- the types of information we collect and how we collect it;
- the ways in which we use, share and protect that information;
- the choices you have in controlling the collection of your information; and
- your ability to access and update your information.
Some Important Vocabulary
Whenever we reference “this site,” “our site” or “the site,” we mean the CT Lottery website found at www.ctlottery.org and all related sites optimized for mobile devices. When we talk about “authorized features and apps,” we’re referring to elements of our social media presence viewable from Facebook, Twitter, YouTube, LinkedIn, or any of the many other available external third-party controlled and operated social media platforms, as well as mobile or other apps we’ve created and distributed to let our fans and followers view our site or otherwise interact with our content. When we use the term “services,” we mean the sites and authorized features and apps collectively. Last, but definitely not least, when we refer to “personal information,” we mean information that can be used to identify you or that can be easily linked to you. So, a fairly comprehensive list of “personal information” would include such things as your name, address, telephone number, fax number, e-mail address, social security number, and date of birth. In contrast, a domain name or an internet protocol (“IP”) address or type of browser used to access the site is not considered personal information.
We’re a Bit Different: Records Retention and the Freedom of Information Act
Our services are not like others you may be used to accessing. We say that because we are what is known as a “quasi-public” agency. In other words, we are, in certain ways, more like a governmental agency than a private company. One of the ways we’re more like the government is that we retain the information collected through our services in accordance with the records retention and disposition requirements of Connecticut law. Another way we’re more like the government is that the Freedom of Information Act, also known as “FOIA,” applies to us. What this means to you as a visitor or user is that no matter how committed we are to maintaining the privacy of the information we collect, we cannot ensure its absolute privacy. Under FOIA, any person can request information collected by a public agency (or, as in our case, a quasi-public agency), and that information must be disclosed unless an exemption applies. If you want to know more about FOIA in Connecticut, then this is a good place to start: http://www.ct.gov/foi/site/default.asp
This policy is intended to provide you with the information you need to make an informed choice about your use of our services, as well as to make a decision about whether to share personal information with us through the services. You should consider the implications of FOIA as you make that decision. You should also be aware that, although we consider the information you provide to us to be trade secret information, we will use or disclose personal information when compelled to do so by legal obligations other than FOIA (e.g. a valid subpoena or court order), or based on our good-faith belief that the use and disclosure of personal information is necessary to enforce and protect our rights and interests or the rights and interests of others or to ensure that the lottery continues to be operated with integrity and for the public good. We do not sell, rent, or trade personal information with third parties.
Please be a Grown Up: User Age Requirements and Children’s Privacy
Connecticut law prohibits anyone under the age of 18 from participating in the games and programs we offer. So, purchasers of our products and users of our services, including registration for second-chance drawings and entry in our giveaways, must be at least 18 years of age. We take those age-related legal requirements very seriously and, consistent with them, do not intend for the services to be used by individuals under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from individuals under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information through the services, then we will delete that information and will not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the internet.
Nothing Personal: Automatically Collected Information
When you visit or use our services or interact with us, basic information is passively collected through various means, including through your web browser via use of tracking technologies such as “cookies”, "web beacons," "clear gifs," and the like, that utilize, among other means, simple text files sent from our servers to your device. The information we collect through these means is not personal information and does not individually identify you. It includes things like:
- the domain name and IP address from which you accessed our site.
- the type of browser and operating system you use.
- the date and time and length of your visit.
- the specific page visited, graphics viewed and any documents downloaded.
- the specific links to third party content you accessed from our services.
- the specific links from other sites you used to access our site.
Mobile devices are the one possible exception to the rule that our passive, automatic-collection activities exclude personal information. We say that because, if you access our services from a hand-held or other mobile phone or device, then the mobile services provider may transmit to us uniquely identifiable mobile device information that allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone service providers also operate systems that pinpoint the physical location of devices, and we may receive this information as well. If you downloaded our mobile app, then the mobile device on which you use it may use GPS or other similar technology to determine your location for a variety of purposes, including displaying that location on a map and showing you nearby CT Lottery retailers or game information we think you might find relevant. We will not share your current location. If you do not want us to use your location for the purposes just described, then you should turn off the location services on your mobile device whenever you use our mobile app.
We may use both automatically collected non-personal information and mobile device information to compile generic reports about our services (such as popular pages on our site); to see how our followers, fans, and players are accessing our services; and for advertising and marketing purposes. We then use that data to administer the services, make your activities more convenient and efficient, and enhance the functionality of our services (such as by remembering certain of your information, thereby saving you time).
Now it’s Personal: Voluntarily Submitted Information
If you participate in certain activities through our services, then you may need to provide us with information about yourself. For example, if you choose to send us an e-mail, enter a second-chance drawing or promotion, fill out an on-line form (such as a request to have one of our employees speak to your group, or a request for more information about becoming a retailer), or participate in a player survey, then you are voluntarily providing personal information to us. In doing so, you are giving us your consent to collect, retain, use, and disclose that information in the ways we describe in this policy.
We may use voluntarily provided personal information (such as e-mail addresses, the content of e-mail, text messages, and phone numbers) to communicate directly with you on a one-to-one basis; to operate a promotion, giveaway, or a second-chance drawing, and to contact the winners; to verify information, such as age eligibility; to customize our promotional and giveaway pages with more relevant news and information; for our internal marketing and product development purposes; and for any other lawful purpose.
We may also use personal information as otherwise described to you at the point of collection, pursuant to your consent. We do not sell, rent, or trade personal information with third parties. We consider the information you provide to us to be trade secret information. If you don’t want us to collect your personal information, then don’t provide it! This means you shouldn’t participate in the activities offered through our services that request or require it. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the services, but it will not affect your ability to access important lottery information.
Note that some authorized features and apps may allow users to post or upload messages, comments, screen names, computer files, and other materials. If you choose to make personally identifiable information public through these means, then we will consider that information to be in the public domain and will not limit its disclosure in the manner described by this policy.
A Choice you can make: Opt Out
If we are using personal information you provided to receive materials from us, such as newsletters, promotions, and program announcements, via text or e-mail, and you decide you don’t want to receive such materials, then you may opt out by sending an e-mail to us with your name, e-mail address, and/or mobile phone number (as applicable) to email@example.com. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. This information remains part of our records, and may be available under FOIA even after you opt out.
Please understand that communications may not stop immediately. Additionally, if you continue to separately submit forms to us or take surveys after you opt out, then you will be voluntarily submitting your personal information through those separate means.
Do Not Track
Your web browser may offer a Do Not Track (DNT) feature allowing you to tell us you want to opt out of tracking for some purposes. At this time, our site does not specifically respond to DNT signals sent from your web browser.
Things Happen: We do what we can to ensure Information Security
We will take all reasonable security precautions to protect your personal information provided through our services. Due to the inherently open and somewhat risky nature of the Internet, however, we cannot guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction or alteration will not occur. We disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. You should also note that third party companies that help us operate and maintain both our services and our corporate technology environment (for example, a service provider that sends e-mails on our behalf) will have incidental access to your information, including your personal information, as part of the work they perform, and we cannot guarantee or be responsible for their practices.