Bee-Ethical Ltd is an External Lottery Manager (ELM), licensed by the Gambling Commission, authorised to operate the lottery on behalf of charitable organisations.
To enable the delivery of this service, Bee-Ethical acts as an independent “Controller” for the personal information we process, which is necessary for us to deliver the lottery service and products.
Under UK GDPR (UK General Data Protection Regulation) the lawful basis for us to process your personal data is under “contract”.
Bee-Ethical is fully committed to compliance with the UK GDPR and has a legal duty to protect any information we collect from you. The UK GDPR provides the legal framework that defines how personal information can be stored and used.
As a lottery participant (“player”) this privacy notice explains:
Personal data is any information we handle that relates to an identified or identifiable natural person. An ‘identifiable natural person’ is anyone who can be identified, directly or indirectly, from information including by reference to a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
As a lottery participant (“player”) we will use the following categories of your personal data:
We do not collect Special Categories of Personal Data, nor information about criminal convictions and offences relating to the public.
We will collect personal data in the following ways:
The table below is relevant to all data subjects who are players of the lottery:
| Purpose for using personal data | Lawful basis for using |
|---|---|
| For you to join/sign up for the lottery to become a lottery “player”. | UK GDPR Article 6.1(b) — performance of a contract which you have agreed to, or where we are working to enter into a contract with you. |
| To notify you if you have won and interact with you to supply your winnings. | |
| To process monies so you are able to participate in the lottery. | |
| To send notification emails: cancellations, lottery entry communications, Direct Debit management, lottery number reminders, winner notification, inability to claim monies. | |
| To create statistics submitted to the Gambling Commission as part of our quarterly return. | |
| To conduct age verification checks in accordance with Gambling Commission requirements. | UK GDPR Article 6.1(f) — legitimate interest of the Data Controller. [Note: age restriction is a condition of our Gambling Commission licence — LCCP 3.2.13.] |
| To send you marketing material for the lottery according to your preferences. | UK GDPR Article 6.1(a) — consent you have provided. You may withdraw consent at any time. |
| To conduct Anti-Money Laundering checks on players in accordance with UK Gambling Laws. | UK GDPR Article 6.1(c) — compliance with a legal obligation (Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017; Proceeds of Crime Act 2002). |
| Where you are a large prize winner, to make contact to ask if you would like to provide a testimonial or be part of promotional materials. | UK GDPR Article 6.1(f) — legitimate interest of the Data Controller. |
| If you provide consent, to use your personal data in public-facing promotional materials. Note: printed materials may not be immediately retractable; we will remove your information when reprinting. | UK GDPR Article 6.1(a) — consent you have provided. You may withdraw consent at any time. |
| To conduct statistical monitoring of the lottery to monitor for issues and improvements. | UK GDPR Article 6.1(f) — legitimate interest of the Data Controller. |
| To create pseudonymised identifiers to help reduce identifiability and allow us to monitor activity within our systems. | |
| To handle enquiries by you about the lottery or charitable organisation by phone or email. |
Any data shared with recipients is the minimum necessary for the task they have been instructed to carry out on our behalf or in conjunction with us. Each category of recipient is subject to review by the Compliance Team to ensure they have appropriate security measures in place.
Where sharing occurs within the context of a product or service supplied under contract, a Data Processing Agreement (in accordance with GDPR Article 28) is put in place to prevent suppliers from using your personal data outside of permitted purposes.
Within the purposes listed above, we will share your personal data with the following where appropriate:
There may be scenarios where we are subject to a legal obligation to disclose your personal data — such as to law enforcement agencies, regulatory bodies, or public authorities — to prevent or detect crime or to demonstrate compliance. We will only ever disclose personal data to these parties to the extent required by law.
Data sharing with third-party organisations that are not suppliers to Bee-Ethical does not occur unless there is a legal obligation or sound lawful purpose for such sharing.
If Bee-Ethical were to transfer your data outside of the UK, we would ensure that the destination country has been approved by the UK Government in accordance with adequacy decisions. See: The UK approach to international data transfers — GOV.UK.
You may withdraw consent to marketing at any time by contacting us using the details below.
Bee-Ethical keeps your personal data for as long as necessary for the particular purpose(s) for which we hold it. Data shall be reduced, redacted, de-identified and deleted at appropriate times so that we retain the minimum amount of data possible throughout the running of the lottery.
We keep your personal data for at least six (6) years in accordance with associated legislation once you are no longer a player with us, unless there is another legal reason to retain it longer. All data is securely stored for this period and then safely deleted.
Should a player wish to withdraw and no longer participate, their personal financial data will be retained in accordance with Bee Ethical policy. All other related player personal data will be removed and destroyed from the internal lottery management system.
Full details can be found in our Records Management, Retention and Disposals Policy.
If you begin sign-up but do not complete it, or if you attempt to access our platform and are unsuccessful, we may retain limited information to help resolve technical issues and improve your experience. We may contact you to offer assistance.
Yes. We implement appropriate technical and organisational measures to protect your personal data from unauthorised disclosure, use, or alteration in accordance with data protection requirements, UK Gambling Commission licencing obligations (ISO/IEC 27001:2022) and FCA regulated e-money services where appropriate.
The lottery platform is security tested on a regular basis throughout the year and maintains security encryption and access standards to ensure compliance with the Gambling Commission’s Licence Conditions and Codes of Practice (LCCP).
We will always keep these measures under review to ensure they remain appropriate. No personal data is subject to any automated decision-making.
Under data protection law, you have the following rights:
Learn more about your rights: Individual rights — guidance and resources (ICO).
The Information Commissioner’s Office (ICO) regulates the processing of personal data. You can complain to the ICO if you are unhappy with how Bee-Ethical have processed your personal data.
Our website may contain links to other websites outside our control and not covered by this Privacy Policy. If you access other sites, their privacy policies may differ.
When you first visit our site, you are given the choice of continuing to use the site with cookies or to discontinue using our site. By continuing to use our site you are consenting to the use of cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognise your browser and capture and remember certain information.
We use technologies such as cookies to customise content and advertising, to provide social media features and to analyse traffic to the site. For further information on cookies, including how to control and manage them, visit: Cookies — ICO.
Help make the website usable by enabling basic functions. The website cannot function properly without these cookies.
| Name | Provider | Purpose | Max Duration | Type |
|---|---|---|---|---|
| atlassian.xsrf.token | Atlassian | Ensures visitor browsing security by preventing cross-site request forgery. Essential for website and visitor security. | Session | HTTP Cookie |
| ARRAffinity | Azure | Used to distribute traffic to the website on several servers in order to optimise response times. | Session | HTTP Cookie |
| ARRAffinitySameSite | Azure | Used to distribute traffic to the website on several servers in order to optimise response times. | Session | HTTP Cookie |
| CookieConsent | Cookiebot | Stores the user’s cookie consent state for the current domain. | 1 year | HTTP Cookie |
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Help website owners understand how visitors interact with websites by collecting and reporting information anonymously.
| Name | Provider | Purpose | Max Duration | Type |
|---|---|---|---|---|
| _pk_id# | bematomo.neptunedata.co.uk | Collects statistics on user visits to the website, such as number of visits, average time spent, and pages read. | 1 year | HTTP Cookie |
| _pk_ses# | bematomo.neptunedata.co.uk | Used by Piwik Analytics Platform to track page requests from the visitor during the session. | 1 day | HTTP Cookie |
Used to track visitors across websites to display relevant and engaging advertisements.
| Name | Provider | Purpose | Max Duration | Type |
|---|---|---|---|---|
| _ga [x2] | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. | 2 years | HTTP Cookie | |
| _ga_# [x2] | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. | 2 years | HTTP Cookie |
If you would like to make any changes to your details, or have any questions or concerns about the information in this privacy notice, please contact us:
The materials on this website are provided for general information purposes only. Every effort has been made to ensure accuracy at the time of inclusion, but Bee-Ethical does not guarantee such accuracy and is not liable for any action taken as a result of relying on information or advice on the website. Bee-Ethical reserves the right to make changes and corrections to this website without notice.
This website contains material protected by copyright and other intellectual property rights. All copyright and intellectual property rights, including names, images, and logos, are owned by Bee-Ethical unless otherwise stated. All rights are reserved.
Bee-Ethical Ltd reserves the right to modify this Privacy Policy at any time. Material changes to this policy will be notified here, by email, or through other means deemed appropriate.