This Privacy Policy forms part of, and is incorporated into, the Lotto Spot! App Terms and Conditions (the “Agreement”), and the capitalized terms in this Privacy Policy are as defined herein or in the Agreement.

Mobile users can use the App without telling us who they are or revealing any personal information about themselves. WCLC does not collect information through the App that personally identifies individuals except when individuals provide such specific information voluntarily by e-mail, by participating in a survey or contest, though the Registration process to open and maintain an Account, to sign in and use the App, including making purchases through the Account, and through the applicable Prize claim processes.

When you use the ticket checker tool, WCLC collects your internet protocol (IP) address, the ticket numbers submitted, the date and time of requests, HTTP data, and other technical and traffic information regarding your use of the ticket checker tool to help prevent inappropriate use of the ticket checker tool and for fraud prevention and security monitoring purposes. WCLC will not seek to match such information to identifiable individuals unless we are required by law to do so, or we are investigating detected or suspected security breaches or other illegal behavior or unauthorized use, and we need to do so in order to carry out the investigation.

The user's location will be used when they access the Find a Store section of the App. However, before the App can use this function, you must allow the App to use Location Services on your Device to access this information. The location used by Find a Store will not be retained by the App.

With respect to e-mail, WCLC may collect, retain and use such information in the same manner as it does other correspondence sent to WCLC. With respect to personal information provided by participating in a survey or contest, the purpose for the collection of the personal information and how such information will be used will be identified at the time the information is provided.

As part of setting up and/or maintaining an Account on the App, WCLC will ask for personal information like your name, date of birth and email address. When you sign in and use the App, transactional and use information is collected, including your requested purchases and Account activities. The App also collects your specific location information, such as your IP address and location coordinates when you sign in, as part of the Account registration process, and when you attempt to make a purchase.

We will use your personal information for the following purposes:

• To administer and operate the App, including to register Players;
• To verify that you meet the registration requirements for the App;
• To identify you and to authenticate and distinguish you and your Account from that of other users/Players;
• To communicate with you about your Account;
• To provide, maintain, protect and improve our services;
• To send electronic communications to you in accordance with your communication preferences;
• To resolve disputes and enforce our agreements, including the Agreement, and to comply with applicable legal requirements and protect our legal rights;
• To confirm physical location to ensure you are physically located within the required WCLC authorized jurisdiction when required;
• To provide you with customer service and, generally, respond to inquiries;
• To customize the content and delivery of our products, services and marketing;
• For internal data analysis purposes;
• To maintain the security of the App, including conducting security investigations;
• To investigate Prohibited Activities, including suspected Prohibited Activities, and to report such activities to third parties WCLC determines to be appropriate in the circumstances, including law enforcement agencies;
• To improve the operations of the App and to improve how we communicate with you;
• To process, validate, investigate and publish prize claims (including publication of your name, address, recent photograph, amount won and place of residence) if you become a winner, in accordance with the Agreement and the applicable Rules;
• To process payments related to your transactions on the App (taking into account our desire to prevent fraudulent, unauthorized or ineligible financial transactions), and to investigate financial transactions as permitted by law or as set out in the Agreement (e.g., fraud, credit card or other chargebacks);
• To assist WCLC and its service providers for the above noted purposes as deemed necessary or advisable by WCLC.
  

WCLC sometimes retains third parties to assist us in order to provide the App services. WCLC may disclose your personal information to such service providers acting on behalf of WCLC in relation to the general purposes outlined above and in order to perform processing and other specialized services, including data processing and storing, verification of location, and payment processing. If you sign up for an Account on the App, WCLC may also disclose your personal information to service providers such as financial/banking institutions or credit card providers. These third-party service providers are located inside and outside of Canada, and/or store and access information both inside and outside of Canada, and are given only the information necessary to perform the specific services they are providing to WCLC. WCLC does not sell any personal information that it collects to any third party and does not share or transfer personal information that it collects to unaffiliated third parties for their own marketing efforts.

WCLC also uses the following reporting and marketing analytics services for this App, which are more fully described below:

By using this App, you also expressly consent to the collection, processing and use of data about you by the above reporting and marketing analytic services providers and WCLC in the manner and for the purposes set out above. WCLC will not seek to match IP addresses or device id to identifiable individuals, unless we are required by law to do so, or we are investigating detected or suspected security breaches or other illegal behavior, and we need to do so in order to carry out the investigation. In addition, your Device ID is recorded and stored when you request to receive notifications, or opt-in through Apple’s privacy framework (ATT). Your Device ID and operating system information will also be collected when you request certain App troubleshooting services. This information in no way identifies you personally.

WCLC has security measures in place to attempt to protect against the loss, misuse, and alteration of your user data and personal information under our control. WCLC keeps such information in secure facilities, protected from unauthorized access. Only persons who have a need to know your personal information for the purposes described in this Privacy Policy have access to the user data you choose to provide to us. WCLC has imposed strict rules on WCLC employees who have access to the databases that store user personal information or to the servers that host our services. While we cannot guarantee that loss, misuse or alteration to data will not occur, we make reasonable efforts to prevent such occurrences.

WCLC will retain your personal information for as long as your Account is active and as needed to provide services to you. If you decide to cancel your Account, or if we need to cancel your Account (e.g. if you are not complying with the terms of the Agreement), we will retain and limit use of your information as necessary to comply with the applicable retention periods, our legal obligations, to resolve disputes, and to enforce agreements.

Upon your written request, subject to specific exceptions, WCLC will provide you with access to your personal information. We reserve the right to charge a reasonable fee for providing it. To access or amend your personal information, you can contact our privacy officer as described below.

With respect to communicating with us over the Internet, although WCLC takes steps to prevent unauthorized access to the information maintained by WCLC, please note that Internet communications are inherently not absolutely secure, and accordingly we cannot guarantee that the information you send to us will not be intercepted, collected, and misused by others without your consent.

The App may contain links to websites maintained by third parties. The linked sites are not under the control of WCLC, and WCLC is not responsible for the contents of, or the privacy practices of, any linked site or any link contained in a linked site. WCLC provides these links only as a convenience, and the inclusion of a link does not imply endorsement of the linked site by WCLC.

WCLC may update this Privacy Policy from time to time to reflect changes to its information practices. You are encouraged to periodically review this Privacy Policy for the latest information.

This Privacy Policy is an implementation of, and is subject to, WCLC's general privacy policy. A copy of WCLC's general privacy policy can be obtained by contacting WCLC at privacyofficer@wclc.com.

Updated: 22 March 2023