Tuckwell Chase Lottery (TCL) is committed to ensuring that your privacy is protected and respected, and to respect the personal information that you share with us when you support our charities via our lottery. We promise to look after your personal information, and not to use it in any way that you would not reasonably expect. This privacy statement and policy sets the basis for processing any personal information that you provide.

OUR PRIVACY PROMISE

We promise to follow the six principles of the General Data Protection Regulation (2016) set out at the end of this document, known as the GDPR, by:

• Keeping your personal information safe and private
• Only collecting the minimum of personal information necessary for the purpose of the lottery
• Not selling information to another organisation
• Exchanging information only with the founding charities
• Holding your personal information only for as long as absolutely necessary
• Ensuring that you are in control of how we use your information, and that you will always have the right to inform us how to use your data
• Contacting you only in your preferred ways and about your preferred interests
• Giving you ways to manage and review your communication preferences at any time
• Ensuring you can request access to the information we hold about you at any time

Consent

By using our website, social media pages or providing your information, you consent to our collection and use of the information you provide in the way(s) set out in this policy. If you do not agree to this policy please consider carefully the use of our website, social media pages or service.

About Tuckwell Chase Lottery

Tuckwell Chase Lottery Limited is committed to using our lottery to raise vital funds for Phyllis Tuckwell Memorial Hospice Limited (hereafter known as Phyllis Tuckwell Hospice Care) and Shooting Star Children’s Hospices responsibly.

Tuckwell Chase Lottery Limited is registered with the Information Commissioner and is fully supportive of the ICO’s (Information Commissioner’s Office) mission and guidance.

Privacy Policy in brief

The full Privacy Policy sets out in greater detail the information we hold, how we may use it, and what your rights are. Below is a simple summary of the main points, however it is important that you read the full policy.

• We collect information that is either personal data or non-personal data (such as web pages accessed) solely to enable us to support our charities via our lottery
• We collect information about our supporters, volunteers and employees
• Our lottery is not open to any person under the age of 18 years; therefore no information is collected relating to this age group
• We collect information so that we can fundraise for our dedicated hospices, for administration, profiling and analysis
• We collect information for the prevention and detection of crime
• We will ensure that you are only contacted in the ways, and by our selected partners, that you have consented to
• We will ensure that we update your data when you tell us to do so
• We will only collect the data that we need, or that would be useful to us to provide you with the best possible service and experience, and the minimum possible is kept once no longer required to provide our service
• We will do our very best to keep personal information secure whenever we collect it online
• We will never sell your data or share it with another company or charity for marketing purposes other than to support our specific charities, the exception being data of supporters of Shooting Star Children’s Hospices, where all data is shared with the charity
• We will only share data where we are required to do so by law or with the carefully selected partners we work with
• We will respond to your request to access to your information in a timely manner
• We will use our best endeavours to ensure any actual or potential data breach (the loss or unauthorised sharing of personal information) is detected, reported and the subject informed without undue delay

The Six Principles of the General Data Protection Regulation (2016)

1. Lawfulness, Fairness and Transparency
2. Purpose limitation
3. Data minimisation
4. Accuracy
5. Storage limitation
6. Integrity and confidentiality

1. Policy Scope

This policy applies to all Tuckwell Chase Lottery (TCL) staff, volunteers, our website, our use of email and text messages for marketing purposes and any other methods we use for collecting information.

It outlines the information we collect and why, what we do and what we will not do with your personal information, and your legal rights.

2. Definitions

Personal Information, or data, is information that can be used to help identify an individual, such as name, address, telephone number, email address and also now includes online identifiers (eg Cookies and IP address, which is the location of your computer on the internet). The term ‘data’ is used to refer to personal information for the purposes of this policy.

3. The data we collect and when we collect it

TCL will only ever collect the minimum amount of data necessary to enable us to carry out the lottery function which is:

• Personal information: your name, date of birth, email address, postal address, telephone number, credit/debit card details.
• Non-personal information such as web pages you may have accessed and files downloaded. We may use this information to personalise the way our website is presented when you visit it, to make improvements to the website and to ensure we provide the best service for users. This information does not tell us anything about who you are or where you live, it simply allows us to monitor and improve our service.
• Our lottery is not open to any person under the age of 18 years; therefore no information is collected relating to this age group

This data is collected in connection with specific activities mainly:

• At the point of registration for the lottery, whether directly to TCL, via our marketing agents, or via Phyllis Tuckwell Hospice Care or Shooting Star Children’s Hospices (both of whom comply with Fundraising and General Data Protection Requirements)
• When you make a purchase on our website www.tclottery.org.uk
• When you advise us of any changes
• When you subsequently log into our website or report a website problem
• When you contact us by telephone, email, or letter
• When you apply for a job with us (including sending us your CV)
• When you volunteer with us

4. How we use your personal data

Tuckwell Chase Lottery Limited is committed to using our lottery to raise vital funds for Phyllis Tuckwell Hospice Care and Shooting Star Children’s Hospices in a responsible manner. We collect information about you to:

• Fundraise for our dedicated hospices
• Process payments and verify financial transactions
• Record any contact we have with you
• Administer the lottery programme
• Provide you with information and communications about what we do, and other services and products related to our specified charities
• Carry out research on the demographics, interests and behaviours of our supporters, to gain a better understanding of them and to enable us to improve our service.
• Prevent or detect fraud, or abuses of our website
• Enable our partners (third parties) to carry out technical, logistical, marketing or other functions on our behalf
• Carry out obligations arising from any contract agreed between you and us
• To validate entitlement to play the lottery to comply with our licence requirements
• Investigate, and respond to, complaints, incidents, legal matters or other issues that may arise
• Send you information and communications relevant to your membership, employment or volunteering role
• Contact you if it appears you are experiencing difficulties with our on-line registration form once you have entered your contact details but have not finalised with ‘send’ or ‘submit’.

5. Who we share your data with

From May 2018 TCL will be using legitimate interest as the legal basis for processing data. This means that we will only share your information with third parties for the following reasons:

• Phyllis Tuckwell Hospice Care for administration purposes only, such as to ensure databases are as up to date as possible
• Shooting Star Children’s Hospices (SSCH) for administration purposes, and SSCH supporter marketing
• Mailing companies (who destroy the data after each specific mailing exercise)
• Marketing agencies working on behalf of TCL

We will never share your data so that you are contacted by any other organisation.

We will never sell your data.

6. Marketing

We will only send marketing information to individuals who have specifically consented to this or have a legitimate interest in our work.

When we send you marketing information via email, every message we send will include a link if you wish to request that we do not contact you this way in the future. Our e-marketing provider Mail Chimp is a participant in the Privacy Shield Framework which puts in place appropriate safeguards to protect your data, or otherwise ensure that we can transfer your data in a way that complies with data protection law. Mail Chimp’s Privacy Notice can be found here: https://mailchimp.com/legal/privacy/.

You can change your marketing preferences at any time by contacting us – see the end of this policy for contact details.

7. Digital Media

We may participate in various digital media ‘Custom Audience’ programmes, which enables us to display adverts to our existing supporters when they visit Facebook or other media sites. To do this we provide your email address, mobile number and address to enable identification of a registered account with them. Our advert may then appear when you access these sites in future.

Your data is sent in an encrypted format which is deleted by the organisation if it does not match with an account. We only receive data from these sites on the number of people within a specific ‘Custom Audience’ and are therefore unable to identify individuals within that audience.

For further information specific to Facebook please see Facebook Help: About Custom Audiences https://www.facebook.com/business/help/744354708981227 and the Facebook Data Policy https://www.facebook.com/policy.php

8. Automated decision making and profiling

To help us develop the lottery service, and offer our supporters the best experience possible, we may occasionally undertake profiling and automated decision-making activities, to identify key individuals who might be interested in specific services.

Before we do this, we will:

• Undertake a Data Protection Impact Assessment to identify and address any potential risks
• Via our website we will tell our supporters about any profiling or automated decision making carried out, what information is used to create the profiles and where it came from
• Ensure any data is anonymised before inclusion in any profiling activity

If you would prefer that your data is not used in this way, please contact us – see the end of this policy for contact details.

9. Payment processing

Your payments made via our website, using a debit card, or other method are encrypted using either of the three following organisations who each hold a privacy policy:

• WorldPay: https://www.worldpay.com/uk/privacy-policy
• Secure Collections: http://www.securecollections.com/terms-and-conditions
• Evergiving: https://www.evergiving.com/gdpr/
• Ideal Host:http://www.pdasolutions.co.uk/index.php?q=privacy_policy

TCL is compliant with the Payment Care Industry Data Security Standard, which is designed to keep credit and debit card payment data safe and secure.

10. Our Legitimate Interests

TCL will process data for certain legitimate organisational purposes. When you join the lottery we have a legitimate organisational interest to use your data to respond to you, and where there is no overriding prejudice to you by using your data for this purpose. This also includes:

• Where processing enables us to enhance, modify, personalise or otherwise improve our services, marketing and communications for the benefit of our users and supporters
• The identification and prevention of fraud
• A better understanding how our users and supporters interact with our website
• Providing postal communications that we believe might be of interest to you Determining the effectiveness of promotional campaigns and advertising
• Enhancing the security of our network and information services

11. Consent/Withdrawing Consent

You have the right at any time to object to TLC processing your data in the ways described, however in the future TLC will rely on obtaining your consent to use your personal information at the outset of any new interaction, such as when you first join our lottery.

You can change or withdraw your consent and advise us of your wishes at any time by contacting us – see the end of this policy for contact details.

12. How your data is stored and kept confidential

TLC takes the security of your data seriously and ensures that the information you give us is safe by:

• Storing data on a restricted access database with physical and electronic security controls to prevent loss, misuse and alteration
• Regular reviews of who has access to data, based on ‘need to know’ access only, including staff and volunteers
• Comprehensive checks of our third-party mailing house partners, with contracts that ensure compliance with current data protection legislation, ensuring data is held for the minimum period only required to complete their task
• Encrypting all data that is transferred to our third party partners (See 5. Who we share your data with), who then store data in line with General Data Protection Regulations
• Ensuring those who no longer need to access our website (e.g. members, staff, agents) are removed from the system at the appropriate time
• Checking our website regularly to identify malicious content or users

13. Retention and Destruction

TCL keeps your data only for as long as is necessary for us to carry out the lottery service to you. We may however need to keep some anonymised data for legal and regulatory reasons, and to continue to hold it for a number of years after you stop playing our lottery and/or close your account.

Contracts with our third-party mailing house partners and agents ensures that they destroy any data immediately the task is completed.

14. Access to your data (Personal Data) and the Right to be Forgotten

The General Data Protection Regulations ensure that you have the right to request access to, and amend any of the information that TCL holds about you including:

• The right to ask us to stop processing your personal information (in some circumstances we may legally be required to retain some information for audit or legal purposes)
• The right to ask for a copy, or to view, the information that we hold about you, and to have any inaccuracies corrected.

You also have the right to object to our continued use of your data, and to ask us to delete, remove, or stop using it if there is no need for us to keep it. This is known as the ‘right to object’, ‘right to erasure’, or ‘right to be forgotten’. There may be legal or other official reasons why we need to keep or use your data, but please tell us if you think that we should not be using it.

Please contact us if you wish to view, amend, delete or restrict how we use the data held about you – see the end of this policy for contact details – or use our Subject Access Request form which provides more information about making a request for information.

15. Links to other websites

Our website, and documents, may include links to websites run by other organisations. TCL is not responsible for the privacy practices of these other organisations and it is recommended that you read their Privacy Policies carefully if you have any concerns.

16. Cookies

Cookies enable us to understand more about how our website is used and to ensure that it reflects your specific needs; it is a small file that contains information that will allow us to recognise that you have used the website previously but will not contain any personal data.

By browsing our website you are accepting our use of cookies. If you do not want cookies to be stored on your PC it is possible to disable this function within your browser settings without affecting your navigation around the website.

Google Analytics cookies are the only cookies used on our website and are set and utilised by Google to track and analyse how people use our website. These cookies contain no personal information, however they will use your computer’s IP address to understand where in the world you are accessing the internet. The data they hold is sent directly to Google, who may transfer this information to third-parties if required to do so by law. More information can be found at Google Privacy https://privacy.google.com/ .

17. Complaints

Should you need to complain please visit our complaints page. If you are not content with how your complaint is handled initially our response to you will be reviewed by the Chair of our Trustee Board. Following that you have the right to complain directly to the Information Commissioner’s Office; the ICO provides helpful advice regarding raising concerns, https://ico.org.uk/for-the-public/raising-concerns/ .

Please note that TCL is not a ‘public authority’ for the purposes of the Freedom of Information Act (2000) and we will not respond to requests made under this Act.

18. Data Breaches

TCL will use its best endeavours, to ensure your data is kept secure at all times, and to ensure any potential or actual data breach (the loss or unauthorised sharing of personal information) is detected, reported and the subject informed without undue delay.

19. Changes to this Statement and Policy and Contact Details

This statement and policy may be updated in the future. If significant changes are made we will make this clear via the TCL website. If you have any questions or comments regarding this statement and policy the contact details are:

Tuckwell Chase Lottery Data Controller:

Marcelle Stubbs, Director

Tuckwell Chase Lottery
Alexandra Barn
1 Waverley Lane
Farnham
GU9 8BB
Surrey

Tel. 01252 728411

Email: office@tclottery.org.uk

Information on the General Data Protection Regulation (2016)

The Information Commissioner’s Office provides full information about the GDPR: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/

The Six Principles of the General Data Protection Regulation (2016)

1. Lawfulness, Fairness and Transparency
2. Purpose limitation
3. Data minimisation
4. Accuracy
5. Storage limitation
6. Integrity and confidentiality

Tuckwell Chase Lottery Cookies Policy

Cookies enable us to understand more about how our website is used, and to ensure that it reflects your specific needs.  Cookies are used in various forms by most websites, do not contain any personal data and are usually harmless.

What is a cookie?
Cookies are small text files are stored on your hard-drive that can be used by websites to make your experience more efficient and in order to provide you with more functionality. Cookies contain no personal information and use your computer’s IP address to understand where in the world you are accessing the internet. For example, a cookie can help a website to remember that you are logged in when processing an eCommerce transaction or may be used to remember your language preferences.

Cookies may be ‘session cookies’ or ‘persistent cookies’. Session cookies are automatically deleted after you have left our website and Persistent cookies remain to help you with your experience next time you return.

 

What are cookies used for?

We use cookies to enhance the online experience of our visitors, to better understand how our website is used and to monitor how our advertisements perform.  We have broken up the types of cookies that most websites use into the following categories:

• Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
• Preference cookies enable a website to remember information that changes the way the website behaves or looks, such as your preferred language or the region that you are in.
• Statistical cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously. Statistical cookies may benefit the ongoing improvements of the website and increased efficiency/relevance of any related marketing campaigns.
• Marketing cookies are used to track visitors across websites. The intention is to display advertisements that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party

How do we use cookies?
To help you understand how we use cookies, this is a list of all cookies set across our website and what each is used for:

Cookie Name	Type	Category	Expires after	Purpose
_ga	persistent	Statistics	2 years	Analytical insights for our website to help grow our business
_gid	persistent	Statistics	1 day	Analytical insights for our website to help grow our business
_gat_gtag_UA_17588726_1	session	Statistics	1 minute	Analytical insights for our website to help grow our business
_gat	session	Statistics	1 minute	Analytical insights for our website to help grow our business
various	various	Statistics	various	As well as those cookies listed google might add further cookies
wfvt_3374393342	Session	Necessary	on exit	To protect the site against malware as part of a firewall
wordfence_verifiedHuman	Persistent	Necessary	24 hours	To protect the site against malware as part of a firewall
woocommerce_cart_hash	Session	Necessary	on exit	Contain information about the cart and helps WooCommerce know when the cart data changes.
woocommerce_items_in_cart	Session	Necessary	on exit	Contain information about the cart and helps WooCommerce know when the cart data changes.
wp_woocommerce_session_	Session	Necessary	on exit	A unique code for each customer so that it knows where to find the cart data in the database for each customer.

Can I block cookies?
Our cookies do not store financial information or information which is capable of directly identifying you (such as your name or address).  If you are concerned about cookies being stored on your computer by our website or other, you have the right to choose whether to accept these cookies by amending or setting the controls on your browser to reflect your cookie preferences.

Your browser will usually allow you to alter and control the type of cookies that you will allow websites to store via the browser ‘Help’ menu. However, please note that if you choose to refuse cookies some sections of this website might not be available to you.

Cookies set by third-parties

If you go onto a page on our website that contains embedded content, for example YouTube, you may be sent cookies from these websites.

Our website also contains embedded ‘share’ buttons to enable users of the site to easily share articles with their friends through a number of popular networks, for example, Facebook and Twitter.  These sites may set a cookie when you are also logged in to their service.

We do not control the setting of these cookies and, if you are concerned, we suggest you check the third-party website for more information about their cookies and how to manage them.

Review

The details of cookies may change from time to time; to ensure currency we will review and update this policy as required, and at least annually.

This Cookie Policy is correct and accurate as of the March 2024.