookies
from category D on your device. If you wish to delete the cookies we have set on your device,
please refer to your browser Help menu.
If you do nothing to indicate your cookie preference for our Website (i.e. if you do not click on "I
agree"), category D cookies will not be set on your device. To modify your cookie settings, please
refer to the Help menu of your browser.
If you say no to cookies on our Website , we will not set category D cookies on your device. Please
note that if you do this you may not be able to use the full functionality of our Site.
CHANGES TO THIS PRIVACY AND COOKIES POLICY
We keep this Policy under regular review. We may change this Policy from time to time by updating
this page in order to reflect changes in the law and/or our privacy practices. The date at the top of
this Policy will be updated accordingly.
We encourage you to check the date of this Policy when you visit the Website for any updates or
changes. We will notify you of any modified versions of this Policy that might materially affect the
way we use or disclose your personal information.
CONTACT AND ADDRESS DETAILS
If you have any questions about this Policy, please contact us by e-mail at firstname.lastname@example.org,
or by mail at:
UK Raffles 2019 Ltd, Kemp House, 160 City Road, London, EC1V 2NX.