Privacy Policy

Last updated: July 2025

Summary

This privacy policy aims to give you information on how Zebra Games Ltd collects and processes your personal data through your use of the website, including any data you may provide through this website when you take part in a prize draw, purchase tickets for a free prize draw or sign up to our newsletter.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
Where we rely on your consent, you may withdraw this consent at any time.

Important information and who we are

This privacy policy sets out how Zebra Games Ltd (“we”, “us”, “our”) processes your personal data and your data protection rights, including the right to object to some of the processing. We are the controller in relation to the processing described in this privacy policy. This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

If you have any questions about this privacy policy, including any requests to exercise your data protection rights, please contact us using the information set out in the contact details section.

The types of personal data we collect about you and how we collect it

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Category	Details
Identity Data	title, first name, last name, any previous names, username or similar identifier, date of birth, social media username(s) alongside image, voice, footage and other information that identifies you, including as necessary for KYC purposes.
Contact Data	billing address, home address, email address and telephone numbers.
Financial Data	bank account and payment card details and any wider information required to adopt social responsibility measures we choose to put in place.
Transaction Data	details about payments from you and to you (for example, any prizes), details of draws entered into and games played, and the outcome of those draws and games.
Technical Data	internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data	your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
Usage Data	information about how you interact with and use our website, products and services.
Marketing and Communications Data	your preferences in receiving marketing from us and our third parties and your communication preferences.

The majority of the information listed above will be collected from your directly or generated about you through your use of our website and services and other interactions with us.

Sometimes, we receive information about you from third parties. In particular:

Referrals. Where you have made a referral, or have been referred to our services, we may receive information about that referral to allow us to process referral bonuses, such as referral codes.
Social media services. Where you interact with us through use of social media service, we may receive information about you from that social media service, such as your username and profile information.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy [LINK] for further details.
Technical Data is collected from analytics providers such as Google based outside the UK.
Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Truelayer, Pay.com based inside the UK.
Identity and Contact Data is collected from publicly available sources such as Companies House and the electoral Register based inside the UK. We may also, where appropriate, use third-party services to obtain information to verify your identity and carry out appropriate KYC checks.

We also collect, use and share aggregated data such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering

Mandatory processing

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to sell you a ticket to a lottery draw). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests, unless we rely on a recognised legitimate interests identified by law not requiring such balance to take place. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent, or are otherwise required or permitted to do so by law, including in the case of recognised legitimate interests).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of Data	Legal Basis
To register you as a new customer	1. Identity 2. Contact	Performance of a contract with you. We must be able to identify and contract you to perform our obligations
Ensure you are based in Great Britain, where we are licensed to operate and to ensure that you are eligible to enter a prize draw	1. Technical Data 2. Identity	Necessary for compliance with a legal obligation
Comply with any and all regulatory obligations required for the legal supply of the Prize Draw in the United Kingdom	1. Identity 2. Contact 3. Financial 4. Transaction	Necessary to comply with a legal obligation
Comply with any related social responsibility measures which we put in place from time to time	1. Identity 2. Contact 3. Financial 4. Transaction	Necessary for a contract or, where relevant, our legitimate interest in safeguarding the wellbeing of players.
To verify your identity and carry out relevant KYC checks.	1. Identity 2. Contact 3. Financial 4. Transaction	Necessary for compliance with a legal obligation or (where not required by law) our legitimate interest in preventing fraud and knowing our customer.
To operate the referral scheme, including: 1. Notifying referrers when their referred player wins prizes 2. Sharing winner identity information (name, town/country) within the referral network 3. Facilitating referral bounty payments 4. Administering tier-based referral bounties	1. Identity 2. Contact 3. Transaction	As necessary for the performance of the referral scheme contract of which you are a party or, where you are the referred player, our legitimate interest in sharing information with referrers and the referral network to ensure fairness and transparency of our referral scheme.
To facilitate the payment of prizes to you	1. Identity 2. Contact 3. Financial 4. Transaction	Performance of a contract with you
To detect and prevent fraudulent activity	1. Identity 2. Contact 3. Financial 4. Transaction	Necessary for our legitimate interests in preventing fraud and protecting our business interests
To process your purchases including: 1. Manage payments, fees and charges, including exchanging data with External Third Parties who are providers of technical, payment and delivery of services such as TrueLayer, Fonix and Pay.com 2. Collect and recover money owed to us	1. Identity 2. Contact 3. Financial 4. Transactions	Performance of a contract with you
To otherwise manage our relationship with you, which will include: 1. Notifying you about changes to our terms or privacy policy 2. Dealing with your requests, complaints and queries	Any of the data items listed above.	1. Performance of a contract with you, where we are managing our contractual relationship 2. Necessary to comply with a legal obligation 3. Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)
To administer our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) and protect our business interests and legal rights	Any of the data items listed above.	Necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise and protection our business and legal rights)
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	1. Identity 2. Contact 3. Profile 4. Usage 5. Marketing and Communications 6. Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	1. Technical 2. Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To carry out market research through your voluntary participation in surveys	1. Identity 2. Contact 3. Technical Usage 4. Profile 5. Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services and grow our business)
To make suggestions and recommendations to you about goods or services that may be of interest to you	1. Identity 2. Contact 3. Technical 4. Usage 5. Profile 6. Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business) Or, where required, your consent

Direct Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us about our own similar products and services if you begun a purchase journey on our web services or purchased products or services from us, where you were offered the opportunity to opt out and you have not subsequently opted out of receiving the marketing. We rely on our legitimate interests for such marketing. We may also in other circumstances seek your consent to direct marketing, for example where marketing any third party product or service, or where intending to share your data with a third party for their own marketing purposes. Where you have given consent to marketing, you may withdraw that consent at any time. You can in any event opt-out of marketing at any time including by following the opt-out links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a product/service warranty registration, updates to our Terms and Conditions, checking that your contact details are correct.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see winamillion.com/cookie-policy.

We use Google Analytics on our websites for analytics purposes. Our contract for Google Analytics is with Google Ireland Limited, based outside the UK in the Republic of Ireland. Google Analytics operates through the placing of cookies. We require your consent to use cookies in this way, which we obtain through our consent management platform [add link]. Please note that if you provide your consent to our use of Google Analytics using cookies, your personal data will be transferred to Google LLC (the importer, acting as a sub-processor), based in the USA, where it may be subject to local lawful access. You can withdraw your consent to your personal data being processed by Google Ireland Limited at any time. Further information on our use of Google Analytics can be found in our cookie policy;

Disclosure of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

(a) Internal members of our group which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

(b) External Third Parties for the purposes above, particularly in connection with legal obligations to share or sharing where necessary to protect the rights, interests property, or safety of us, our customers, or others third parties as appropriate. This includes exchanging Contact, Financial and Transaction Data with:

(i) the External Third Parties who are providers of technical, payment and delivery services such as Truelayer, Pay.com, Fonix and other companies and organisations for the purposes of fraud protection, KYC and credit risk reduction;

(ii) IT Systems providers in order to provide software to create your account and communicate with you;

(iii) Marketing services providers and agencies for the purpose of sending email communications and notifications;

(iv) Police, UK law enforcement agencies, security companies and other regulatory authorities for the purpose of compliance with investigations or other regulatory purposes;

(v) Credit reference agencies for the purpose of confirming that your personal data is correct and accurate;

(vi) HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;

(vii) External advisors, including auditors, accountants, lawyers and insurers for the purpose of providing associated services;

(viii) Referrers and the Referral Network in relation to administering our Referral Scheme (this includes details of your winning status, prize amounts, your identity and town/county; and

(ix) Members of the public, where publishing the details of winners to meet self-regulatory principles on administering fair competitions, and

(d) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with the approved methods of ensuring the protection of data transferred internationally under UK law. We in particular use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or if we have put in place any social responsibility scheme that requires us to prevent certain users from making use of our service.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers, including for tax purposes.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

You have a number of rights under data protection laws in relation to your personal data. In some instances these rights may be limited under applicable law.

You generally have the right to:

(a) Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it, subject to certain exemptions.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c) Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be required or able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object or a need to use the information for the establishment, exercise or defence of legal claims.

(e) You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Direct Marketing above for details of how to object to receiving direct marketing communications).

(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g) Withdraw consent at any time where we are relying on consent to process your personal data (see the table above on How we use your personal data for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(h) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

(i) If you want us to establish the data’s accuracy;

(ii) Where our use of the data is unlawful but you do not want us to erase it;

(iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us see Contact Details below

Contact Details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please us in the following ways:

Email address: [email protected]

Postal address: Third Floor, Marlborough House, Victoria Road South, Chelmsford, United Kingdom, CM1 1LN

Right to Complain

You have the right to make a complaint to us, or to the ICO, the UK regulator for data protection issues (<www.ico.org.uk>). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.