Privacy Notice

Lottery Stupore values the privacy of our website visitors and members. We strive to safely store our customer's personal information within a secured system.

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We aim to inform and establish trust with our users by transparently explaining how and where their personal information is used. Lottery Stupore abides by all personal information protection regulations.

Information Collection: We collect certain personal information such as name, address, phone number, mobile number, email address, nationality, and date of birth to facilitate our services. By registering, users are deemed to have given their consent. We may use cookies for data collection to enhance user experience and analyze website usage. Users can opt-out of cookie use.

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Purpose and Range of Information Use: The collected personal information is used for:

• Identification and verification for the use of member services and for processing winnings from the 6/45 Korean tax.

• Communication, ensuring smooth communication regarding purchase history and winning details.

• Notifying of new services, promotions, or events.

• Delivery of official documents in case of major winnings.

• Transactions requiring refunds or exchanges.

 

Lottery Stupore uses customer's personal information within the stated range and never provides or uses it beyond the said scope for its profit or any third party's benefit. However, in compliance with legal requests, data may be provided to governmental bodies after legal review.

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Accessing and Editing Personal Information: Customers can view or edit their information at any time by clicking on "Edit Profile" on the Lottery Stupore website. Requests can also be sent to our data protection officer.

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Provision and Outsourcing of Personal Information: We do not provide personal data to third parties without the user's consent.

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Destruction of Personal Information: Once a user de-registers, their personal information is deleted immediately, unless a separate retention agreement exists or there's a legal mandate to retain the information.

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For legal retention periods, refer to laws such as the Consumer Protection Law in Electronic Commerce, Electronic Financial Transactions Act, and Communication Secrets Protection Act. Lottery Stupore ensures data is stored securely and not used for other purposes.

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Personal Information Protection System: Technical measures are in place to prevent loss, theft, leakage, alteration, or damage of personal data. Data is encrypted, protected by passwords, and safeguarded by security software against potential threats. We also have intrusion detection and vulnerability analysis systems to ensure maximum security.

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Linked Sites: Lottery Stupore may provide links to other websites. We do not have control over these sites, and their privacy policies might differ from ours. Users are advised to review the privacy policies of sites they visit.

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User's Rights and Obligations: Users can view or modify their personal information anytime and can also withdraw their membership. It's the user's responsibility to provide accurate information to avoid potential issues. It's also the user's responsibility to ensure that they do not violate the rights of others, including personal information and posted content.

 

Feedback and Complaints: Customers have the right to receive prompt and sincere answers to their questions. Lottery Stupore has established a customer service center for effective communication.

 

Data Protection Officer: Personal Data Protection Officer & Customer Satisfaction Team Contact: E-mail: contact us

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Supplementary Provision: This personal data protection policy is effective from August 24, 2023.

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1. HOW WE USE YOUR PERSONAL DATA

PURPOSE FOR WHICH WE USE YOUR PERSONAL DATA We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Where we need to perform the contract we are about to enter into or have entered into with you. b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. c) Where we need to comply with a legal or regulatory obligation. d) When you provide us with explicit consent to do so.

PROCESSING ACTIVITIES We strive to process your personal data in a transparent manner. Here are the primary reasons and purposes for which we might process your personal data:

• To register you as a new customer.

• To process your order, manage your account, and if necessary for our services, verify your identity.

• To manage our relationship with you, which may include notifying you about changes to our terms or privacy policy.

• To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

• To use data analytics to improve our website, products, services, marketing, customer relationships, and experiences.

• To suggest and recommend goods or services that might be of interest to you.

OPTING OUT You have the right to opt-out of marketing messages at any time. You can do this by contacting us at any time. Once you opt out, we will remove you from our marketing lists and stop sending you further marketing communications.

1. DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with third parties for the purposes set out in this policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA). If this policy changes in the future, we will notify you and ensure that safeguards are in place to protect your data as per the GDPR standards.

1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to request access to, correction, or deletion of your personal data, object to processing of your data, request restriction of processing, request transfer, and the right to withdraw consent.

1. DISCLOSURE OF YOUR PERSONAL DATA We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

External Third Parties including:

• Service providers who provide IT and system administration services.

• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

• Lottery Stupore partners and other parties we work with in order to provide our services to you.

• Authorities, including regulatory bodies, law enforcement agencies, or courts when required by law or when we believe disclosure is necessary to protect our rights or comply with a legal obligation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

1. DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

1. DATA RETENTION We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

1. YOUR LEGAL RIGHTS You have rights under data protection laws in relation to your personal data. This includes the right to request access, correction, erasure, restriction, transfer, to object to processing, to the portability of data, and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please Contact us.

1. CONTACT DETAILS If you have any questions about this privacy notice or our data protection practices, please Contact us using the details provided on our website.

2. CHANGES TO THIS NOTICE We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website or services. We advise you to print a copy for your records.

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MARKETING We strive to provide you with choices regarding certain personal data uses, especially around marketing and advertising. Review and adjust your preferences for the use of your personal data in the My Account section of the website.

PROMOTIONAL OFFERS FROM US We may use your Identity, Contact, Technical, Usage, and Profile Data to determine what might be of interest to you. This helps us decide which products, services, and offers might be relevant (we call this marketing). You will receive marketing communications from us if you have requested information or have purchased products or services, and haven't opted out of marketing communications.

OPTING OUT At any time, you can stop marketing messages by adjusting your preferences on our website or using the opt-out links in our communications. Opting out of marketing doesn't affect data used for other transactions.

CHOICE You always have a choice regarding the provision of Personal Information. If you decide against providing Personal Information, some features and offers might be inaccessible.

CHANGE OF PURPOSE Your data is used for the reasons it was collected unless we need it for another compatible reason. If we require it for an unrelated reason, we'll notify you. Sometimes, we might process data without consent, if legally required or permitted.

5. DISCLOSURES OF YOUR PERSONAL DATA Your Personal Information is private. We don't sell or rent it. Sometimes, we might share it for the purposes mentioned in paragraph 4.

• Internal Third Parties as detailed in the Glossary.

• External Third Parties as detailed in the Glossary.

GOOD FAITH DISCLOSURE In good faith, we might disclose information for legal processes, enforcing our terms, addressing fraud or security, or protecting our company and users.

MERGER, SALE OR BANKRUPTCY If our company merges, is acquired, or goes bankrupt, your Personal Information might be transferred or assigned. In such events, your data would fall under the new entity's privacy policy.

6. INTERNATIONAL TRANSFERS Your data might be shared globally, sometimes outside the European Economic Area (EEA). We ensure your data's safety by:

• Transferring to countries approved by the European Commission.

• Using European Commission approved contracts when transferring to countries without an ‘adequacy decision’.

For more details about international transfers, please contact us.

7. DATA SECURITY We prioritize the safety of your Personal Information using industry standards. While we strive for complete security, no internet-based method guarantees it. If you have security concerns, reach out to us.

8. DATA STORAGE AND RETENTION Your data may be stored in the EU/EEA on our or third-party servers. We keep your data as long as necessary, governed by various factors including legal requirements. Sometimes, you might be able to request data deletion. Some data might be anonymized for indefinite use.

9. YOUR LEGAL RIGHTS You have several rights regarding your data, such as access, correction, erasure, and others. To learn more or exercise any right, contact us.

Usually, accessing your data is free unless your request is excessive or unfounded.

To process requests, we might need to confirm your identity or ask for more details. We aim to respond within a month, but complex requests might take longer.

COMMITMENT Your privacy is paramount to us. We continually adapt to ensure your online privacy. If you have feedback or questions about our Privacy Notice, reach out to us.

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1. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Group acting as processors and who are based in Romania and provide IT and system administration services and undertake leadership reporting.

EXTERNAL THIRD PARTIES

• Service providers acting as processors based in Israel who provide IT and system administration services.

• Service providers acting as processors, based in Malta and the Netherlands providing data hosting services.

• Service providers acting as processors such as GB Group plc (GBG), Aristotle, and Acuris based in the UK and the US providing anti-fraud, customer due diligence, anti-money laundering, and sanctions checks.

• Service providers such as WalkMe and Hotjar, acting as processors based in Israel and Malta who provide marketing services.

• Service providers such as Data Dog and Humio acting as processors based in Israel and Malta who provide logging tools.

• Service providers such as Twillio, BriteVerify, SendGrid, Google Cloud Messaging (GCM), Apple Push Notification service (APNs), and Trustpilot acting as processors based in Ireland, UK, and Denmark who provide communication services.

• Service providers acting as processors based in Cyprus and the UK who provide payment services.

• Professional advisers acting as processors including lawyers, bankers, auditors, and insurers based in Malta who provide consultancy, banking, legal, insurance, and accounting services.

• Inland Revenue department, regulators and other authorities acting as processors or controllers based in Malta who require reporting of processing activities in certain circumstances.

• Regulatory bodies, law enforcement bodies, and other authorities acting as controllers may request us to provide your personal data in certain circumstances.

• Lottery Operators such as the Lottery Stupore acting as processors or controllers who may require us to provide your completed prize claim form, identity details, and verification documentation for the purpose of collecting your wins.

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing of your personal data.

• Request the transfer of your personal data to you or to a third party.

• Withdraw consent at any time where we are relying on consent to process your personal data.