1. Introduction

SLL (“we,” “us,” “our”) provides an online platform that enables clubs, charities, and community organisations to manage their fundraising, membership, and supporter engagement activities — including online draws, raffles, ticket sales, and payments.

We are not a gambling operator. All fundraising activities and draws hosted through the SLL platform are managed and operated by the individual clubs or organisations. Each club is responsible for the conduct, management, and promotion of its own fundraising events.

SLL is committed to protecting your privacy and handling your personal information securely and transparently, in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (Ireland).

2. Data Roles and Responsibility

• When you interact with a club or organisation through our platform (e.g., to join a fundraiser, buy a ticket, or register as a supporter), that club or organisation is the Data Controller for your personal information.
• SLL acts as the Data Processor, providing the technology and systems necessary for the club to manage its fundraising and communications.
• When you visit our website (sll.ie) or contact us directly, SLL acts as the Data Controller for information collected through those channels.

If you have any questions about how your club uses your data, please contact the club directly.

3. Personal Data We Collect

We collect only the information necessary to provide our services and maintain compliance with relevant laws.

3.1 Information you provide:

• Name, email address, phone number, and postal address
• Confirmation of being over 18 years of old
• Payment details (processed securely by our payment providers — we do not store card information)
• Account login credentials (encrypted)
• Communication preferences and consent choices

3.2 Information automatically collected:

• IP address and device information (browser type, operating system, and access time)
• Cookies and analytics data (see Section 10)
• Log data for system security and fraud prevention

4. How We Use Your Information

We use your personal data to:

• Provide access to the platform and its fundraising features.
• Facilitate secure payments and ticket confirmations.
• Maintain records of your transactions and participation in club events.
• Communicate important updates or respond to your support queries.
• Improve our website and platform performance.
• Comply with legal and regulatory obligations.

We do not use personal data for gambling, betting, or behavioral advertising purposes.

5. Legal Basis for Processing

We rely on the following lawful bases under GDPR:

• Contractual necessity – to process payments, issue tickets, and manage your fundraising activity.
• Legitimate interest – to ensure platform security, prevent fraud, and improve user experience.
• Consent – for optional marketing communications and non-essential cookies.

6. Data Sharing and Disclosure

We may share your information with trusted third parties only where necessary to operate our platform:

• The club or organisation running the fundraiser you participate in.
• Payment processors (e.g., Stripe, Opayo) to process secure transactions.
• IT hosting providers for secure storage of data within the EEA.
• Email/SMS service providers for communications you have opted into.

We do not sell, rent, or trade personal data with any third parties for marketing or commercial purposes.

All third-party partners are bound by data processing agreements ensuring they act only under our instructions and maintain GDPR compliance.

7. Data Retention

We retain personal data only for as long as necessary to:

• Fulfil the purpose for which it was collected;
• Comply with legal, accounting, or reporting obligations;
• Resolve potential disputes.

When data is no longer required, it is securely deleted or anonymised.

8. Security of Your Information

We take appropriate technical and organisational measures to protect personal data, including:

• Encrypted data transmission (SSL/TLS)
• Strict access controls and authentication
• Regular system testing and backups

While we take every precaution, no online system is 100% secure. Users are encouraged to use strong passwords and avoid sharing login credentials.

9. International Data Transfers

All data is primarily stored within the European Economic Area (EEA).

If it is necessary to transfer data outside the EEA (e.g., by a third-party service provider), we ensure that adequate safeguards such as EU Standard Contractual Clauses are in place.

10. Cookies and Analytics

We use cookies to ensure our platform functions properly and to understand how it is used.

Types of cookies:

Essential cookies – required for login and security (cannot be disabled).

Analytics cookies – to monitor website performance (Google Analytics, anonymised).

Preference cookies – to remember your language or display settings.

You can manage or disable cookies through your browser settings.

11. Your Rights

You have the following rights under data protection law:

• Access – request a copy of the personal data we hold about you.
• Rectification – correct inaccurate or incomplete information.
• Erasure – request deletion of data when no longer required.
• Restriction – limit processing in certain circumstances.
• Portability – receive your data in a structured, machine-readable format.
• Objection – object to processing carried out on legitimate interest grounds.
• Withdraw consent – at any time, for data processed based on consent.

To exercise these rights, contact us at customercare@smartlotto.ie

If your data was provided to a club/ organisation, you may also contact the club/ organisation directly.

12. Children’s Data

SLL’s services are intended for individuals aged 18 and above, unless a club specifically allows younger members to register under parental consent.

Where parental consent is required, the club is responsible for verifying and maintaining such consent.

13. Updates to This Policy

We may update this Privacy Policy periodically to reflect operational or legal changes.

When changes are made, we will revise the “Last Updated” date above and, where appropriate, notify users via email or in-app notice.

14. Contact

For privacy-related questions, data access requests, or complaints, please contact:

Address: GTEIC Údarás Industrial Estate, Ballina Rd, Belmullet, Co. Mayo, F26 P997, Ireland

We will endeavour to respond as soon as reasonably possible.