Privacy Policy

Pick Media Ltd (‘Pick’ / ‘we’) collects and processes information from our members and potential members at several different points on freemojilottery.com (the ‘Website’) as well as through other methods of contact, including email.

This Privacy Policy (‘Policy’) along with Pick’s Terms and Conditions and Cookie Policy sets out the way Pick collects, stores and uses data relating to you (your personal data) and the reasons for doing so.

By continuing to access the Website, by registering on the Website, or by providing information to Pick, you are accepting and consenting to Pick’s use of your personal data, as a Data Controller, in the ways set out in this Policy.

A summary of how we collect, store and use your data

When it comes to your personal data, Freemoji Lottery operates on three very simple principles:

  • We won’t sell your personal information to others without asking you directly;
  • We won’t share your contact details without your explicit permission, so the emails you’re agreeing to receive will only be coming from us;
  • We will follow industry practices to secure your data and always take our responsibilities as a data controller seriously;

In order to run the Website effectively, we collect information from various sources, including third parties. This information may be collected automatically, such as when you visit the site, or explicitly, such as when you answer questions or surveys or set your preferences.

We utilise this information to:

  • Improve your experience on the Website, by giving you control over your settings and preferences and by providing more relevant advertisements and offers.
  • Measure, fix and improve the Website’s performance.
  • Monitor the use of the Website for a wide range of purposes, including the provision of rewards to our members, the prevention of suspicious or fraudulent claims and recording statistics that help Pick run more successfully as a business.
  • Share anonymous and aggregated statistics between our trusted partners including our advertisers, affiliates, acquisition partners, survey participants and monitoring services.
  • Connect with third party services including social media companies and survey tools.
  • Contact you, but only where you have consented or requested that we do so.

General data collection

The following personal data relating to you may be collected:

Information you provide

You may provide information to us through web forms on the Website, by email, or by phone. The information you provide may include your name, address, e-mail address and phone number. We will not intentionally or systematically seek to collect, store, use or otherwise process information about you classed as ‘sensitive personal data’ (for example, information relating to any trade union membership, ethnic origin or medical conditions). We cannot prevent you from disclosing the same to Pick, or Pick’s agents, as part of your correspondence with us but you should ensure that such information is only provided where it is absolutely necessary.

Information we collect

We automatically collect certain information to help analyse the Website and our service, including: technical information like the internet protocol (IP) address used to connect your computer or device to the internet, your browser type and version, time zone setting, operating system and platform; and information about your visit including the full uniform resource locators (URL) clickstream to, through and from our site (including date and time); pages you visited or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. This General Data may be used for analysing the performance of any aspect of the Website, or the Website as a whole, including split testing experiments (also known as A/B testing).

Any phone number used to call our contact numbers, postal addresses supplied in correspondence and any email addresses used to contact us are also stored for the purposes of administration and record-keeping.

We also collect information from the third party services outlined in this Policy.

Pick’s services and the Website are for use by members 18 years old and over only. We do not market to users under the age of 18 and do not intentionally collect data on users under the age of 18.

Using your information

Pick uses the information you provide largely to contact you – by email, phone or by post – in order to seek further information, to update you on any changes to our service, to send you general commercial (non-marketing) communications, to send you any communications that you have specifically requested, and to inform you of any similar or related services that we provide that we consider may be of interest to you. We may keep this information on file to record enquiries that we have received about our service, to help us to assess how effective our various marketing programs are, and to comply with any legal obligations that may be imposed upon us from time to time, such as recording your consents to Notifications.

Pick uses the information we collect to ensure our Website and other communications with you are presented in the most effective way, to administer the Website (including troubleshooting it and carrying out testing and analysis), to ensure that our Website and other arrangements for collecting your data and communicating with you are as secure as possible and for marketing purposes.

Sharing your information

Pick might share your information with others, in limited circumstances, including as follows:

We will share your information amongst Pick’s group companies (that means companies that partially own Pick or are owned by Pick) – as they may help in analysing and progressing your potential instructions.

As mentioned above, we work closely with selected partners who may provide administrative support, who may assist in collecting and storing your information and who may assist Pick in contacting you.

We may share information with analytics and search engine providers that assist us in the improvement and optimisation of our site. Please see the section on “Third party tracking” for details on how to opt-out where possible.

We may need to disclose your information if required by law, if we believe that disclosure is necessary to comply with a current judicial proceeding, or a court order or legal process served on us. In the event Pick goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ your information will, in most instances, be part of the assets transferred.

Storing your information

Your information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). Pick will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on secure server space.
Unfortunately, the transmission of information (in particular, via the internet) is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of data transmitted either through the Website or by post, email or phone. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

If we become aware of any unauthorised access to data submitted to us, we will contact the Information Commissioner’s Office and the individuals affected in accordance with the General Data Protection Rules.

Links

The Website contains links to other sites. Please be aware that Pick is not responsible for the privacy practices or content of such other sites and you should read the terms and conditions, privacy policy and cookies policy before utilising such other sites.

If you believe that a site linked to from Pick contains improper content or is misleading in content or service, please report the URL containing the link and the URL of the link itself to our admin team.

Account registration and fulfilment of preferences

In order to provide a personalised experience on the Website, we store and process information related to each member’s account (‘Account Data’).

The Account Data includes any email address and any postcode that the member has submitted to the Website. We also record the notifications preferences of each member and their individual answers to our in-house surveys on the survey draw. There are also optional settings for features on the Website such as the leaderboards, as well as advertising preferences. All of these settings can be controlled through your account page.

The Account Data also includes how each member was referred to us (e.g. whether they conducted a Google search, clicked on an advert for Pick or were referred by an existing member or acquisition partner). This referral information will sometimes come through third parties and is used to calculate rewards for others members as well as fulfil contractual obligations we have towards third parties including acquisition partners.

We also record the the registration time and date and the internet protocol address in use by the member at the time they registered. This is recorded to demonstrate a members eligibility for the draws and assist in preventing fraudulent claims.

We use the Account Data to customise the offers and advertisements a member may see on the Website or in notifications. This process does not involve sharing the Account Data with third parties.

Administration of the draws

The Website runs multiple free-to-play prize draws (‘Draws’). In order to effectively administrate the Draws, we record all results including the email addresses and postcodes of any potential winners as well as ineligible claimants registered to the site at the time of each draw. We also record the details for each prize claim, including the internet protocol address of every member making a claim. This collectively is the Draws Data and is recorded separately from the Account Data.

The Draws Data will be safely stored on the Website, securely copied to the Website’s internal email system and copied to our external client relationship manager, which is further detailed below.

The result of the Draws is determined by selecting the emojiname of a randomly chosen member. The emojiname is then displayed publicly on the Website with the potential prize pot and the number of potential claimants and number of successful claims. If you consider your emojiname to be personally identifiable information when viewed on its own, please register or amend your emojiname to an alternative, or withdraw from the Website. By sharing your emojiname with us, you consent for us to display it as a result of the Draws.

The records of the Draws will be kept indefinitely to provide a history of all previous Draws. This history is used internally for record keeping and available publicly as a searchable record of the Draws. The winning postcode is available as part of this public history, as is the amount won (including any bonus accrued by the winner) but no other Account Data (such as the name or email address of the winner) is provided.

Email addresses recorded as part of the Draws Data will only be used to help process a successful claim or request feedback from winners of the Draws. This may be done through our external client relationship manager or require the use of a third party payment portal, both detailed below.

Affiliate networks

We work alongside affiliate networks to record when a member has completed an offer. These records are used to provide rewards to our members in addition to helping us track the performance of the offer. We also use the records to prevent the member claiming multiple rewards and to display the offers completed by the member on their account page.

In order to correctly record when a member has completed an offer we share a unique identifier with the affiliate network, which they return back to us when the offer has been completed. This information is most commonly returned to us through a post-back or through a tracking pixel using the details of the offer and a unique identifier. This process is carried out securely over HTTP over TLS (HTTPS).

The unique identifier used in this process is most likely to be the member’s person id, which is a number assigned to them upon registration. Where this is not possible the unique identifier may also take the form of an irreversibly obfuscated hash of the member’s email address. To generate the hash an email address is combined with a secret passphrase and put through the SHA-256 cryptographically secure hash algorithm, which was developed by the United States National Security Agency. The secret passphrase is random and unique for each affiliate network. The hashing is a one-way process that cannot be reversed and requires the recipient to already be in possession of the email address and secret passphrase to verify the hash.

Some offers require a voucher code or reference in order to be eligible for the offer. Where possible we automatically share this with our affiliate networks and/or other offer partners to ensure the offer is recorded correctly and any applicable discount or favourable terms are applied for our members. Where the number of voucher codes or references are limited, this could amount to a unique identifier. As detailed above, it is possible that it could be associated with your person id but we never share your contact details or any other Account Data during this process. If you do not consent to this process, please do not take up any offer with a voucher code or reference.

Advertisements

Advertisements help fund the prizes on Pick, so we encourage all members to whitelist the Website when using any advertisement blocking software.

Pick does not share any personally identifiable information it has collected about you with its advertisers. When connecting you to third party services through the Website, including Pick’s advertisers, your browser will share information about the connection. This is likely to include details about your internet protocol address, the device you are using, your web browser as well as additional information that assists in the connection being made and the transmission of the requested content or advertisement. To limit this information or restrict access to third party cookies, please refer your web browser’s documentation.

By default the only data Pick shares with advertisers or potential advertisers will be anonymous and aggregated, in order for the advertiser or potential advertiser to better understand the general demographics of Pick’s members, measure the success of different kinds of advertisements with a view to serving more appropriate adverts. None of the data shared by Pick can be used to target a specific individual.

Pick and its advertising partners, adhere to the Interactive Advertising Bureau’s Transparency and Consent Framework. The details of which can be found at (https://advertisingconsent.eu/) (‘Consent Framework’).

The Consent Framework ensures that any advertisers on the Website are not permitted to process or store any personally identifiable information about you, including any data from third party sources, when serving you advertisements.

If you would like to see more relevant advertisements and are happy for advertisers to use third party data, including unique identifiers that may allow them to show you products or services that you have searched for or looked at on other websites, then you will need to opt-in on the account page when this option becomes available. This functionality uses the Quantcast Consent Management Platform.

Useful References:

External client relationship managers

In order to appropriately manage communication with our members, Pick utilises various third party tools that help better maintain our relationship with our members (‘CRMs’).

The CRMs record all information made available through emails to and from our support team and employees, including messages sent through the Pick contact page. This includes responses to and from any such communication.

By emailing us, responding to our emails, or contacting us through the contact page, you are consenting for these details to be stored within the CRMs indefinitely, for the purposes of record keeping and processed in order to assist with your enquiries or improve how we manage relationships with our members.

The CRMs may contact you, but only on our behalf, examples of which are when we reply to your enquires, set up an automated response, or request feedback on how helpful our responses have been.

Payment portals

Pick is completely free and does not receive payments from its members. Payment portals, such as Paypal, are used to facilitate the payment of prizes or rewards. All payment portals will require some unique personally identifiable information, such as an email address or bank account number, in order to get the payment to the appropriate recipient.

By making a claim or supplying us with these details, you consent for us to use them in order to make such payments and to store them indefinitely as a record of the prize and related payment.

Email verification

When joining Pick or updating your contact details, we send an email to your email address to verify that the address is correct and active.

We also receive information from a third party that provides automated verification of your email address and determines whether the email address is active, disposable or if it is a role address (a generic address such as sales@ or admin@).

The third party does not contact you or store any of your personal information in this process. The verification process is conducted through your email service provider.

Social media sharing

On most pages the Website has buttons that allow you to share its content on social media sites. Please do not use this service if you do not agree with the terms and conditions or privacy policies (or equivalents) of the social media sites you are sharing to.

Pick reserves the right to collect information you publicly share to social media sites for republication. Where possible Pick will republish this information through the services provided through the social media site. This will allow you to control the shared information through your social media site account.

We also may collect and store any content you make available through the public comments on the Facebook commenting system.

Notifications

When registering an account with Pick or changing the email registered on your account, we will send you an email asking you to verify that the email address is real. We will also send you an email when you initially complete this verification process, confirming your participation in the Draws.

We will also send you emails in response to any enquiries you send to us, or as part of processing prizes or payments or otherwise administering claims.

We may also email you if there are changes to our terms and conditions, this privacy policy or our cookies policy, that are likely to effect the majority of our members.

We will also email you after an extended period of your account being dormant, giving you an opportunity to unsubscribe from future notifications or delete your account with us. Removing your account helps protect your data.

You will also have the option to receive the following emails from us:

Daily reminders

The daily reminder emails are there to help ensure you never miss out on a prize. Pick will send you one email a day to remind you to check the Website for the new results. The daily reminder emails also include daily offers (see below for details).

Newsletter and important updates

The newsletter and important updates emails will contain general information about Pick, the Website and its content. Examples of the features we regularly include are luckiest regions, interviews with the Pick team and messages from recent winners. We expect to send one newsletter a month. Examples of important updates will include announcements of new features on the Website, such as new Draws or other competitions run by Pick.

Deactivation emails

Deactivation emails are sent to warn users before they become ineligible to claim prizes in the Draws. They do not contain any third party marketing and are sent on a weekly basis.

Messages from our trusted partners

We do not currently have any trusted partners directly emailing our members.

If you are happy to receive emails direct from our trusted partners, you can register your interest by consenting to the relevant opt-in on the account page. We will then email you or inform you through the Website when a trusted partner has requested to get in touch with you directly. This request can be accepted or declined. This request will also detail any general demographic information that the trusted partner would like to receive about you and why.

By accepting the request, you consent for us to share your email address and any demographic information outlined in the request with the designated trusted partner. No information will be shared should you choose to decline the request.

Offers in our emails

Pick will take reasonable care to only include offers in our emails that are in-keeping with the tone and content of the Website. The offers will be in the following areas of interest:

  • Baby
  • Beauty
  • Entertainment
  • Fashion
  • Finance
  • Food & Drink
  • Health & Fitness
  • Home & Garden
  • Kids
  • Learning
  • Pets
  • Sports & Outdoors
  • Technology
  • Travel
Tracking our emails

In order to better manage the emails we send to you, we collect data to see which emails to our members have been delivered, rejected, marked as spam/junk, opened and/or clicked on. To reduce the likelihood of Pick sending unwanted emails, we also work with third party mail providers that support feedback loops. Feedback loops let us know when you’ve clicked on the unsubscribe link or have marked us as junk or spam in an email application, so that we can automatically unsubscribe you and prevent you from receiving further emails.

Contact numbers, phone calls and SMS

We do not collect landline phone numbers or mobile phone numbers from our members. We may store contact numbers you have sent to us as part of correspondence, but we will not contact you unless you have specifically requested it.

Surveys

The Website uses surveys to help us better understand our members and help generate revenue to pay for the prizes. All surveys are optional. By taking part in a survey you agree for your data to be used as detailed below for each of the survey tools use across the site.

Pick survey tool

The Pick survey tool is used to collect surveys on behalf of the Website. These are referred to as ‘In-house surveys’. To confirm a survey is an in-house survey, click on the ‘about your data’ link above the survey. If this opens a notice that confirms ‘Your data is being gathered by Pick’ the survey responses given are available for use by the Website only.

If the Pick survey tool is collecting responses on behalf of third parties, the ‘about your data’ notice will default to be open without the need for you to click on the ‘about your data’ link. The notice will confirm who the data is being collected on behalf of, how the data will be used and link to the relevant privacy policy. The Website will store and be able to process this data in the same way as In-house surveys.

The Website will also pass the data collected in the responses to the third party stated in the ‘about your data’ notice, but will not share any Account Data with the third party unless it forms part of the freely given survey response.

The Website uses the Pick survey tool responses to customise the offers and adverts seen by members on the Website and in Notifications.

Any answers you supply to us can be viewed, updated, and deleted on your account page.

Where responses have been collected and shared to a third party, the account page will show a link the third party’s privacy policy to help the member view, correct or delete their responses with the third party.

Please note this facility is only available where personally identifiable data (such as an email address) or a unique identifier (such as a user id) has been shared with the third party. Anonymous and aggregated statistics cannot be associated with an account.

Members are free to skip surveys they do not wish to answer. Skipping will reveal the survey draw result.

Google Consumer Surveys

The Google Consumer Survey tool (‘GCS’) is used to collect survey responses to enable Google to provide aggregated data to the third party Google are collecting responses for.

In contrast to the other survey tools, the GCS tool will be branded with Google’s name and/or trademark. It also links to further information about the survey and a copy of the relevant privacy policy.

The Website will never receive a copy of the individual responses given through the GCS tool. The Website will receive aggregated and anonymous data for surveys it is conducting through the GCS tool.

Pick is not a data controller or data processor of the information a member provides to the GCS tool. Please read through the links to further information and privacy policy supplied on the GCS tool survey before submitting any responses.

Members are free to ask for a different question or skip this process by clicking on the links provided. Skipping will show the survey draw result.

Pollfish

Pollfish is a third party online survey platform allowing other third parties to collect responses to surveys.

In contrast to the other survey tools, the Pollfish surveys shown on the Website will state they are from Pollfish and members will be asked to ‘take part now’ before being shown the content of the Pollfish survey.

The Website will never receive a copy of the individual responses given through the Pollfish survey tool.

The Website will receive aggregated and anonymous data for surveys it is conducting through Pollfish. The Website will also receive a confirmation from Pollfish when a Pollfish survey has been completed or the responding member has been screened out. This confirmation is used to provide a reward to the member and does not contain any details of the survey response.

Pick is not a data controller or data processor of the information a member provides to the Pollfish survey tool. Please do not submit responses to Pollfish unless you agree to its terms and conditions (including privacy policy) available at (https://www.pollfish.com/terms/respondent).

Members can opt-out of Pollfish surveys by following the instructions at (https://www.pollfish.com/respondent/opt-out).

Please also carefully consider the following information Pollfish have requested we incorporate into this Privacy Policy:

Pollfish is a third party on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones and website owners in order to have access to users of such applications/websites and address survey questionnaires to them.

This website uses and enables Pollfish cookies. When a user connects to this website, Pollfish detects whether the user is eligible for a survey. Data collected by Pollfish will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users.

For a full list of data received by Pollfish through this website, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. By using this website you accept this privacy policy document and you hereby give your explicit consent for the placement of a Pollfish cookie in your system and the processing by Pollfish of the aforementioned data.

Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website or by disabling “third party cookies” from your browser’s settings. The prizes on offer through Pollfish are administered solely by Pollfish and are

Apple, Google and Amazon are not a sponsor nor are involved in any way in the Pollfish contest/draw. No Apple products are being used as prizes.

Third party tracking

The Website shares limited information with third parties, including search engines, social media websites, affiliate networks and acquisition partners to help monitor traffic to the Website and understand where our visitors are coming from. This information is typically used to measure the success of different keywords in search engines, monitor the advertisement of our own services on other websites or reward affiliates and acquisition partners making referrals to the Website.

The information shared is limited to the details of the keywords or advertisement and may include the use of a referral id and/or temporary unique identifier. It will also include the information required to make a connection, including your internet protocol address at the time the connection is made as well as details about your device and browser.

The third party tracking services will share aggregated and anonymous data with us, to help us better understand our users and measure success. In the case of Google Analytics, this includes general demographic data.

  • Google Analytics
  • Google Ad Services
  • Twitter
  • Facebook
  • Bing
  • Tradedoubler

You can opt-out of Google Analytics tracking by installing the opt-out tool available at:
https://tools.google.com/dlpage/gaoptout?hl=en-GB

Please note this will opt-out of Google Analytics for all websites you visit for as long as the tool is active.

Changes

Pick will occasionally update this Privacy Policy to reflect company and customer feedback. Pick encourages you to periodically review this Privacy Policy to be informed of any changes to how we deal with your information. To help you in doing so, the version and date of this policy are stated below.

This Policy has been in force since:
Friday, 25th May, 2018

Policy Version:
2.0

Your rights and our details

You have the right to access and update the personal data we hold about you and the right to understand how it is being processed, used and shared.

You also have the right to delete personally identifiable data we hold about you, except where previously outlined in this Policy or as required by law.

You can exercise these rights at any time by visiting the account page or by sending us details of your subject access request, including your registered postcode and email address, to our Data Protection Officer.

We aim to respond to subject access requests within 28 days, starting the next working day (Monday through Friday, excluding bank holidays) following receipt of the request.

If you are unhappy with anything related to the personal data you have shared with Pick, you have the right to make a complaint to our Data Protection Officer, or the Information Commissioner’s Office (https://ico.org.uk/concerns/).

Our Data Protection Officer can be contacted through email or post as below.

Email address:
dpo@pickmypostcode.com

Postal address:
Data Protection Officer
Pick Media Ltd
Floor 3, C/O Filmlondon
The Arts Building
Morris Place
London
England N4 3JG

The admin team are happy to help, so if you have questions about this Policy please read through the Frequently Asked Questions or email admin@freemojilottery.com before contacting the Data Protection Officer.

Pick Media Ltd trading as Freemoji Lottery and freemojilottery.com, registered in England, company number 06377138.

Registered with the Information Commissioner’s Office as a Data Controller, registration number Z2763081.