The Scotto’s Privacy Policy

The Scotto supports the Jackpot Community Trust (SC052059) (the "Charity").

The Charity has appointed MBC ELM Limited, a company registered in Scotland (Company Number SC513712), with registered office at 272 Bath St, Glasgow, G2 4JR (MBC ELM" or "we") to promote and manage the Lottery. MBC ELM is the data controller responsible for looking after your personal data in line with data protection and privacy laws.

We are committed to ensuring your privacy and protecting the data we hold about you. This Privacy Policy explains how we do this and describes how, when and why we collect and process your personal data. In addition, we let you know how to exercise the rights you have in relation to your personal data.

By using the Lottery's services, (the "Services"), you are presumed to have read and understood this Privacy Policy.

Please note that we update our Privacy Policy from time to time, so we recommend that you take a fresh read through. If we make significant changes to our Privacy Policy we will notify you either when you access the Services or by some other means such as email.

This privacy policy was last updated 27th April 2023.

Contents

1. What data is collected about you and when?
2. Why we collect data and how we use it
3. Security
4. Sharing of Your Data
5. Marketing & other communications
6. Cookies and other tracking technologies
7. Telephone calls
8. Links to Other Sites
9. Your Rights
10. Contact Details

What data is collected about you and when?

When you use our Services, some personal data will be collected as follows:

Registration: When you register and open an account with the Lottery, 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 on our Services (both in a single transaction and over a period of time), and your preferences relating to our Services.

Technical: Includes information about your device or browser when you use our website, date/time of visits and page view data.

Marketing: Includes your instructions as to whether or not you wish to receive digital marketing from MBC ELM Ltd.

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 - we will action your request as soon as reasonably practicable.

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 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 (please see below for more info).
• Where we have your consent.
• In order to comply with a legal or regulatory obligation.

Security

The security of your account 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 website or mobile app are 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. Our server then reads the data using a private key. This means that your data is turned into a code that can only be decoded with the private key or password. If your browser is suitably configured, you may receive a warning message when you first access any secure page on the Services. This is simply information to advise you that the website is protecting your data.

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.

Please be aware that the sending of information through the internet is not completely secure. We do not guarantee the security of your data transmitted to and from the Services over the internet, and you accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we have been negligent. For your own privacy protection, we encourage you not to include sensitive information (such as financial information) in any email or text communication you may send to us.

AVOIDING LOTTERY SCAMS

Scammers use emails, phone calls or letters which try to trick you into thinking you've won a lottery prize and may use real or convincing company logos in their emails or letters.

They do this so that they can ask you for money to release the prize or for your personal details, which they can use to try 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.

It is not necessary to select links in emails we send to you to claim your prizes.

Remember that 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've 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 The Scotto to win a prize with us.
• If you are unsure about any communication you receive, please call our Customer Service Team on freephone number 0330 123 3952 or email us on help@thescotto.com and we will be happy to advise.

REPORT A SCAM

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

MORE INFORMATION

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

Sharing of your data

We share your data in the following ways:

• when we carry out identity and due diligence checks as required by law.
• when we engage data processing companies from time to time, to help provide the Services, such as our lottery platform provider Bonobo PLCs, marketing service providers to enable us to send you emails, and other supplier to manage your account, provide customer services, and provide usage analytics to us. These companies must comply strictly with our instructions and we do not permit them to further use or share your data. We also require them to have appropriate technical and operational security measures in place;
• when you register for, and otherwise access our Services we share your data with MBC ELM Limited, one of our group companies, who delivers digital media services ("MBC"). MBC will store and use your personal data on our behalf, and in accordance with our instructions, for lottery advertising activity as well as for its own purposes. MBC will share data to enable profiling of users and to provide more relevant advertising and other customised communications across our respective services;
• In order to process your financial transactions and pay any prize winnings we will 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 Lottery, MBC ELM, our customers, or others (which may include steps taken arising from a breach of our Terms and Conditions);
• 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. In particular, we share information with auditors to ensure we are compliant with our regulatory/licence and/or contractual requirements; and
• the Gambling Commission, the police, and other relevant regulatory bodies, for the purpose of complying without our regulatory requirements and in connection with any active investigations in suspected fraud or other criminal activity.

Marketing & other communications

You will receive service emails from us about your account or to update you on any material changes to our Terms and Conditions, privacy and cookies policies.

Where you have agreed, we will also send you promotional messages about the Lottery. We will keep you up to date by sending you emails, SMS and e-newsletters from time to time. We may also communicate with you by phone and text. All communications from us will be clearly marked as being sent by us and will include information that will enable you to stop the promotional communications at any time, if you wish to do so.

We may also, from time to time, send marketing communications to you via post on the basis of our legitimate interests.

Where you have agreed, MBC ELM Limited will also send you marketing emails. These emails will be clearly marked as being sent by MBC ELM Limited.

You can opt-out of receiving our email communications by following the link contained at the bottom of the relevant emails or by contacting us at contactus@thescotto.com. You can also manage your marketing preferences via your account profile. You should note that if you opt out of marketing communications, we will still contact you with customer servicing information, or operational information about your player account or the Lottery. This means that you will not be removed completely from our mailing / contact lists.

Cookies and other tracking technologies

When you access our Lottery Services 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 MBC with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).

More information on the types of cookies we use, what we use them for and on how to manage your cookies, see our Cookie Policy: www.thescotto.com/cookie-policy.

Please note that some of the system functionality will not work if you disable cookies that are strictly necessary.

Telephone calls

If you phone our customer service team on 0330 123 3952, your call may be recorded. We use these recordings for training and quality assurance purposes. Recordings can also help us to resolve queries quickly.

Links to other sites

To inform and enhance your experience when on our sites, or using our Services, we provide a number of links to third party websites who apply their own privacy policies. Please note that this Privacy Policy will not apply to any such third party website. We do not control such third party websites or have any responsibility for them.

Data Retention

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. At the end of this period, we will either delete or anonymise your data (meaning that it can no longer be used to identify you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

To determine how long we keep your Personal Data for, we consider the amount, nature and sensitivity of the Personal Data, the purposes for which it was collected and the potential risk of harm from us continuing to keep it.

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

Your Rights

You have various rights in relation to the Personal Data we hold about you which include a 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 that we hold about you We may ask you to provide sufficient proof of your identity before we can make the requested changes. If your sensitive data (such as financial information) is not up-to-date then please make the relevant changes to your player account. We recommend that you never send financial information to us by email.
• 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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.
• Data Portability. You have the right to request the transfer of a copy of the Personal Data we hold about you in an electronic format whether the basis of our holding such information is your consent or the performance of a contract and the information processed 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.

If you wish to exercise any of the rights set out above, please contact us in writing or email dp@thescotto.com

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

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.

Contact Details

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

Email: dp@thescotto.com