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Privacy Policy

The Jackpot Community Trust (SC052059) (the “Trust”) is the charitable body responsible for distributing good cause funding generated through the following society lotteries: The Scotto, What a Lotto and the Scottish Children’s Lottery (together, the “Lotteries”). All three Lotteries are owned and operated by MBC ELM Limited (“MBC ELM”).

The Trust has appointed MBC ELM Limited, a company registered in Scotland (Company Number SC513712), with registered office at 147 Bath Street, Glasgow, G2 4SN, to promote and manage the Lotteries and to carry out the majority of the Trust’s operational functions. MBC ELM acts as data controller in relation to personal data collected in connection with the Lotteries and their players.

The Jackpot Community Trust, registered at 147 Bath Street, Glasgow, G2 4SN, acts as data controller in relation to personal data collected through direct contact with the Trust (for example, via the JCT website contact page) and through the online grant platform used by charitable organisations applying for funding.

This Privacy Policy explains how both MBC ELM and the Jackpot Community Trust collect, use, store and protect your personal data, and describes the rights you have in relation to that data.

By using the Lotteries’ services or interacting with the Jackpot Community Trust, you are presumed to have read and understood this Privacy Policy.

We update this Privacy Policy from time to time and recommend that you check back periodically. If we make significant changes we will notify you either when you access our services or by other means such as email.

Contents

  • What data is collected about you and when?
  • Why we collect data and how we use it
  • Security
  • Sharing of your data
  • Marketing and other communications
  • Cookies and other tracking technologies
  • Telephone calls
  • Links to other sites
  • Data retention
  • Your rights
  • Contact details

 

1. What Data is Collected About You and When?

Lottery Players (Data Controller: MBC ELM Limited)

When you use the Lottery services, some personal data will be collected as follows:

Registration

When you register and open an account with any of the Lotteries, we collect your name, email address (and a password), postcode and postal address, telephone number, date of birth and banking details. We may also collect some of this information when you interact with us via our customer service team.

Correspondence

Any personal data you provide when you communicate with us via any means such as by email, phone or post, and via our customer service team with any comments or questions.

Financial

Your bank account details (including account number, sort code and account holder name). This also includes transaction details including payments from you, ticket purchases, payments made to you (withdrawals and winnings), bonuses and vouchers given to you and used by you, details of games played and the outcomes of those games.

Analytical

Information about how you use the services including, for example, the frequency of your visits, the amount you spend (both in a single transaction and over a period of time), and your preferences relating to our services.

Technical

Information about your device or browser when you use our website, date and time of visits and page view data.

Marketing

Your instructions as to whether or not you wish to receive digital marketing communications from MBC ELM Limited.

Data from Other Sources

We may also receive personal data from various third parties, such as Bacs Payment Schemes Limited and The Access Group. We may also utilise publicly available sources including search engine results and social media pages.

You may ask us to amend your details or close your account by contacting us at help@thescotto.com (The Scotto), help@whatalotto.com (What a Lotto) or help@scottishchildrenslottery.com (Scottish Children’s Lottery) and we will action your request as soon as reasonably practicable.

Grant Applicants and Charitable Organisations (Data Controller: Jackpot Community Trust)

When a representative of a charitable organisation interacts with the Jackpot Community Trust – whether by contacting us directly through our website or by registering and using the online grant platform provided by Good Grants – we collect personal data about that individual and information about their organisation. This may include, but is not limited to:

Individual Contact Details

  • Name
  • Address
  • Email address
  • Contact telephone number(s)
  • Position or role within the organisation

 

Organisation Information

  • Charity name and registered address
  • Charity registration number
  • Email address and contact telephone number(s)
  • Description of charitable activities and work
  • Number of people supported
  • Financial information including accounts and funding details
  • Details of funding applications, project descriptions and outcomes
  • End-of-grant reports and impact evidence

Where you contact the Trust directly via the JCT website, we will collect any personal data you provide as part of that correspondence.

 

2. Why We Collect Data and How We Use It

Data protection and privacy laws permit us to collect and use your personal data on a limited number of grounds. The key grounds upon which we rely are one or more of the following:

  • Where we need it to perform the contract or agreement we have with you.
  • Where it is necessary for our legitimate interests and/or those of a third party (where applicable) and your interests and fundamental rights do not override those interests.
  • Where we have your consent.
  • In order to comply with a legal or regulatory obligation.

 

3. Security

The security of your data is important to us. We have technical and operational security policies in place to protect the data we collect, use and store against unauthorised access or disclosure, improper use, alteration, unlawful or accidental destruction or loss.

Any data transmitted via our websites or the grant platform is encrypted at all times whilst in transit over the internet. We use Secure Sockets Layer (“SSL”) technology, a special protocol that automatically encrypts any data sent by you on our secure pages.

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 are subject to a duty of confidentiality.

Please be aware that the sending of information through the internet is not completely secure. We do not guarantee the security of data transmitted over the internet and you accept the inherent security implications of using the internet.

Avoiding Lottery Scams

Scammers may use emails, phone calls or letters which try to trick you into thinking you have won a lottery prize, and may use real or convincing company logos. They may ask you for money to release a prize or for your personal details to steal your identity.

If you are in any doubt about an email you have received, please do not select any links in it. Instead, type the website address directly into your browser. We will never ask you for money to release a prize and we do not give details of winning prize amounts in our emails.

Use Email Safely

  • Do not open emails which you suspect as being scams.
  • Do not forward emails which you suspect as being scams.
  • Do not open attachments from unknown sources.

 

Avoiding Fraud

  • Do not pay money to anyone who claims you have won.
  • Do not give your details to someone who contacts you unexpectedly.
  • Do not select links in unsolicited emails, even if they use a real company’s name or logo.
  • You cannot win a lottery unless you have entered. You must be a player of one of our Lotteries to win a prize with us.
  • If you are unsure about any communication you receive, please contact the relevant customer service team for the Lottery in question.

 

Report a Scam

If you think you have been the victim of a scam, contact Action Fraud on 0300 123 2040 or visit https://www.actionfraud.police.uk/

For more information about online security, visit www.getsafeonline.org

 

4. Sharing of Your Data

Lottery Player Data (MBC ELM Limited)

We share lottery player data in the following ways:

  • When we carry out identity and due diligence checks as required by law.
  • When we engage data processing companies to help provide the lottery services, such as our lottery platform provider Bonobo PLC, marketing service providers to enable us to send you emails, and other suppliers to manage your account, provide customer services and provide usage analytics. These companies must comply strictly with our instructions and we do not permit them to further use or share your data.
  • In order to process financial transactions and pay any prize winnings, we share your data with banks and payment processors; in particular we use Access Group to securely process transactions.
  • Where we are required by law or regulation to do so, and/or to protect the rights, property or safety of the Lotteries, MBC ELM, our customers or others.
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • To our professional advisors (including legal, accountancy and audit), where necessary for the provision of their services to us.
  • The Gambling Commission, the police, and other relevant regulatory bodies, for the purpose of complying with our regulatory requirements and in connection with any investigations into suspected fraud or other criminal activity.

 

Grant Applicant Data (Jackpot Community Trust)

We share grant applicant and charitable organisation data in the following ways:

  • With Good Grants, the provider of our online grant platform, who process data on our behalf strictly in accordance with our instructions and applicable data protection law.
  • With the Jackpot Community Trust Board, for the purposes of reviewing, assessing and making decisions on funding applications.
  • With MBC ELM employees who carry out operational functions on behalf of the Trust, including the administration of the grant programme.
  • With our professional advisors (including legal, accountancy and audit) where necessary.
  • Where we are required by law or regulation to do so.

 

5. Marketing and Other Communications

Lottery players will receive service emails about their accounts or to update them on any material changes to Terms and Conditions, privacy and cookies policies.

Where you have agreed, we will also send promotional messages about the Lotteries by email, SMS and e-newsletter. We may also communicate with you by phone and text. All communications will be clearly marked and will include information that enables you to stop promotional communications at any time.

You can opt out of receiving email communications by following the unsubscribe link at the bottom of the relevant emails or by contacting us directly. You can also manage your marketing preferences via your account profile. Please note that if you opt out of marketing communications, we will still contact you with customer servicing or operational information about your player account.

Grant applicants and charitable organisations will receive communications from the Jackpot Community Trust relating to the administration of the grant programme, including acknowledgements, assessment updates, decisions and reporting requirements.

6. Cookies and Other Tracking Technologies

When you access our lottery services or the JCT website you are asked to give permission for cookies. Our services use cookies and similar tracking technologies to operate, personalise and enhance their performance and to distinguish you from other users.

Your web browser or device may also provide us with information about your device, such as a device identifier or IP address.

For more information on the types of cookies we use, what we use them for and how to manage your cookies, please see our Cookie Policy.

7. Telephone Calls

If you phone our customer service team, your call may be recorded. We use these recordings for training and quality assurance purposes. Recordings can also help us to resolve queries quickly.

8. Links to Other Sites

Our websites may provide links to third party websites which apply their own privacy policies. Please note that this Privacy Policy does not apply to any such third party website. We do not control third party websites and have no responsibility for them.

9. Data Retention

Lottery Player Data

We will hold your personal data on our systems for as long as you use the lottery services and as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We keep your personal data for seven years after you close your account, after which we will either delete or anonymise your data for statistical purposes.

Grant Applicant and Charitable Organisation Data

Personal data and organisational information collected through the grant platform or through direct contact with the Jackpot Community Trust will be retained beyond the grant cycle. Given the Trust’s obligations around transparency, accountability and the long-term reporting of good cause funding, this data is retained indefinitely to support audit, historical reporting and compliance purposes.

We may anonymise data (so that it can no longer be associated with you or your organisation) for research or statistical purposes, in which case we may use this information indefinitely without further notice.

10. Your Rights

You have various rights in relation to the personal data we hold about you, including the right to:

  • Request access to a copy of the personal data we hold about you (commonly known as a “data subject access request”).
  • Request correction of any inaccurate personal data we hold about you.
  • Request erasure of your personal data, where there is no good reason for us continuing to process it. Note that we may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object.
  • Request restriction of processing of your personal data in certain circumstances.
  • Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
  • Data portability – the right to request the transfer of a copy of your personal data in an electronic format where the basis of processing is consent or contract and processing is by automated means.
  • Make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

You will not have to pay a fee to access your personal data or to exercise any of the other rights listed above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

11. Contact Details

If you have any questions about this Privacy Policy or wish to exercise any of your legal rights, please contact us using the details below:

For Lottery Player Data Queries (MBC ELM Limited)

Email: dp@thescotto.com

Post: Data Protection, MBC ELM Limited, 147 Bath Street, Glasgow, G2 4SN

For Grant and Charitable Organisation Data Queries (Jackpot Community Trust)

Email: charity@jackpotcommunitytrust.com

Post: Data Protection, Jackpot Community Trust, 147 Bath Street, Glasgow, G2 4SN