1. LottoStar (Pty) Ltd and its subsidiaries and/or affiliates (“LottoStar”) (also collectively referred to as “we”, “our”, and “us” want you to be familiar with our Privacy Notice and how we collect, use, process and disclose personal information. This Notice describes our practices in connection with the information that we collect through activities that link to this Notice including websites and mobile sites.
2. LottoStar is a Responsible Party in terms of the POPIA with regard to your Personal Information. We process all such Personal Information in order to enable us to do business with you and to provide products and services to you as requested. In this Notice, “you” means you as an individual who has a betting account with LottoStar and whose Personal Information we may need to collect and process in order to provide the requested services and for any of the purposes described in the Notice.
3. LottoStar’s Notice clearly sets forth our position in relation to the processing of any of your Personal Information regardless of whether it is in terms of this Notice or not. Our Notice also summarises our principal obligations to you in connection with the lawful processing of your Personal Information, as well as the rights which you have in relation thereto. You will also be able to source the contact particulars of our Information Officer and how you can contact them in this Notice.
4. This Notice has been developed to acknowledge the importance and assist in providing a framework for, the appropriate level of protection for consumer identification, collection, holding, using, disseminating, merging, collating, disclosing and protection of your Personal Information (“process” or “processing”). The Notice represents LottoStar’s commitment to compliance with its obligations under the Protection of Personal Information Act, 2013 (“POPIA”). This Notice is prepared in accordance with the provisions of POPIA, detailing the lawful approach we take in the collection of information and in regard to the management, use and processing of all information collected from you and other legitimate sources and all subsequent dealings with your lawful representatives, credit reporting bodies and other entities listed in this policy. In the course of our business we only process Personal Information for the sole and exclusive use for which it is sought and intended.
5. We respect your privacy and we are committed to protecting the privacy of the users of this website. We seek to use our best endeavours when it comes to the collection and processing of Personal Information. We further reserve the right to change our Notice as necessity dictates.

1. In terms of Section 18 of POPIA you are hereby expressly informed of the fact that when you: engage in any competition run directly or indirectly by LottoStar; register an account with LottoStar; deposit monies; place betting transactions; and/or withdraw any monies from your LottoStar account you are providing LottoStar with the following Personal Information, including but not limited to:
   1. Your first and last name,
   2. Your identity number or Passport number;
   3. Mobile number;
   4. Date of birth;
   5. Banking details;
   6. Source of funds;
   7. Home or other physical address;
   8. Email address;
   9. online identifiers (e.g. cookies, online analytical identifier numbers, internet protocol (IP) addresses and device ID;
   10. biometric information (e.g. facial biometrics);
   11. photographs/images; and
   12. Other contact data as the case may be.
2. We collect and record all telephone calls, internet communications (including IP addresses), all correspondence we have with you irrespective of the medium of communication, details of your betting transactions and visits to our website. In addition, we collect and generate information in relation to your betting activities, records of withdrawals and your customer profile. You may contact our Information Officer to obtain any information in regard to your personal data that we hold about you.

We do not collect any special Personal Information as defined in section 26 of POPIA including your religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion (except as is required for purposes of identifying a politically exposed person (peps) under the Financial Intelligence Centre Act, 2001), health or sexual orientation or biometric information.

1. We collect Personal Information from:
   1. You on the basis of the documents requested;
   2. Agents;
   3. Service Providers;
   4. Advisers;
   5. Credit Reporting bodies;
   6. Government;
   7. Contractors, vendors, or suppliers;
   8. Agents, distributors, or other resellers;
   9. Public sources; and/or
   10. Social media, emails and telephone calls.

1. Using, processing, sharing/transferring or engaging in analytics of your Personal Information for:
   1. routine business purposes; or
   2. the purpose of new business or product development. This may include circumstances contemplated in clauses 5.2. to 5.19.
      
2. To establish your needs, requirements and preferences in relation to the products and/or services provided by LottoStar.
3. To allocate unique identifiers to you for the purposes of processing your Personal Information, securely storing, retaining, and recalling your Personal Information from time to time, regardless of whether you conclude an agreement with LottoStar.
   
4. To evaluate whether or not to offer, extend or modify any offering or service requested by, or provided to you.
   
5. For general administration purposes pertaining to your request(s) and to reply to you when you contact our Customer Service for support.
   
6. To improve the quality of LottoStar’s products and services.
   
7. To transfer your Personal Information across the borders of South Africa to other jurisdictions should it be so required for the legitimate business requirements and interests of LottoStar.
   
8. To identify products and services which might be of interest to you, as well as to inform you of such products or services.
   
9. To process any betting transaction that you submit and to notify you of the outcome of your bet.
   
10. To lawfully allocate funds deposited by you into your LottoStar account.
    
11. To investigate and attempt to resolve your query, complaint or request.
    
12. To administer a promotional competition you may have entered through our website, or otherwise, and deliver any prize that may be applicable.
    
13. To process your withdrawal that you have requested from our account.
    
14. To verify the accuracy of your Personal Information.
    
15. For business purposes such as analysing and managing our business, market research, audits, developing new products, gauging customer satisfaction and customer services.
    
16. For the purpose of enhancing the scope of the products and services we can offer to you or the method of delivery of same, share or transfer all or any part of your Personal Information to a third party who is a potential business partner or actual provider/ supplier of outsourced services to LottoStar.
    
17. To check when was the last time you used LottoStar services, if at all.
    
18. To receive confirmation that you have provided us with authority to act as the Responsible Party if information is held by a third party.
    
19. To, unless you expressly “opt-out”, process your Personal Information as defined above for the purpose of marketing and advertising to you products and services provided by LottoStar.
20. To share your Personal Information with LottoStar’s The Star Foundation (“TSF”) in order for TSF to issue Section 18A (i.e. tax deduction) certificates.

1. We are legally required to collect and process certain information, including:
   
   1. in terms of the Financial Intelligence Centre Act (to meet our know-your-client obligations), including monitoring accounts to combat money laundering, financing of terrorist activities and conducting sanctions screening; or
   2. to meet record-keeping obligations; or
   3. to report and respond to information requests from relevant authorities;
   4. to report suspicious, unusual and fraudulent activities on your account to the relevant authorities; or
   5. to report to any other governmental agency or statutory body (including, but not limited to, the South African Police Service, the South African Revenue Service, the Mpumalanga Economic Regulator (or any other provincial gambling board) and the National Gambling Board); or
   6. for purposes of dealing with duplicate processing, chargeback requests/recall requests, allegations of fraud or the like received from banking institutions.
      
2. We reserve the right to disclose your Personal Information in the interests of enforcing our terms and conditions and without prior notification and/or consent required from the Player.
3. We are additionally entitled to use or disclose your Personal Information if such use or disclosure is required in order to comply with any applicable law, subpoena, order of court or legal process served on us, or to protect and defend our rights or property. The aforementioned may be shared without prior notification and/or consent required from the Player

1. Your personal information may be shared with third party vendors (such as software developers) to help us maintain our service.
   
2. Your personal information is only shared with service providers that we trust and who have agreed to keep your personal information safe and confidential.
   
3. We will take all reasonable steps to ensure that your information is kept secure and protected.
   
4. Service providers are used to communicate with you, verify that your personal information provided is accurate; store betting transactions and your personal information; provide IT services; to conduct checks against appropriate third party databases to verify identity, personal details or credit card information; and any other information supplied by you that LottoStar deems necessary to acquire independent verification.
   

1. The information you provide maybe transferred across foreign borders. This information transfer is authorised under Chapter 9 of POPIA which allows a Responsible Party (“access seeker”) access to transfer the information across foreign borders in the following circumstances:
   
   1. Two bodies must provide adequate protection of the information so requested and received;
      
   2. You must consent to the transfer;
      
   3. The transfer must be necessary for the performance of a contract between you and the responsible party;
      
   4. For the implementation of pre-contractual measures taken in response to your request;
      
   5. The conclusion or performance of a contract concluded in your interest between the Responsible Party and a third party; or
      
   6. The transfer is for your benefit and it is not reasonably practicable to obtain your consent for that transfer and if it were reasonably practicable to obtain such consent, you would provide it.

1. In all circumstances the information is held by LottoStar on our secure systems or data base.
   
2. We undertake to take all reasonable and necessary steps to secure the integrity and confidentiality of your Personal Information and protect your information from misuse, loss, interference, unauthorised access, modification or unauthorised disclosure.
   
3. Electronic copies are held in a secure environment, with the application of appropriate passwords and other computer and software security protocols.
   
4. Information required to process third party checks and payments are transmitted securely to LottoStar’s processors. The parties with which LottoStar contracts for the verification of information may keep records of all data requests and data submitted to them by LottoStar.
   
5. All your Personal Information is stored securely by LottoStar through the use of Cloud based storage facilities.
   
6. We may transmit or transfer Personal Information outside South Africa to a foreign country, as such, Personal Information may be stored on servers located outside of South Africa in a foreign country.
   
7. By using the website and the services offered, Players consent to us processing their Personal Information in a foreign country, i.e. outside of South Africa, whose laws regarding processing of Personal Information may be less stringent.

1. LottoStar will always keep the Personal information of a Data subject for the period required by law and where it needs to do so in connection with legal action or an investigation in which it is involved.
   
2. Otherwise, LottoStar will keep Personal information of a Data subject:
   
   1. for as long as needed to provide the Data subject with access to services he has requested;
      
   2. where the Data subject has contacted LottoStar with a question or request, for as long as necessary to allow LottoStar to respond to the question or request and as required by law.

1. You have the right to withdraw all or part of any consent you may be required to provide in relation to our processing of your Personal Information.
   
2. In the event that you withdraw all or part of your consent, there may be a certain period of time during which LottoStar is legally or contractually obliged to, or for which there may be a legitimate business need, to continue processing such Personal Information until a full and final termination of our business relationship with you can be affected.
   
3. If your consent is withdrawn partially or fully in any particular set of circumstances, this may influence our ability to provide services to you, for which LottoStar cannot be held liable or responsible.
   
4. You have a right to be notified that your Personal Information is being collected.
   
5. You have a right to be notified of any security breaches and/or compromises where there are reasonable grounds to believe that your personal information may have been accessed by an unauthorised person.
   
6. You have a right to ask LottoStar what Personal Information we have on record and gain access to such information.
   
7. You have the right to correct and/or erase wrong and/or inappropriate personal information provided that specific statutory and/or gaming regulations do not require us to retain certain Personal Information about you.
   
8. You have a right to unsubscribe (“opt-out”) from any direct marketing material that LottoStar may send you from time to time.

This notice applies to all data (including all Personal Information) past, present or future submitted by you to LottoStar or which we otherwise obtain pursuant to undertaking our normal business activities.

You may complain in either of the two ways. You may complain verbally or in writing by contacting dataprotection@lottostar.co.za. Alternatively, you may lodge a formal complaint with the Information Regulator of South Africa (complaints.IR@justice.gov.za / inforeg@justice.gov.za). Postal address: P.O Box 31533, Braamfontein, Johannesburg, 2017.

1. Data Subjects must inform LottoStar when their personal information changes, as soon as possible after the change.
2. You warrant that when you provide LottoStar with personal information pertaining to your spouse or any other person, you have permission from them to share their personal information with LottoStar. LottoStar will collect the personal information of the player’s spouse or any other person which the Player has shared with it as stated in this notice.

In terms of section 1 of the Promotion of Access to Information Act, 2000 and section 55 of POPIA, Tasoulla Hurwitz (dataprotection@lottostar.co.za) is the Information Officer for LottoStar. In terms of section 58 of POPIA, Alexandra Stylianou (dataprotection@lottostar.co.za) is the Deputy Information Officer.