Date: 27 July 2020

This notice describes how Walleto Limited collects and uses your personal data in the context of the Lotto Sharers Website (the “Website”) including all its services and functions. The terms “we”, “us”, “our” refer to Walleto Limited. For more information on our contact details see ‘Contacting Us’. We are committed to safeguarding the privacy of our Website users. Therefore, we encourage you to read this notice carefully.

1. What information do we collect?

2. How we collect your data

3. The purposes for which your data is used

4. Legal basis

5. Information sharing

6. Security of your personal data and data retention

7. International data transfers

8. Your Rights

9. Right to Access

10. Changes to Privacy Policy

11. Contacting Us

1. What information do we collect?

By using the Website, we collect and further process the following personal data:

i)Information that you provide at the time of registering for use of, or access to, the Website. For example, requesting further services, registering for newsletters or other communications, entering a contest or promotion sponsored by us, reserving place for participation in our marketing activities or reporting a problem with the Website.

ii)Details of your visits to our Website including, but not limited to, traffic data, location data and other communication data, and the resources of the Website that you access and how you use them; session time; number of sessions within the time unit; number of payments within one session; amount of payment; payment type (regular/stream); successful/failed payments.

iii)Your IP address, which we automatically receive and record when you interact with our Website.

2. How we collect your Data

Most of the personal data we process is information that you knowingly provide to us directly.

If you refuse to provide personal data that we require for the performance of a contract or compliance with a legal obligation, we may not be able to provide all or parts of the services you have requested from us.

3. The purposes for which your Data is used

We use information that we collect about you or that you provide to us, including any personal data for the following main purposes:

i)To carry out our agreement with you, including payments.

When you enter into an agreement with us, we process your personal data for the purpose of delivering you the products and services. This includes the processing of personal data relevant for concluding the agreement and the performance of obligations of both parties.

ii)To communicate with you

We use your contact details to communicate with you, answer your questions or when we handle your complaints.

iii)For statistical research

General. We use automatic tools to perform statistical research into general trends regarding the use of our services, websites and social media and the behaviour and preferences of our customers and users. We also send periodically enquiries to our customers and prospects to gain insight in their opinions and preferences.

Data. To perform our research, we may merge and analyse the different types of data as described above. We may also combine such aggregated data with information we receive from our group companies or from market research. Without your consent we will not use sensitive data for this statistical research.

Interests and benefits. Statistical research helps us to develop better services and offerings, to provide more responsive customer support and to improve the design and content of our websites and products.

iv)For direct marketing

General. We may use your personal information to send you newsletters, magazines, promotions or other marketing communications.

Categories of data. To understand what is relevant for you we may use automatic tools to analyse your personal information. For this purpose, we may use and combine the information described above. We may also combine such data with information we receive from our group companies or from other sources, such as market research or public information. Without your consent we will not use sensitive data for statistical research.

Interest and benefits. We use the results of our analysis to tailor our marketing communications to you, specific interests and preferences. For example, if we notice that you work in a specific sector, we may customize our offers to this sector.

Channels. We use different channels for our marketing communications, such as emails and social media.

Object or revoke. You may object or revoke your consent for receiving marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us (see below).

v)To comply with statutory obligations

We may be required by law to collect and share your identifying information and personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.

We only send you emails with updates and special offers with your prior opt-in. You can unsubscribe from these commercial emails with updates and special offers any time by clicking the unsubscribe link in the email or by contacting us (see below). You may object to the use of your personal data for direct marketing purposes anytime (please see 'Your Rights').

4. Legal Basis

We collect, use and store your personal data to provide services to you, to comply with the legal obligations we are subject to, if necessary, for our legitimate interests or the interests of a third party or on the basis of your consent.

You may withdraw your consent at any time by following the specific instructions in relation to the processing for which you provided your consent, by adjusting your settings (if available) or by contacting us (see below).

When we process your personal data for our legitimate interests or the interests of a third party, we have balanced these interests against your legitimate interests. Where necessary we have taken appropriate measures to limit implications and prevent unwarranted harm to you. Our legitimate interests may for example include security and safety purposes, improving the Website or to provide better services and offers to you. For more information on these interests, please see the purposes for which we process your personal data above. Where we process your personal data for our legitimate interests or the interests of a third party, you have the right to object at any time on grounds relating to your particular situation (see 'Your Rights' below).

Where we process your personal data for a purpose other than that for which we collected it initially (and we rely on a legal basis other than consent or complying with legal obligations for this new purpose), we will ascertain whether processing for this new purpose is compatible with the purpose for which the personal data was initially collected.

5. Information Sharing

We may share personal data that we collect with our subsidiaries, corporate affiliates and Google Analytics. These third parties are bound by contractual obligations to keep personal data confidential and may only use information about you to perform services on our behalf, except to the extent that they are required to do so by law or in connection with any legal proceedings or prospective legal proceedings. All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.

In addition to the disclosures for the purposes identified elsewhere in this Privacy Policy, we may disclose information about you:

(i)to the extent that we are required to do so by law;

(ii)in connection with any legal proceedings or prospective legal proceedings;

(iii)in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); and

(iv)to the purchaser or seller (or prospective purchaser or seller) of any business or asset which we are (or are contemplating) selling or purchasing.

Except as provided in this Privacy Policy, we do not intend to sell, share or rent your information to third parties.

6. Security of your Personal Data and Data Retention

We have taken appropriate technical and organizational measures to protect your personal data against unauthorized use, unauthorized access and wrongful modifications, loss or destruction. Where we have given you (or where you have chosen) a username or password, you are responsible for keeping these credentials confidential. We ask you not to share your credentials with anyone.

Your personal data will be stored no longer than is necessary for the purpose they were obtained for, our compliance with legal and fiscal obligations, or for solving any disputes but not longer than 3 (three) years.

7. International Data Transfers

The collected data may be transferred to trusted third parties in countries outside of the European Economic Area for the purposes mentioned above. We will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable data protection law and regulations. These transfers of data outside the European Economic Area shall only occur on the basis of a legally recognized transfer mechanism, such as the Standard Contractual Clauses “(EU-) controller to (Non-EU/EEA-) processor” Decision 2010/87/EU (see Article 46 GDPR).

The European Commission has determined that certain countries outside the European Union offer an adequate level of data protection (see Article 45 GDPR). You can find an overview of these countries here.

8. Your Rights

Providing the required data is necessary for you to use the Website. If you do not wish to provide the required data, you cannot use the Website. When you use the Website, and provide the required data, you can contact us (see below) to exercise any of the rights you are granted under applicable data protection laws, which includes:

(i)the right to access your data;

(ii)to rectify it;

(iii)to erase it;

(iv)to restrict the processing of your data;

(v)the right to receiving a file of your personal data; and

(vi)the right to object to the processing, and where we have asked for your consent, to withdraw this consent.

These rights may be limited in some situations. We may, for example, deny your request for access when necessary to protect the rights and freedoms of other individuals or refuse to delete your personal data in case the processing of such data is necessary for compliance with legal obligations. The right to data portability, for example, does not apply in case the personal data was not provided by you or if we process the data not on the basis of your consent or for the performance of a contract.

When you would like to exercise your rights, please send your request to the contact details in 11 below. Please note that we may need you to provide additional information to confirm your identity. You also have the right to lodge a complaint with the Information Commissioner’s Office in the UK, place of work or of an alleged infringement of your rights regarding your personal data.

9. Right to Access

You may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy. When complying with an access request, we will also provide you with additional information, such as the purposes of the processing, the categories of personal data concerned, as well as any other information necessary for you to exercise the essence of this right.

A)Right to rectification

You have the right to have your data rectified in case of inaccuracy or incompleteness. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.

B)Right to erasure

You also have the right to have your personal data erased, which means the deletion of your data by us and, where possible, any other controller to whom your data has previously been made public by us. Erasure of your personal data only finds place in certain cases, prescribed by law and listed under article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data is no longer necessary in relation to the initial purposes for which it was processed as well as situations where it was processed unlawfully. Due to the way we maintain certain services, it may take some time before backup copies are erased.

C)Right to restriction of processing

You have the right to obtain the restriction of the processing of your personal data, which means that we suspend the processing of your data for a certain period of time. Circumstances which may give rise to this right include situations where the accuracy of your personal data was contested but some time is needed for us to verify its accuracy. This right does not prevent us from continue to store your personal data. We will inform you before the restriction is lifted.

D)Right to receive a file (data portability)

Your right to data portability entails that you may request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.

E)Right to object

You also have the right to object to the processing of your personal data, which means you may request us to no longer process your personal data. This only applies in case the ‘legitimate interests’ ground constitutes the legal basis for processing (see ‘Legal basis’ above).

At any time and free of charge, you can object to direct marketing purposes in case your personal data is processed for such purposes, which includes profiling purposes to the extent that it is related to such direct marketing. In case you exercise this right, we will no longer process your personal data for such purposes.

10. Changes to Privacy Policy

We may update this privacy policy from time-to-time by posting a new version on this page and, at our discretion, provided to you by email or via the Website.

11. Contacting Us

If you have any questions about this Privacy Policy or the Website please feel free to contact us at Walleto Limited, 71-75 Shelton Street, London, WC2H 9JQ, UK, by phone at +44 207 117 2455 or by email at

This Privacy Policy has been prepared in various languages. In the event of any inconsistency, the English version shall apply and be binding upon the parties.