Legal
Privacy Policy
How we collect, use and protect your personal information.
Last updated: [Date]
1. Who we are
This policy is provided by Harrow Giving, the giving arm of Harrow Together (registered charity no. 1167770). We are the data controller for the personal information you provide when you play the lottery, donate or contact us.
2. What data we collect
We may collect your name, date of birth, contact details, address, payment information and records of your entries, donations and communications with us. We collect this directly from you and from our payment and lottery service providers.
3. How we use your data
We use your data to administer the lottery and pay prizes, process donations and claim Gift Aid where eligible, manage your account and subscriptions, respond to enquiries, and — where you have agreed — to send you marketing about our work. You can change your marketing preferences at any time.
4. Legal basis for processing
We rely on contract (to administer your entries), legal obligation (for regulatory and financial record-keeping), consent (for marketing) and legitimate interests (to operate and improve our services) as our legal bases for processing.
5. How long we keep data
We keep your data only for as long as necessary to fulfil the purposes described in this policy and to meet our legal and regulatory obligations, after which it is securely deleted or anonymised.
6. Your rights
You have the right to access, rectify, erase, restrict and object to the processing of your personal data, and to data portability. You also have the right to complain to the Information Commissioner's Office (ICO) if you are unhappy with how we handle your data.
8. Third-party processors
We share data with trusted third parties who help us operate the lottery, including our payment provider and External Lottery Manager. These providers act on our instructions and are bound by appropriate data protection obligations.
9. Contact us about your data
To exercise any of your rights or ask a question about this policy, please contact our Data Protection Officer at dataprotection@harrowca.org.uk.