Draw List Lotto ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you participate in our charity raffle or visit our website.

By purchasing a raffle ticket or using our website, you consent to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Personal Information You Provide

We may collect the following personal information when you purchase raffle tickets or interact with our services:

• Contact Information: Name, email address, phone number, mailing address
• Identification Information: Date of birth, government-issued ID (for age verification and winner claims)
• Transaction Information: Ticket purchase details, payment information (processed securely through third-party payment processors)
• Communication Records: Records of your correspondence with us via email, phone, or other channels

1.2 Information Collected Automatically

When you visit our website, we automatically collect certain information, including:

• Device Information: IP address, browser type, operating system, device type
• Usage Data: Pages visited, time spent on pages, links clicked, referring website
• Cookies and Similar Technologies: We use cookies to enhance your browsing experience (see Section 6 below)

1.3 Information We Do NOT Collect or Store

To protect your security, we do NOT directly collect or store:

• Full credit card numbers or banking information (handled securely by our payment processors)
• Social insurance numbers
• Sensitive health or financial records beyond what is necessary for raffle participation

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Raffle Administration

• Process ticket purchases and payments
• Verify eligibility to participate (age and residency requirements)
• Conduct the raffle draw and select winners
• Contact winners and verify their identity
• Deliver prizes to winners
• Maintain records for regulatory compliance and auditing

2.2 Communication

• Send transaction confirmations and receipts
• Provide customer support and respond to inquiries
• Send important updates about the raffle, draw dates, and results
• With your consent, send newsletters and promotional information about future raffles

2.3 Legal and Regulatory Compliance

• Comply with applicable laws, regulations, and AGCO requirements
• Maintain records as required by gaming authorities
• Respond to legal requests and prevent fraud or illegal activities

2.4 Website Improvement

• Analyze website usage to improve functionality and user experience
• Troubleshoot technical issues
• Monitor and ensure website security

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share your information only in the following limited circumstances:

3.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating our raffle and website, such as:

• Payment processors (for secure payment handling)
• Email service providers (for communications)
• Web hosting and technology providers
• Prize fulfillment services

These service providers are bound by confidentiality agreements and are only permitted to use your information for the specific services they provide to us.

3.2 Legal Requirements

We may disclose your information if required by law, including:

• In response to subpoenas, court orders, or legal processes
• To comply with regulatory requirements (e.g., AGCO reporting obligations)
• To protect our rights, property, or safety, or that of our users or the public
• To investigate or prevent fraud, illegal activities, or violations of our terms

3.3 Charitable Partners

We may share aggregated, non-identifiable information about raffle proceeds and participation with our charitable partners for transparency and reporting purposes.

3.4 Public Announcements

Winners' names and cities of residence may be publicly announced on our website, social media, and other channels as required by regulations and to maintain transparency. We do not publicly disclose full addresses or other sensitive information.

4. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Secure Socket Layer (SSL) encryption for data transmission
• Secure servers and databases with access controls
• Regular security assessments and updates
• Employee training on data protection and confidentiality
• Use of reputable third-party payment processors that comply with PCI-DSS standards

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Raffle Records: Retained for at least 7 years as required by AGCO regulations
• Winner Information: Retained indefinitely for verification and historical records
• Marketing Communications: Retained until you opt out or request deletion
• Website Analytics: Typically retained for 1-2 years

After the retention period expires, we will securely delete or anonymize your personal information.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze site usage.

Types of Cookies We Use:

• Essential Cookies: Necessary for the website to function properly (e.g., session management)
• Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics)
• Preference Cookies: Remember your settings and preferences

Managing Cookies:

You can control cookies through your browser settings. Most browsers allow you to:

• View and delete cookies
• Block cookies from specific websites or all websites
• Set your browser to notify you when cookies are being set

Please note that disabling cookies may affect the functionality of our website.

7. Third-Party Links

Our website may contain links to third-party websites, such as charitable partner sites, social media platforms, or support resources. We are not responsible for the privacy practices of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

8.1 Access and Correction

You have the right to request access to the personal information we hold about you and to request corrections if the information is inaccurate or incomplete.

8.2 Deletion

You may request that we delete your personal information, subject to legal and regulatory obligations that may require us to retain certain records.

8.3 Opt-Out of Marketing

You may opt out of receiving promotional emails from us at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us directly at privacy@drawlistlotto.com

Please note that even if you opt out of marketing communications, we may still send you transactional emails related to your raffle participation.

8.4 Withdraw Consent

If we process your information based on your consent, you have the right to withdraw that consent at any time.

To Exercise Your Rights:

Contact us at privacy@drawlistlotto.com with your request. We will respond within a reasonable timeframe as required by applicable law.

9. Children's Privacy

Our raffle is intended for individuals 18 years of age or older. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected information from a person under 18, we will take steps to delete that information promptly.

10. Compliance with Canadian Privacy Laws

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy legislation. This includes:

• Collecting personal information only for legitimate purposes
• Obtaining consent for collection, use, and disclosure
• Limiting collection to what is necessary
• Ensuring accuracy of information
• Protecting information with appropriate safeguards
• Being transparent about privacy practices
• Providing access to personal information upon request
• Being accountable for compliance

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending an email notification if you have provided your email address

Your continued use of our services after changes are made constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

13. Privacy Complaints

If you believe we have not complied with this Privacy Policy or applicable privacy laws, you may file a complaint by contacting our Privacy Officer using the information above.

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

• Website: www.priv.gc.ca
• Phone: 1-800-282-1376