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BACKGROUND:

Property Lotto, which is a trading name and style of Smart Competitions understands that your privacy is important to you and that you care about how your personal data is used and shared online. Property Lotto respects and values the privacy of everyone who visits this and every other website belonging to Property Lotto and/or Smart Competitions and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Property Lotto obligations and your rights under the law. Please read this Privacy Policy carefully and ensure you understand and agree to it. You will be required to read and accept this Privacy Policy when purchasing a ticket when entering online and for entries by post it will be accepted by the entrant that they have read, understood and accept the content of this Privavcy Policy. If you do not accept and agree with this Privacy Policy, you must stop using this and any associated Property lotto site(s) immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site(s). This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); a copy of which can be read on this site and

“His, Him, Her, We, Us, Our,” means Property Lotto Ltd staff and associates and its Founders Mark Walker & Howard Rose and any other business or website operated and controlled by them, whose business office address is shown on any specific website or other medium as Property Lotto Ltd - 121 Cathedral Road Cardiff CF11 9PH UNITED KINGDOM

2. Information About Mark Walker and Howard Rose

2.1 This Site and other Sites redirecting you here are owned and operated by Mark Walker and Howard Rose, whose office address is Property Lotto Ltd - 121 Cathedral Road Cardiff CF11 9PH UNITED KINGDOM

2.2 Property Lotto Data under this and the GDPR Policy is covered under Data Protection with the Information Commissioners Office. ICO Reference number is ZA320039

2.3 The Property Lotto Data Protection Officer is Mark Walker. He can be contacted by email at:
DPO@property-lotto.com by telephone on +44 (0)843 289 4643, or by post at Property Lotto Ltd - 121 Cathedral Road Cardiff CF11 9PH UNITED KINGDOM

2.4 Property Lotto is registered with PSA - The UK regulator for content, goods and services charged to a phone bill

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Property Lotto Site(s). Property Lotto Site(s) may contain links to other 3rd party websites. Please note that Property Lotto has no control over how your data is collected, stored, or used by other 3rd Party websites and Property Lotto advises you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data
have been designed to uphold:

4.1.1 The right to be informed about Our collection and use of personal data;

4.1.2 The right of access to the personal data We hold about you (see section 12);

4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us
using the details in section 14);

4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold
your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please
contact Us using the details in section 14);

4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;

4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);

4.1.7 The right to object to Us using your personal data for particular purposes; and

4.1.8 Rights with respect to automated decision making and profiling.

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details
provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also
have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local
Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Site(s), We may collect some or all of the following personal and non-personal data (please also see section 13 on Our use of Cookies and similar technologies and Our Cookie Policy):

5.1 name;

5.2 business/company name;

5.3 contact information such as email address, postal address and telephone number;

5.4 IP address;

5.5 web browser type and version;

5.6 operating system;

5.7 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.

5.8 a history of searches you have performed on Our Site.

6. How Do We Use Your Data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

6.2.1 Providing and managing your Account;

6.2.2 Providing and managing your access to Our Site(s);

6.2.3 Personalising and tailoring your experience on Our Site(s);

6.2.4 Supplying Our services to you;

6.2.5 Personalising and tailoring Our services for you, e.g. sending targeted emails relevant to you and your location
(subject to your opt-in, see Clause 6.2.7);

6.2.6 Replying to emails and telephone enquiries from you;

6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by updating your
Email Preferences on the My Account page);

6.2.8 Market research;

6.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site(s) and your
user experience.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or through social media with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 Third parties (including Facebook Ads, Facebook Pixels, Google and DoubleClick) whose content appears on Our Site(s) may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

6.6.1 Personal data provided in connection with your account or the provision of services to you will be retained until:

6.6.1.1 You ask us to cancel your account; or

6.6.1.2 Two years after the last log-in has taken place on your account and there are no active email subscriptions.

6.6.2 Personal data provided in connection with direct marketing or newsletter subscriptions will be retained as long as
your subscription remains active and your consent is considered to be valid.

6.6.3 Personal data provided during communication with our customer support team either via email or live chat
applications will be retained for two years after your most recent communication with us.

7. How and Where Do We Store Your Data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

7.2 Most of your data will be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).

7.3 Some of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site(s) and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:

7.3.1 Ensuring that any US based companies are Privacy Shield Certified and their Model Contract clauses fully meet
the requirements under the GDPR.

7.4 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site(s).

7.5 Steps We take to secure and protect your data include:

7.5.1 Using secure connections (HTTPS) when you access our Site(s).

7.5.2 Encryption of any data prior to being backed up.

7.5.3 Encryption of connections between data processing facilities.

7.5.4 Restrictions on who within our company can access your data.

8. Do We Share Your Data?

8.1 We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, service delivery, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.2 We may compile statistics about the use of Our Site(s) including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

8.3 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:

8.3.1 Putting EU Model Contracts in place.

8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of
        control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part
        of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling
        party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which
        it was originally collected by Us.

9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and
informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from
the new owner or controller.

10. How Can You Control Your Data?

In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site(s), you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving such emails from Us, which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).

11. Your Right to Withhold Information

11.1 You may access certain areas of Our Site(s) without providing any data at all. However, to use all features and
functions available on Our Site you may be required to submit or allow for the collection of certain data.

11.2 You may restrict Our use of Cookies. For more information, see section 13 and Our Cookie Policy.

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under GDPR, no fee would normally be payable and We will endeavour to provide any and all information in response to your request free of charge. Please contact Us for more details at DPO@property-lotto.com, or using the contact details below in section 14.

13. Our Use of Cookies

Our Site(s) may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site(s) and to provide and improve Our services. By using Our Site(s) you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site(s) for integration of third party content and advertising services. In addition, Our Site(s) use analytics services provided by Google Analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site(s). For more details, please refer to Our Cookie Policy.

14. Contacting Us

If you have any questions about Our Site(s) or this Privacy Policy, please contact Us by email at DPO@property-lotto.com, by telephone on +44 (0)843 289 4643, or by post at Property Lotto Ltd - 121 Cathedral Road Cardiff CF11 9PH UNITED KINGDOM. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site(s) and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site(s) following the alterations. We recommend that you check this page regularly to keep up-to-date.

Last Updated: April 2019

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