Policy
-personal data protection
1 - OUR COMMITMENTS
Your privacy is a priority for LOTERIE NATIONALE (having its registered office at 18 rue Léon Laval L-3372 Leudelange). We are committed to building a relationship of trust with our customers and we undertake to protect the privacy and integrity of the personal data of users of our website Loteriesport.lu and offers in accordance with the General Data Protection Regulation (as defined below).
As such, we undertake to respect the following principles:
- We collect and process only the personal data that we need.
- We process your personal data for explicit, lawful, legitimate, and specified purposes.
- We keep your personal data only for as long as it is necessary for the purposes for which it was collected or, as the case may be, for as long as required by law.
- We do not share your personal data with third parties, except with the service providers that need to know the information and are involved in providing you with the best possible quality of our Offers and services.
- We take care to implement appropriate security measures to ensure a suitable level of protection for your personal data.
The Policy applies to all of our Offers (as defined below)
By using our Offers, you agree to the processing of your personal data by the LOTERIE NATIONALE (or, where applicable, its subcontractors) in accordance with the provisions of the Policy.
The Policy may be modified at any time, so please consult this page regularly.
2 - A few useful definitions to get you STARTED
The terms listed below have the meaning ascribed to them hereunder when used in the Policy.
"data controller" refers to the legal entity (company, municipality, etc.) or natural person who determines the purposes and means of a processing operation, i.e., the objective and the way in which it is carried out. For the purposes of the Policy, the LOTERIE NATIONALE acts as data controller.
"General Data Protection Regulation" or "GDPR" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
“GTCs” means the Loteriesport.lu General Terms and Conditions.
"Offers" refers to the Website including the related lottery, games, and sport betting offers.
"personal data" refers to any information or data that identify you or make you identifiable as a natural person (e.g., first and last name, telephone number, identifier, postal or e-mail address, etc.).
“player account” refers to your online player account opened on the Website.
"processing" or "data processing" means any operation, or set of operations, relating to personal data, whatever the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission or dissemination or any other form of making available, reconciliation).
"subcontractor" refers to a natural or legal person (company or public body) who processes data on behalf of the LOTERIE NATIONALE (acting as data controller), as part of a service or provision.
“Website” refers to Loteriesport.lu.
3 - WHAT PERSONAL DATA DO WE COLLECT?
When using or accessing our Offers, we collect and process, as the case may be:
- Personal data that you provide us for the creation, administration, and management for your player account. This data may include, for example, your first name, surname, date of birth, e-mail address, postal address, bank details, correspondence with the customer/ support service, credit card information, replies to security questions, complaints, etc.
- Personal data that you transmit to us when filing in a contact form (e.g., name, first name, contact details…),
- Personal data collected when accessing or using our Offers and/ or connecting to the Website: gaming/ betting limits, game and betting history, date and hours of connection, IP address, device information, source and destination data,
- Personal data that we obtain indirectly, notably via cookies or tracers (and subject to your choices) when you browse the Website or are exposed to one of our advertisements broadcasts on third-party sites. This data may include, for example, your connection and browsing data, IP address, preferences, and interests.
4 - WHAT IS THE BASIS FOR PROCESSING PERSONAL DATA?
Your personal data is processed on the following grounds:
- Contractual obligations and compliance with regulatory requirements
- Your consent
- Legitimate interest
5 - HOW DO WE PROCESS AND USE YOUR PERSONAL DATA?
- Managing your player account and commercial relationship
The LOTERIE NATIONALE is legally obliged to check that the data provided by its players is accurate, complete and up-to-date. We may therefore contact you at any time to check that your information is correct and/or to provide additional documentation or evidence.
In order to provide you with the best possible service, we also process your personal data to manage your requests and complaints to our Customer Service department. In this context, we may also record your telephone calls and correspondence. We may also carry out analyses of requests made by our customers via our various contact channels (e.g., telephone, e-mail, social networks, etc.) in order to improve our operational processing of these requests and to give us a more global view of the reasons for customer satisfaction, dissatisfaction, contacts and complaints.
- Preventing excessive gaming and ensuring responsible gaming
- Managing payments
Your bank account details (IBAN) are used for the sole purpose of paying your winnings and the sums shown in the balance of your player account.
Your payment card details are securely stored to record financial transactions (as required by the applicable laws) and to facilitate later payments. Facilitation of payments allow you to not have to re-enter your credit card number each time you make a payment into your player account. Each payment card transaction is processed by our PCI-DSS-certified online payment service provider (international security standard ensuring the confidentiality, security and integrity of credit card and transaction data). You will be able, at any time, to request to our customer service that your credit card information stops appearing on your Account for future purchases.
- Information, commercial offers, and newsletters
- Social networks
However, we have no control over how social networks use your personal data on their own behalf. In this respect, we invite you to consult the personal data protection policies of the relevant social networks.
- Personalization of services and online advertising
Based on your personal data such as age range or interests, we may create trends to:
- Display ads on the Website or on third-party sites that best match your interests, and/or
- Be able to send advertising, via partners, to people with a profile like yours (for example: to identify people who might be interested in the same categories of games or bets).
- Studies and statistics
- Combating fraud, money laundering and the financing of terrorism
In addition, in order to ensure you an optimal experience and to prevent fraud, we have implemented and maintain controls and checks requiring the process of your personal data. These controls enable us to detect, amongst others, potential cheating, breach to our gaming/ betting rules, or fraudulent alliances to manipulate or trying to manipulate the results of games or bets.
6 - WHO WILL RECEIVE YOUR DATA?
Your personal data is collected and processed by LOTERIE NATIONALE, acting as data controller.
However, for specific services, purposes, or processes, LOTERIE NATIONALE may share your personal data with subcontractors. The personal data are provided to these subcontractors on a need-to-know basis and to the extent that is reasonably necessary for the proper management and maintenance of the Website, the management of your player account, the proper performance of our services and Offers and/ or compliance with applicable regulation. Subject to your prior authorization, it may also be shared with partner companies. LOTERIE NATIONALE has appointed its subcontractors within the framework of a specific contract.
We carefully and diligently select subcontractors established in European Union member states and/or in countries recognized by the European Commission as applying an equivalent level of personal data protection. We require our subcontractors to apply stringent personal data protection rules in compliance with the GDPR and all applicable laws and regulations.
Our subcontractors are currently:
| Name of subcontractor | Purpose | Country of registration / head office |
| Mentor | Service for responsible gaming | Austria |
| Xtremepush | Service for customer engagement, via push notifications, inbox message | Ireland |
| Sendgrid | Service for transactional and marketing emails | USA (under EU-US Data Privacy Framework “(DPF) |
| Acuris/C6 | Service for anti-fraud and anti-AML | Ireland |
| Mobius Solutions Ltd. | Service for customer retention optimization | Israel (under Adequacy Decision) |
| Google Analytics | Service for website analytics | USA (under EU-US Data Privacy Framework “(DPF) |
| Datatrans PCI Proxy | Service to achieve PCI-DSS compliance | Switzerland |
| ASW Sportsbook | Sportsbetting provider | Austria |
| Adyen | Payment provider | Netherlands |
| Paypal | Payment provider | Luxembourg |
We reserve the right to disclose the Personal Data to any court, judicial or administrative authority, when required or legally compelled to do so.
7 - HOW LONG DO WE KEEP YOUR PERSONAL DATA?
| Purpose(s) | Duration of storage |
| Personal data required to manage your player account and promotional operations | 10 years from the closure of your player account |
| Financial operations and transactions information | 10 years from the end of the current financial year |
| Personal data required to combat money laundering and the financing of terrorism | 5 years from the closure of your player account, the request for payment of a win or your first contact with us. |
| Data required for commercial prospecting | 1 year from last contact |
| Cookies and trackers | Maximum 13 months |
| Financial data (e.g., in the event of a payout) | 10 years from the end of the current financial year. |
8 - ARE YOUR PERSONAL DATA PROCESSED IN A SECURE MANNER?
LOTERIE NATIONALE has implemented and maintain reasonable and appropriate technical, physical, and organizational controls to ensure the security, integrity, and confidentiality of your personal data, in particular to protect it against loss, destruction, alteration, misuse and access by unauthorized access.
In addition, your payment information is managed by our PCI DSS-certified online payment service provider (international security standard ensuring the confidentiality, security and integrity of credit card and transaction data).
9 - COOKIES AND OTHER TRACKERS
- What is a cookie?
These cookies may come from different sources:
- LOTERIE NATIONALE cookies: these are cookies that may be placed on your terminal by the LOTERIE NATIONALE when you browse the Website. These cookies enable us to personalize and continually improve your experience on the Website.
- Third-party cookies: these are cookies that may be placed on your terminal by third-party companies (e.g., advertising agencies, social networks, LOTERIE NATIONALE’s partners, etc.) as you browse the Website. During the period of validity of their cookies, these third-party companies are able to identify your centers of interest, collect browsing information relating to your visit to the Website, and personalize advertising likely to correspond to your centers of interest and user profile, to which you may be exposed on the Website.
- What types of cookies does LOTERIE NATIONALE use?
| Cookie types | Role | Is it necessary to obtain your prior consent? |
| How our services work | These cookies are strictly necessary for the operation of the Website. They enable you to browse the Website and use its functionalities. | No - these cookies are considered essential and do not require your consent. If you have chosen to deactivate these cookies via your web browser, access and/or use of the Website may be altered. We advise you to leave them activated so that you can take full advantage of our services, our Offers, and your browsing experience on our Website. |
| Audience measurement and content improvement | These cookies are used to measure the Website's audience and the performance of our campaigns in order to improve content and services for all users. Thanks to these cookies, we can compile visitor statistics (e.g., number of visits, pages viewed, sections consulted, etc.), evaluate advertising performance (number of clicks, conversions after viewing an ad, etc.) and understand the activity of visitors to the Website. This allows us to continually improve the Website and marketing campaigns to make your experience more enjoyable. | Yes - these cookies are considered non-essential and therefore require your prior consent. |
If you delete the cookies considered essential that are stored on your terminal, you will no longer be able to benefit from a certain number of functions required for optimal browsing of the Website (for example, cookies enabling us to recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings, or the country from which your terminal appears to be connected to the Internet). In such circumstances, we accept no responsibility for any consequences arising from the impaired operation of our services and/or Offers as a result of our inability to store or retrieve the cookies required for the proper operation of the Website.
- How to exercise your choices from your web browser?
To express or reconsider your choices regarding cookies, we invite you to configure your browser. Please note that blocking cookies through your browser settings may impact the functionality of the Website and your ability to access certain features or Offers. You may experience limited functionality, difficulty in navigating the Website, or an inability to complete certain actions, such as logging in or making purchases. We recommend that you allow essential cookies to ensure a seamless and secure browsing experience on the Website.
If you share the use of your terminal with other people or if you use several browsers from the same terminal, we cannot be certain that the services and advertisements intended for your terminal correspond to your own use of this terminal and not to that of another user.
- How can you exercise your choices with third-party cookie issuers?
10 - WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?
In accordance with the provisions of the GDPR, you have the right to:
- Limit the processing of any and all of your personal data,
- Object to the processing of any and all personal data,
- Access any and all personal data,
- Request the portability of any and all personal data, and/ or
- Request the rectification and/or deletion of any and all personal data.
Please also note that in application of certain laws or regulations, the LOTERIE NATIONALE may be obliged to retain a copy of its personal data despite your request for deletion or portability.
If you would like to know more about the provisions of this Policy or contact our Data Protection Officer, you can also write to us at the following address: Loterie Nationale Service Relation Client 18 rue Léon Laval, L-3372 Leudelange, Luxembourg or by e-mail to: dpo@loterie.lu
You can also exercise your rights in writing by completing our retraction form.
To exercise your rights, you must prove your identity by clearly stating your surname, first names and any useful information enabling us to identify you. You must also give us the e-mail address or physical address to which you would like the reply to be sent.
In addition to the rights set out above, if you consider that the processing of your personal data violates the principles set out in the GDPR, you retain the right to lodge a complaint with the National Commission for Data Protection (www.cnpd.lu).
11 – LANGUAGES AND COMPETENT JURISDICTION
The present document is a translation of a policy initially written in French. In any case of discrepancy between the English and the French versions, the French version shall always prevail.
Any claim or dispute that may arise out of the application or interpretation of the present Policy shall be submitted to the exclusive jurisdiction of the Luxembourg courts.