Donr Lottery: Privacy Policy

Last updated: 10th January 2022

This Privacy Policy sets out how ImpulsePay Ltd (“ImpulsePay”, “we”, “us”, or “our”) collects and uses your personal data when you use our website to purchase a lottery ticket to any of our charity clients services. This website is not for children and we will never knowingly collect data relating to children.

 

Who We Are:

ImpulsePay Ltd, a limited company registered in England and Wales (CRN: 04395570) with registered address at The Stables, Back St. St Georges Terrace, Jesmond, Newcastle Upon Tyne, NE2 2SU.

If you have any queries or are unhappy with how we are using your personal data, you should contact us in the first instance at help@donr.com so that we can consider the issue and seek to resolve it. You also have the right to complain to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues at ico.org.uk.

 

Changes to this Policy

We keep this Privacy Policy under regular review and any relevant changes or updates will be posted on this page and, where deemed appropriate, via email to you. The new/updated policy may be displayed onscreen when using this website and you may be required to read and accept the changes to continue using the website.

This version was last updated on 10th January 2022.

 

Third Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

What personal data do we collect about you and how is it collected?

Personal data/information means any information from which you could be identified. It doesn’t include data where your identity has been anonymised or removed.

The only way in which we will collect your personal data is when you directly provide it to us in the course of entering our lottery. When you participate, the only personal information we will collect is:

Contact Data: name, address, and email address.

We will never ask for or require special category personal data (information about race, ethnic origin, trade union membership, health/genetic or biometric data.

Where we need to collect personal data by law or to facilitate your participation and you fail to provide that data, we won’t be able to process your entry.

 

How will we use the personal data we collect about you?

We will only use your personal information when the law allows us to. Most commonly we will use your personal data:

  • Where we need to perform the contract we are about to enter into or have entered into with you;
  • 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;
  • Where we need to comply with a legal obligation; or
  • Where we have your explicit consent which you will be able to withdraw at any time by contacting help@Donr.com.

We have set out below a description of the ways we plan to use your personal data and the legal basis we are relying on.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To process and deliver your ticket including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) To contact you in the event you win a prize

Contact and Payment Data

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover money due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to this privacy policy

(b) Asking you to leave a review or take a survey

(c) Handling any queries/complaints

Contact Data

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

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

Contact Data

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Marketing

We won’t provide you with marketing material without your explicit prior consent.

 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.Donr.com/cookie-policy.

 

Who do we share your personal information with?

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • The following third parties: charities (that are controllers in their own right with their own privacy policies that you should check) that you are making donations to, Hubspot that provide software services to us, IT service providers, our professional advisors (e.g. lawyers, banks, auditors, insurers etc.), and HM Revenue Customs, the Charity Commission, the Gambling Commission, regulators and other authorities acting as joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy 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 own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International Transfers

Some of our external third parties (e.g Google Analytics) are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, please contact us or visit the Information Commissioner’s website at ico.org.uk .
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, please contact us or visit the Information Commissioner’s website at ico.org.uk.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

How long will you retain my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting, or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.

 

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.