This Privacy Notice describes how TMC Competitions Limited (or otherwise referred to herein as “TMC Competitions”,” Company” “us” or “we”) treats your personal information and the data provided to us in order to be able to manage our relationship. We manage any personal information you provide to us (either through the website www.the-millionaire-club.co.uk or through any other similar means) and are kept by us in relation to you in the manner specified in this Privacy Notice.

1. Who are we?

We are TMC Competitions Limited, a UK company registered in the United Kingdom with company number 13953665, and having its registered office at 1 The Green, Richmond, Surrey, TW9 1PL, United Kingdom. You can contact us by writing to contact@themillionaire.co.uk

2. Why do we collect personal data?

We need to collect data from you to be able to provide you with this service. This may include the need to share this data with our partner companies and service providers, with whom we would have established safeguards to protect your data, for the purpose of providing you with our services as requested when you signed up and accepted the terms and conditions.

We also have a legitimate interest to protect our services from promotion abuse, fraudulent activities, and internet security risks. This also allows us to ensure the security, integrity, accessibility and availability of our data and services.

We may offer marketing communications so that you are constantly kept updated with news about new products, bonuses, special offers and other similar promotions. When this happens, we will ask for your consent to receive such communications. You will have the right at all times and at no cost to withdraw your consent either through your account profile privacy settings or by sending us an email at contact@themillionaire.co.uk

3. What personal data do we collect?

We may collect and process the following categories of personal data:

1. Personal identification and communication details provided to us by completing the registration form on the website or any other information you submit to us through the website or by email.

1. Verification documents provided for Identity, Age and Address, Payment Method verification and other documentation we may request due to our obligations at law.

1. Contact information collected through the website, email, telephone, or other media.

1. Your answers to questionnaires or surveys we may conduct directly or through third parties.

1. Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone, or other media.

1. Details of your visits to the site, including but not limited to traffic data, site information, weblogs, geolocation, and other contact information.

1. Telephone calls or chat sessions to and from our Customer Service Department are recorded for security and educational purposes along with the resolution of questions arising from the service provided to you.

4. Use of Cookies

We use cookies as a means of collecting information from an internet server for the below reasons, at visiting of the site by a member.

Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the website and provide better and more personalized services. Some of the cookies we use are necessary for the operation of the site. For those types of cookies that do not contribute to the operations on the website, we are required to obtain your consent.

If you want to delete any cookies already stored on your computer or stop cookies that record your browsing habits on the webpage, you can do so by deleting your existing cookies and / or by changing your browser’s privacy settings to block cookies (the procedure you follow will vary depending on the browser). Please note that by deleting our cookies or by deactivating our future cookies, you may not be able to access certain sites or services on the site.

To find out more, please read our Cookies Policy.

5. Why do we process your data?

We use your personal data to:

• Create, operate, and manage your account;
• Allow you to participate in competitions and perform relevant functions to participate in them;
• Carry out identification procedures for your participation in the competitions;
• To purchase competition tickets, and to process online payments;
• Comply with the legal and regulatory frameworks governing our operations, including transmission of personal details, personal data about transactions and traffic data to authorities;
• Create personal profiles for Fraud and Anti-Money Laundering Risk Assessment purposes;
• Track transactions for the purpose of preventing fraud, money laundering and fraud, including exchanging personal data with our suppliers of Payment Processing services;
• Conduct research, questionnaires, and analysis;
• For company tax reporting obligations to the tax authorities;
• Meet our obligations to inform and assist relevant authorities in relation to any potential criminal activities such as fraud, money laundering or terrorist financing; and
• any other relevant legislation that requires us to provide some personal information.

When you explicitly consent to marketing, we use your data to provide you with information about site changes, new services, offers and promotions. In case you no longer wish to receive marketing information, you have the right to opt-out of this service. You can opt in again to receiving marketing communications by emailing our support department.

To provide our services, and for the purpose of preventing illegitimate use of our services, we carry out profiling of our customers and their activities using automated processes. However, any decisions taken based on these profiles and information are taken by natural persons.

6. Where do we keep your data?

We take all industry standard precautions to keep your personal data secure within our physically located servers. These servers may in turn be accessed through encrypted connections over the internet. For this purpose, we do our utmost to follow best security practices and standards and to use providers which ensure an adequate level of security.

7. Who do we share your personal data with?

In the event of the need to supply personal data to third parties, a specific opt-in for transfer of your data to these third parties will be provided where the names of such parties and the purpose such persons may use your data will be disclosed. Such events may include for example marketing.

The Company may, however, disclose or transfer data you provide to us, or inferred data based on your data for multiple purposes such as to provide you with our services including but not limited to payment processing, customer support and Anti-Fraud / Anti-Money Laundering checks.

The company may disclose or transfer data you provide to us, or inferred data based on your data for multiple purposes as described in the following sections.

A list of our third-party suppliers can be provided upon request.

Disclosures to third parties to provide you with services.

Your personal data is transferred to some companies to carry out the following processes:

• Payment processing;
• Marketing, where consent has been provided;
• Anti-Fraud and Anti-Money Laundering checks;
• Other Data Controllers;
• Joint Controllers;
• Data Processors.

All mandatory information along with additional requested information, provided by players or potential players during the registration process may be processed for anti-money laundering (AML) purposes.

Disclosures to third parties to satisfy regulatory obligations and legitimate interests.

When processing your competition account and its associated transactions, the company and its contracted processors may need to appeal to credit rating agencies, fraud detection agencies and money laundering agencies to be able to comply with its regulatory and statutory obligations.

The purpose of such communications would be to:

• Assess whether you may be a Politically Exposed Person or an individual subject to Financial Sanctions.
• Assess whether your personal details are similar to those of people suspected of having committed fraud or money laundering.
• Verify your personal details through electronic means by matching against third party databases.

Where such information is requested by payment providers in relation to enquiries regarding fraud, we shall also provide such personal data as long as the request for information is aimed to protect your rights and/or, the legitimate interest of the company to protect itself from fraud.

Disclosures for marketing purposes

The Company may share personal data with marketing partners only based on a freely given, specific, informed, and unambiguous consent from you. Such partners would be limited to receive contact information such as e-mail address and sports preferences for marketing reasons.

You can withdraw your consent at all times through your account profile or by contacting us on contact@themillionaire.co.uk. Should you withdraw your consent, the company will inform marketing partners to stop their marketing communications to you as soon as we receive your request.

8. For how long do we keep your data?

After the closure of any account, the company retains certain elements of personal data for a period of up to 10 years to meet our legal obligations towards Anti-Money Laundering and Countering Finance of Terrorism, Company and Taxation record-keeping obligations.

Specifically:

1. For up to one (1) year from last activity: Details of your visits to the site, including but not limited to traffic data, site information, weblogs, and other contact information; Telephone calls to and from our Customer Service Department;
2. For up to five (5) years from last activity: Personal identification and communication details provided, contact information through the website, email, telephone, or other media;
3. For up to ten (10) years from last activity: Elements of transactions, including financial accounts information that you may provide us, made through the website, telephone, or other media.

We will also keep personal data for the purpose of presenting and processing in case of a litigation or a legal process which you, the relevant authorities or us may be party to, due to our provision of services to you.

If your account, in any of the above cases is not active, then we will not process the data further except for complying with the above legal obligations.

All this information is stored in accordance with this Privacy Notice.

9. Your Rights

You have the right to:

1. access to the personal information provided by you;
2. request rectification of personal data that you consider incorrect;
3. request for restriction of processing of data;
4. request erasure of data;
5. file an objection about processing of your data;
6. request to export your data; and
7. be informed about automated individual decision-making, including profiling; and
8. you have the right at all times to object to the processing of your data and to withdraw your consent through your account profile privacy settings.

Your rights may be exercised in accordance with the Law, which might include restrictions on when you can exercise these rights.

You can exercise these rights by accessing your Privacy Dashboard or by contacting us at contact@themillionaire.co.uk

10. Changes to this Privacy Notice

Any changes we may make to our Privacy Notice in the future will be published from this page on the site and will be effective from the time of their posting. You can request previous versions of this document by sending us an email at contact@themillionaire.co.uk