Privacy Policy
Last updated: February 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: With your consent, we collect usage statistics via Google Analytics, linked to your user ID when logged in
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)
6. Data Sharing
We may share your data with:
- Stripe: For payment processing
- Google: For analytics (anonymised usage data, with your consent)
- 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 use CookieYes to manage your cookie preferences. You can change your preferences at any time by clicking the cookie icon in the corner of any page.
10.1 Essential Cookies
These cookies are necessary for the website to function and cannot be disabled:
- Session management: Keeps you logged in
- Security: CSRF protection
- Cookie consent: Remembers your cookie preferences (CookieYes)
10.2 Analytics Cookies
With your consent, we use Google Analytics to understand how visitors use our website. These cookies collect information including:
- Pages visited and time spent
- How you arrived at our site
- Your general location (country/city level)
- Device and browser type
If you are logged in, we associate your activity with your user ID to help us understand how members use the service over time. This data is used to improve our website and is not shared with third parties for marketing purposes. You can opt out of analytics cookies at any time via the cookie preferences panel.
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