Privacy

How Winnow Lotto collects, uses, and protects personal information.

Important placeholders you must fill in

  • Data controller: [LEGAL ENTITY NAME] ([REGISTERED ADDRESS])
  • Contact email for privacy requests: [PRIVACY EMAIL]
  • Supervisory authority (if applicable): [DATA PROTECTION AUTHORITY]
  • International transfers mechanism (if applicable): [SCCs / ADEQUACY / OTHER]
  • Last updated date: [DATE]

1) Who we are (data controller)

This Privacy Policy explains how [LEGAL ENTITY NAME] (“Winnow”, “we”, “us”) collects and processes personal information when you use the Winnow Lotto website and related services (“Service”).

Contact: [PRIVACY EMAIL].

2) What personal information we collect

  • Account data: name, email, phone, country/currency preferences.
  • Identity & verification data (where required): date of birth, address, and documents/verification results (KYC/AML).
  • Order and transaction data: purchases, products, entry details, wallet activity, payment status (we may store tokenised payment references via processors, not full card numbers).
  • Communications: support requests, emails, and messages you send us.
  • Device and usage data: IP address, browser type, device identifiers, logs, and diagnostic data.
  • Cookies: identifiers and preferences stored on your device (see Cookies section below).

3) How we use your information

  • To create and manage your Account.
  • To process Orders, provide results, and administer winnings and wallet balances where applicable.
  • To verify identity/age/location and comply with legal obligations (including AML/KYC where applicable).
  • To prevent fraud, misuse, and unauthorised access.
  • To provide customer support and send service messages (e.g., receipts, confirmations, security alerts).
  • To improve the Service (analytics, debugging, performance).
  • To send marketing where permitted and where you have consented or where lawful (you can opt out anytime).

4) Legal bases (GDPR/UK GDPR where applicable)

  • Contract: to provide the Service and fulfil Orders you request.
  • Legal obligation: to comply with laws (e.g., AML/KYC, accounting, fraud prevention).
  • Legitimate interests: to operate, secure, and improve the Service and to prevent abuse.
  • Consent: for optional marketing communications and certain cookies (where required).

5) Who we share information with

We do not sell your personal information. We may share it with:

  • Service providers: hosting, analytics, email/SMS delivery, fraud prevention, customer support tooling.
  • Payment providers: to take payments and process refunds/chargebacks.
  • Operational partners: where needed to fulfil the service model (e.g., ticket messenger/courier operations) [IF APPLICABLE].
  • Professional advisers: auditors, lawyers, and consultants where necessary.
  • Authorities: where required by law, regulation, or court order.

6) International transfers

Your information may be processed in countries outside your own. Where GDPR/UK GDPR applies and data is transferred internationally, we use appropriate safeguards such as [SCCs / ADEQUACY / OTHER].

7) Data retention

We keep personal information only as long as necessary for the purposes described above, including legal, accounting, and fraud-prevention requirements. If you close your account, we may retain a limited subset of data to meet legal obligations.

8) Security

We use administrative, technical, and organisational measures designed to protect personal information (including encryption in transit and controlled access). No system is 100% secure; please use strong passwords and keep your credentials private.

9) Your rights

Depending on your location, you may have rights including:

  • Access to your personal information
  • Correction of inaccurate data
  • Deletion (where applicable)
  • Restriction or objection to processing (where applicable)
  • Data portability (where applicable)
  • Withdraw consent (where processing is based on consent)

To exercise these rights, contact [PRIVACY EMAIL]. We may request verification of your identity before responding.

10) Cookies

We use cookies and similar technologies to keep you logged in, remember preferences, measure performance, and improve the Service. You can control cookies through your browser settings. Some cookies are necessary for the Service to function.

11) Children

The Service is not intended for children. You must be at least 18 (or the legal age in your jurisdiction) to use the Service.

12) Changes to this policy

We may update this Privacy Policy from time to time. The “Last updated” date below shows when it was last changed.

Last updated: [DATE]