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Unity Website Privacy Notice

Last updated: September 2026

Introduction

Unity Lottery is a brand operated by Sterling Management Centre Limited ("Sterling", "we", "us" or "our").

Sterling provides lottery administration services to charities and other good causes throughout Great Britain.

This Privacy Notice explains how personal information is collected, used, stored and protected through the Unity Lottery website and platform.

Depending on how you interact with Unity Lottery, Sterling may act as either a:

  • Data Controller, where you contact us directly, enquire about our services or otherwise interact with us as a prospective client, supplier or business contact; or
  • Data Processor, where you provide personal information in connection with a lottery we manage on behalf of one of our charity or good cause clients.

Where you participate in a lottery or register to support a charity through the Unity platform, the relevant charity or good cause is responsible for deciding how your personal information is used and remains the Data Controller. Sterling processes that information on their behalf and in accordance with their instructions.

Who We Are

Sterling Management Centre Limited is a Gambling Commission licensed External Lottery Manager.

Contact Details

Unity Lottery

Suite 8, 2nd Floor, Furness Gate

Furness Business ParkPeter Green WayBarrow-in-FurnessCumbriaLA14 2PE

Email: [email protected]

Telephone: 0370 050 9240

For privacy or data protection enquiries:

[email protected]

Sterling Management Centre Limited is registered with the Information Commissioner's Office (ICO) under registration number Z1232338.

Information We Collect

The information we collect depends on how you interact with the Unity Lottery website and services, and whether Sterling Management Centre Limited is acting as a Data Controller or a Data Processor.

Where Sterling Acts as Data Controller

Sterling acts as a Data Controller when you:

  • Contact us with an enquiry
  • Request information about our services
  • Register interest in becoming a client
  • Engage with us as a supplier or business contact
  • Otherwise interact with us directly in relation to the Unity Lottery platform

In these circumstances, we may collect:

  • Name
  • Job title
  • Organisation name
  • Postal address
  • Email address
  • Telephone number
  • Information contained within enquiries or correspondence
  • Information submitted through website forms

Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including:

  • IP address
  • Browser type and version
  • Device information
  • Operating system
  • Website usage information
  • Date and time of visits
  • Pages viewed

Cookies

Our website uses cookies and similar technologies to help the website function, improve performance, understand how visitors use the site and enhance user experience. Further information can be found in our Cookie Notice.

Where Sterling Acts as Data Processor on Behalf of a Charity or Good Cause

Sterling acts as a Data Processor when you interact with a lottery, raffle or fundraising activity operated through the Unity Lottery platform on behalf of one of our charity or good cause clients. In these circumstances, the relevant charity or good cause remains the Data Controller and determines how your personal information is used.

Depending on the services provided, Sterling may process:

  • Name & surname
  • Postal address
  • Date of birth
  • Email address
  • Telephone number
  • Lottery participation information
  • Payment & bank information
  • Communication preferences
  • Records relating to customer service enquiries

This information is processed solely for the purpose of administering lottery participation and supporting the services provided on behalf of the relevant charity or good cause.

Age Verification

Lottery participation is restricted by law. To comply with legal and regulatory requirements, Sterling may process date of birth and other identifying information to verify an individual's eligibility to participate in a lottery.

Payments

Where lottery participation involves payment, Sterling may process payment-related information on behalf of the relevant charity or good cause. Payment methods supported through the Unity platform may include:

  • Direct Debit
  • Open Banking services
  • Debit card payments

Depending on the payment method selected, Sterling may process bank account details, payment transaction information and payment status information. Debit card details are not stored by Sterling.

Where bank account details are processed, additional technical and organisational controls are applied to protect that information and restrict access to authorised personnel only.

Our Lawful Bases for Processing

Where Sterling acts as a Data Controller, we rely on one or more of the following lawful bases under UK data protection law.

Legitimate Interests

We process personal information where necessary for our legitimate interests, including:

  • Responding to enquiries
  • Developing business relationships
  • Managing client and supplier relationships
  • Improving our services
  • Maintaining website and information security
  • Protecting our legal interests

Where we rely on legitimate interests, we carefully consider and balance our interests against the rights and freedoms of individuals.

Contract

We process information where necessary to enter into or perform a contract with you or your organisation.

Legal Obligation

We process information where necessary to comply with applicable legal and regulatory requirements, including obligations relating to:

  • Data protection legislation
  • Gambling legislation and licence conditions
  • Tax and financial reporting requirements
  • Regulatory or law enforcement requests

Consent

Where consent is required by law, such as for certain marketing communications or non-essential cookies, we will obtain consent and you may withdraw it at any time.

Marketing Communications

Where permitted by law, we may contact prospective and existing clients regarding products and services that may be relevant to their organisation. You can stop receiving marketing communications at any time by:

We will always respect your communication preferences.

Who We Share Information With

Depending on the circumstances, personal information may be shared with:

  • The relevant charity or good cause
  • Payment service providers
  • Professional advisers, including solicitors, auditors and accountants
  • Information technology and cloud service providers
  • Website hosting and support providers
  • Regulatory authorities
  • Law enforcement agencies where required by law

Where third parties process personal information on our behalf, we require them to maintain appropriate security measures and only process information in accordance with our instructions and contractual obligations.

We do not sell personal information to third parties.

International Transfers

Where personal information is transferred outside the United Kingdom, we will ensure that appropriate safeguards are in place in accordance with applicable data protection legislation.

How Long We Keep Information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and to meet our legal, regulatory, contractual and operational requirements. When determining how long information should be retained, we consider factors including:

  • The purpose for which the information was collected
  • The nature and sensitivity of the information
  • Applicable legal, regulatory and contractual requirements
  • Limitation periods for legal claims
  • Ongoing business and operational requirements
  • Information security, audit and governance requirements

Where personal information is no longer required, we will securely delete, anonymise or otherwise dispose of it in accordance with our information governance and retention procedures.

Where Sterling acts as a Data Processor, retention periods are determined by the relevant charity or good cause acting as Data Controller.

How We Protect Information

We take information security seriously and maintain appropriate technical and organisational measures designed to protect personal information from unauthorised access, disclosure, alteration, loss or destruction.

These measures include:

  • Access controls and role-based permissions
  • Encryption where appropriate
  • Security monitoring and logging
  • Staff training and awareness
  • Supplier security requirements
  • Information security policies and procedures
  • Incident management processes
  • Additional safeguards for financial and payment-related information

Sterling maintains an Information Security Management System aligned with ISO/IEC 27001.

Your Rights

Where Sterling acts as Data Controller, you may have the right to:

  • Request access to your personal information
  • Request correction of inaccurate or incomplete information
  • Request deletion of personal information in certain circumstances
  • Request restriction of processing in certain circumstances
  • Object to processing in certain circumstances
  • Request transfer of your personal information where applicable
  • Withdraw consent where processing is based on consent

To exercise any of these rights, please contact: [email protected]

Where Sterling acts as a Data Processor on behalf of a charity or good cause, requests relating to your personal information should normally be directed to the relevant charity or good cause as the Data Controller.

Complaints

If you have any concerns about how we handle your personal information, please contact us first so that we can try to resolve the matter.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO). Further information can be found on the ICO website.

Third-Party Websites

Our website may contain links to third-party websites, including websites operated by charities and good causes. We are not responsible for the privacy practices, content or security of those websites. We encourage you to review the privacy notices of any websites you visit.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in legal requirements, regulatory guidance, technology or our business operations.
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