Privacy Policy

Last updated: April 2026

1. Data controller

LMH Group Ventures Ltd is the data controller for ClubDraw. For privacy questions, contact clubdraw@lmhgroupltd.com.

2. What data we collect

• Your name and email address, provided when you create an account.
• Your device push token, used to deliver draw results and account notifications.
• Your payment status (active / paused / cancelled / failed) and the last four digits of any card used.
• The lotto numbers you have chosen and the club you are entered with.
• Aggregate spend totals used to display weekly and lifetime totals back to you.
• Optional messages you send to your club admin or support team.

3. Why we collect it

We use this data only to operate the ClubDraw service: to enter you into the correct draw, take payment, notify you of results, pay out prizes, provide customer support, and meet our legal obligations as a small society lotto platform under the Gambling Act 2005.

We do not sell your data, share it with advertisers, or use it for marketing without your consent.

4. How long we keep it

We keep your account data for as long as your account is active, plus two years after you delete your account. This retention period is needed to satisfy gambling-regulatory record-keeping requirements and to handle any disputes about prize payments.

When you delete your account, we immediately anonymise your name and email, remove your push token, and hard-delete personal messages. Draw entry history is retained in anonymised form for audit purposes.

5. Your rights (UK GDPR)

• Access — you can download a JSON export of your data from inside the app at any time (Account → Privacy → Download my data).
• Rectification — you can correct your name and email in the app.
• Erasure — you can delete your account and have personal data anonymised (Account → Privacy → Delete my account).
• Portability — your data export is provided in a portable JSON format.
• Withdraw consent — you can self-exclude or cancel your subscription at any time.
• Complain — you can lodge a complaint with the UK Information Commissioner's Office at ico.org.uk.

6. Data processors

We use the following third-party processors to operate ClubDraw:

• Supabase — database hosting, authentication, and storage. EU/UK region.
• Expo — push notification delivery to your device.
• Ryft — card payment processing for member subscriptions and platform fees.

Each processor is bound by a Data Processing Agreement and processes data only on our instructions.

7. Responsible play

ClubDraw includes self-exclusion controls inside the app. If you are worried about gambling, free confidential support is available 24/7 from BeGambleAware on 0808 8020 133 or at begambleaware.org.

8. Changes to this policy

We will update this page if our practices change. Material changes will be surfaced inside the app at next sign-in. The "Last updated" date at the top will always reflect the current version.