Privacy Policy
Your privacy and data security are fundamental to our operations. This policy explains how we collect, use, protect, and manage your personal information in compliance with Australian privacy laws.
Last Updated
January 15, 2025
1. Introduction and Scope
This Privacy Policy governs the collection, use, and protection of personal information by HarbourLottoWins.com (referred to as "we," "us," or "our") in connection with our Australian Lottery services operating under the Shadowstage Lantern Theatre brand. This policy applies to all personal information collected through our website, authorized retail locations, customer service channels, and related lottery operations.
We are committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and all applicable state and territory gambling regulations. By participating in our lottery services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.
This policy should be read in conjunction with our Terms of Service, Cookie Policy, and Responsible Gaming Guidelines.
2. Information We Collect
We collect various types of personal information necessary to provide lottery services, ensure regulatory compliance, and enhance your experience. The information we collect includes:
Identity and Age Verification Information
- Full legal name and date of birth
- Government-issued identification documents (driver's license, passport, proof of age card)
- Identification numbers as required for regulatory compliance
- Photographic identification for age verification purposes
We are legally required to verify that all participants are 18 years or older. This information is essential for regulatory compliance and responsible gaming enforcement.
Contact and Location Information
- Residential address and mailing address
- Email address and phone number
- Geographic location data when using our retailer locator services
- Preferred authorized retail location information
Financial and Payment Information
- Payment card details (processed securely through PCI-DSS compliant payment processors)
- Bank account information for prize disbursements
- Transaction history and purchase records
- Tax file numbers for winners of prizes above statutory thresholds
We use industry-standard encryption and secure payment gateways. We do not store complete payment card details on our servers.
Lottery Participation and Winner Information
- Lottery ticket purchase details and entry numbers
- Game selection preferences and participation history
- Win/loss records and prize claim information
- Winner publicity preferences and consent for name publication
- Playbill-style receipts and machine-readable audit strings
Winners of certain prize divisions may be required to provide additional information for tax reporting and regulatory compliance purposes.
Technical and Website Usage Information
- IP address and device information
- Browser type and operating system
- Website navigation patterns and pages visited
- Cookies and similar tracking technologies (see our Cookie Policy)
- Analytics data for website improvement and security monitoring
3. How We Use Your Information
We use your personal information for legitimate business purposes related to lottery operations, regulatory compliance, and service enhancement. Specifically, we use your information to:
Lottery Operations
- Process ticket purchases and entries
- Conduct draws and determine winners
- Verify and pay out prizes
- Generate playbill receipts and audit documentation
- Maintain accurate transaction records
Compliance and Security
- Verify age and identity (18+ requirement)
- Comply with gambling regulations
- Report to regulatory authorities as required
- Prevent fraud and unauthorized access
- Maintain audit trails for regulatory inspection
Customer Service
- Respond to inquiries and support requests
- Process complaints and resolve disputes
- Provide account assistance and updates
- Notify winners and facilitate prize claims
- Improve service quality and user experience
Marketing Communications
- Send lottery results and draw notifications
- Provide promotional offers (with consent)
- Share responsible gaming resources
- Deliver important operational updates
- Conduct customer satisfaction surveys
Legal Basis: We process your personal information based on:
- Legal Obligation: Compliance with gambling laws, age verification requirements, and tax reporting obligations
- Contractual Necessity: Performance of our lottery service contract with participants
- Legitimate Interests: Fraud prevention, service improvement, and business operations
- Consent: Marketing communications and optional data uses (you may withdraw consent at any time)
4. Information Sharing and Disclosure
We do not sell or rent your personal information to third parties. However, we may share your information with specific entities under the following circumstances:
Regulatory Authorities
We are required to share certain information with gambling regulatory bodies, taxation authorities, and law enforcement agencies as mandated by Australian laws. This includes winner information for prizes above statutory thresholds, audit records, and compliance documentation.
Authorized Retail Partners
Our authorized lottery retailers process ticket purchases on our behalf and receive necessary transaction information to fulfill orders. All retailers are contractually bound to protect your information and comply with our privacy standards.
Payment Processors
We use secure, PCI-DSS compliant third-party payment processors to handle financial transactions. These processors receive only the information necessary to complete payments and are prohibited from using your information for other purposes.
Service Providers
We engage trusted service providers for website hosting, data analytics, customer support, and marketing services. These providers operate under strict confidentiality agreements and are authorized to use your information only to perform services on our behalf.
Legal Requirements
We may disclose your information when required by law, court order, or legal process, or when necessary to protect our rights, property, or safety, or that of our users or the public.
Winner Publicity
For major prize winners, we may publicly announce first name, suburb, and prize amount as permitted by law and with your consent where required. You may opt out of publicity in certain circumstances, though some disclosure may be legally mandated.
5. Data Security and Protection
We implement comprehensive security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:
Encryption and Secure Storage
All sensitive data is encrypted both in transit (using SSL/TLS) and at rest. We use industry-standard encryption protocols to protect payment information, personal details, and authentication credentials.
Access Controls
Access to personal information is restricted to authorized personnel who require it for specific job functions. We maintain strict authentication protocols and regularly review access permissions.
Security Monitoring
We employ continuous security monitoring, intrusion detection systems, and regular vulnerability assessments to identify and address potential threats promptly.
Regular Audits
Independent security audits and compliance reviews are conducted regularly to ensure our systems and practices meet or exceed industry standards and regulatory requirements.
Data Breach Notification
In the unlikely event of a data breach affecting your personal information, we will notify you and relevant authorities as required by law. We maintain an incident response plan to address security breaches promptly and minimize potential harm.
6. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory obligations. Our retention periods vary depending on the type of information and applicable requirements:
Retention Periods
- Transaction Records: Retained for 7 years from the date of transaction to comply with taxation and financial reporting requirements
- Winner Information: Retained for 7 years or longer as required by gambling regulations for major prizes
- Age Verification Records: Retained for the duration of your participation plus 2 years
- Marketing Preferences: Retained until you withdraw consent or request deletion
- Website Analytics: Anonymized and aggregated data retained for 26 months
- Legal Hold: Information subject to legal proceedings or regulatory investigations retained until resolution
When personal information is no longer required, we securely delete or anonymize it according to our data destruction procedures. Some information may be retained in archived form for historical record-keeping and regulatory compliance purposes.
7. Your Privacy Rights
Under Australian privacy law, you have specific rights regarding your personal information. We respect these rights and provide mechanisms for you to exercise them:
Right to Access
You may request access to the personal information we hold about you. We will provide a copy of your information in a commonly used format within 30 days of your request, subject to identity verification.
Right to Correction
If you believe information we hold about you is inaccurate, incomplete, or outdated, you may request corrections. We will update your information promptly, except where legal or regulatory obligations require us to maintain specific records.
Right to Deletion
You may request deletion of your personal information, subject to legal and regulatory retention requirements. Some information may need to be retained for compliance purposes even after you request deletion.
Right to Object
You may object to certain uses of your information, particularly for marketing purposes. You can opt out of marketing communications at any time using the unsubscribe link in emails or by contacting our privacy officer.
Right to Data Portability
You may request a copy of your personal information in a structured, machine-readable format for transfer to another service provider, where technically feasible.
Right to Lodge a Complaint
If you believe we have mishandled your personal information, you may lodge a complaint with us or with the Office of the Australian Information Commissioner (OAIC). We will investigate all complaints promptly and work to resolve issues satisfactorily.
How to Exercise Your Rights
To exercise any of these rights, please contact our Privacy Officer:
Email: privacy@HarbourLottoWins.com
Mail: Privacy Officer, HarbourLottoWins.com, Australia
We will verify your identity before processing requests and respond within 30 days. Some requests may require additional time for complex matters or high volumes of information.
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance website functionality, analyze usage patterns, and improve user experience. Cookies are small text files stored on your device that help us recognize you during return visits.
Our website uses the following types of cookies:
- Essential Cookies: Required for website functionality, age gate verification, and security features. These cannot be disabled without affecting site operation.
- Performance Cookies: Collect anonymous data about website usage to help us improve performance and user experience.
- Functional Cookies: Remember your preferences, preferred retail locations, and customization choices.
- Analytics Cookies: Help us understand how visitors interact with our website through aggregated, anonymized data collection.
You can control cookie settings through your browser preferences. However, disabling certain cookies may limit website functionality. For detailed information about our cookie practices, please review our Cookie Policy.
9. Children's Privacy
Our lottery services are strictly for individuals aged 18 and over. We do not knowingly collect personal information from minors. Our age verification procedures are designed to prevent underage access to our services.
Strict Age Verification
All participants must verify they are 18 years or older before accessing lottery services. We require government-issued identification for ticket purchases at authorized retail locations and maintain mandatory age gates on our website.
If we discover that we have inadvertently collected information from someone under 18, we will delete that information immediately. Parents or guardians who believe we may have collected information from a minor should contact us immediately at privacy@HarbourLottoWins.com.
10. International Data Transfers
Our operations are based in Australia, and we primarily store and process personal information within Australian territory. However, some of our service providers may be located overseas or may store data on servers outside Australia.
When we transfer personal information overseas, we ensure:
- The recipient country has substantially similar privacy protections to Australian law
- We have binding contractual agreements requiring recipients to protect your information
- You have consented to the overseas transfer where required by law
- The transfer is necessary for lottery operations or regulatory compliance
By using our services, you acknowledge that your information may be transferred, stored, and processed in countries outside Australia in accordance with this Privacy Policy and applicable law.
11. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or service offerings. When we make significant changes, we will notify you through prominent website notices, email communications, or other appropriate channels.
The "Last Updated" date at the top of this policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.
Continued use of our services after policy changes constitutes acceptance of the updated terms. If you do not agree with changes, you should discontinue use of our services and may request deletion of your information subject to retention requirements.
12. Contact Information
For privacy-related questions, concerns, or requests, please contact our Privacy Officer:
Privacy Officer
Email: privacy@HarbourLottoWins.com
Mail: Privacy Officer, HarbourLottoWins.com, Australia
We will respond to privacy inquiries within 30 days. Complex matters may require additional time, and we will keep you informed of progress.
13. Additional Legal Information
This Privacy Policy is governed by Australian privacy law, including the Privacy Act 1988 (Cth), the Australian Privacy Principles, and applicable state and territory gambling regulations. We operate under the supervision of the Victoria State Government gambling regulatory authority and comply with all mandated reporting and disclosure requirements.
Related Policies
For comprehensive understanding of our terms and practices, please also review:
This Privacy Policy was last updated on January 15, 2025. Version 1.0.
Your Privacy Matters
We are committed to protecting your personal information and maintaining transparency in our data practices. If you have questions or concerns about how we handle your privacy, please don't hesitate to contact our Privacy Officer.