Privacy Policy

Last updated: October 2026

1. Introduction

This Privacy Policy explains how Herefordshire Samaritans ("we", "us", "our") collects, uses, and protects your personal information when you use The 44 Club lottery service.

2. Data Controller

Herefordshire Samaritans is the data controller for your personal information. We are registered with the Information Commissioner's Office (ICO).

3. Information We Collect

3.1 Information You Provide

Account information: Name, email address, phone number, date of birth
Address: For prize payment and verification purposes
Payment information: Processed securely by Stripe (we do not store card details)

3.2 Information Collected Automatically

Usage data: Pages visited, features used
Device information: Browser type, operating system
Log data: IP address, access times
Analytics data: Anonymous usage statistics via Umami, which doesn't use cookies or identify you

4. How We Use Your Information

We use your information to:

Operate the lottery and process ticket purchases
Send draw results and winner notifications
Process prize payments
Comply with legal obligations
Improve our services
Communicate important updates about The 44 Club

5. Legal Basis for Processing

We process your data based on:

Contract: To provide the lottery service you signed up for
Legal obligation: To comply with gambling and financial regulations
Legitimate interests: To improve our services and prevent fraud
Consent: For marketing communications (where applicable)

We may share your data with:

Stripe: For payment processing
Umami: For anonymous website analytics
Email service providers: For transactional emails
Our Directorship or Trustees: For prize payment processing

We do not sell your personal information to third parties.

7. Data Retention

Active accounts: Data retained while your account is active
Closed accounts: Personal data anonymised, transaction records retained for 7 years (regulatory requirement)
Marketing preferences: Retained until you opt out

8. Your Rights

Under UK GDPR, you have the right to:

Access: Request a copy of your personal data
Rectification: Correct inaccurate data
Erasure: Request deletion of your data (subject to legal retention requirements)
Portability: Receive your data in a portable format
Object: Object to certain processing activities
Withdraw consent: Where processing is based on consent

To exercise these rights, contact us or use the options in your account settings.

9. Data Security

We implement appropriate security measures including:

Encryption of data in transit (HTTPS)
Secure password hashing
Regular security reviews
Limited staff access to personal data

10. Cookies

We only use cookies that the website needs to work. They can't be turned off:

Session management: Keeps you logged in
Security: CSRF protection

10.1 Analytics

We use Umami to understand how people use our website. Umami doesn't use cookies, doesn't track you across other websites, and doesn't identify you. It records:

Pages visited
How you arrived at our site, including the campaign link you followed
Your general location (country level)
Device and browser type
When you start a checkout or complete a purchase, with the number of tickets and the amount, but never who you are

We remove anything personal from page addresses, such as email addresses or reset links, before they're sent. We use this information only to improve our website and our fundraising.

We do not use advertising or marketing cookies.

11. Children's Privacy

The 44 Club is not intended for anyone under 18. We do not knowingly collect data from minors.

12. Changes to This Policy

We may update this policy from time to time. Significant changes will be communicated by email.

13. Contact & Complaints

For any questions about the Lottery or our Privacy Policy, please contact us via our contact page or write to us at:

The Samaritans,
44a Berrington Street,
Hereford,
HR4 0BJ