Privacy Policy

How we collect, use, and protect your personal information.

Last updated: January 2024

1. Introduction

Headway Plymouth ("we", "us", "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our lottery service, website, or interact with us in any way.

Headway Plymouth is the data controller for your personal information. We are registered with the Information Commissioner's Office and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

We may collect the following types of personal information:

  • Identity Data: Name, date of birth, title
  • Contact Data: Address, email address, telephone number
  • Financial Data: Bank account details, payment card details (processed securely by our payment provider)
  • Transaction Data: Lottery entries, payments, prizes won
  • Technical Data: IP address, browser type, device information when using our website
  • Marketing Data: Your preferences for receiving communications from us

3. How We Use Your Information

We use your personal information for the following purposes:

  • To process your lottery entries and payments
  • To notify you if you win a prize
  • To verify your age and identity
  • To comply with legal and regulatory requirements
  • To send you information about our charity's work (where you have consented)
  • To improve our services and website
  • To prevent fraud and protect our legitimate interests

4. Legal Basis for Processing

We process your personal data on the following legal bases:

  • Contract: To perform our contract with you (lottery entries and prizes)
  • Legal Obligation: To comply with gambling regulations and tax laws
  • Legitimate Interests: To operate our charity lottery effectively and prevent fraud
  • Consent: For marketing communications (which you can withdraw at any time)

5. Data Sharing

We may share your personal data with:

  • Payment processors to handle your transactions securely
  • IT service providers who help us operate our systems
  • The Gambling Commission as required by our licence
  • HMRC for tax purposes
  • Legal advisors if necessary to protect our rights

We do not sell your personal data to third parties. All service providers are bound by data processing agreements that protect your information.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. For lottery players, we typically retain data for 7 years after your last interaction with us, in line with gambling regulations and tax requirements.

7. Your Rights

Under data protection law, you have the following rights:

  • Access: Request a copy of your personal data
  • Rectification: Ask us to correct inaccurate data
  • Erasure: Ask us to delete your data (where legally permissible)
  • Restriction: Ask us to limit how we use your data
  • Portability: Request your data in a machine-readable format
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw marketing consent at any time

To exercise any of these rights, please contact us using the details below.

8. Security

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encryption, access controls, and regular security assessments.

9. Cookies

Our website uses cookies to improve your experience. Cookies are small text files stored on your device that help us understand how you use our site. You can control cookies through your browser settings, but this may affect the functionality of our website.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Headway Plymouth
Jan Cutting Healthy Living Centre
Scott Business Park, Beacon Park Road
Plymouth PL2 2PQ
Email: info@headwayplymouth.org.uk
Phone: 01752 552263

12. Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Phone: 0303 123 1113