SeaMoor Lotto Policies

West Devon Borough Council (in association with South Hams District Council) are committed to complying with the Gambling Act 2005, The Gambling Commissions LCCP, Lotteries Council Code of Conduct and The CAP and BCAP code.

1. West Devon Borough Council utilise the services of Gatherwell ltd who are an External lottery management company ensuring that the lottery is delivered on a financially sound basis as:

• The financial structure of the lottery ensures that revenues are received prior to the running of any draw.
• Each draw is self-funded in terms of the liabilities that then arise (prizes, charitable donations etc)
• No players' tickets will be included in the draw unless cleared funds have been secured.
• The prize fund and charity donations are calculated on a % basis of the revenue pot therefore ensuring sufficient funds will always be in place.

2. All terms and conditions are available for participants on the website of Seamoor Lottery, including the main www.seamoorlotto.co.uk

• As part of the sign-up process for new participants, new participants are asked to agree acceptance of the terms and conditions at the time of signing up. New accounts cannot be created unless the terms and conditions are accepted.
• Participants will be advised of changes to the terms and conditions via pop-ups on the website. In exceptional circumstances, all participants can be emailed a link to advise them of the new terms and conditions.

3. Our terms and conditions detail the complaints procedure should participants need to raise any issues or concern, both internally at West Devon Borough Council and externally though the use of an independent arbiter should resolution not be found.



4. No loyalty or reward schemes are being offered.

5. West Devon Borough Council employs the services of Gatherwell Ltd to act the External Lottery Manager. Section 257 of the Gambling act 2005 highlights that "A person acts as an external lottery manager for the purposes of this Act if he makes arrangements for a lottery on behalf of a society or authority of which he is not

(a) a member,

(b) an officer, or

(c) an employee under a contract of employment.

As such Gatherwell ask its board and staff to declare any conflict of interest in any potential target clients, in addition to the specific requirement to comply with the law as stated above for existing clients.

6. Gatherwell Ltd holds responsibility for ensuring that all technical solutions remain within scope of the law.

• These include testing procedures for both existing, upgraded and new software propositions
• Ensuring that all servers are located in the UK
• Software protocols and administrator access is limited to core personnel
• All Contractors and Third Party suppliers are advised of our standards before they are allowed to deliver technical support. Access is limited to the scope of their work and monitored and logged accordingly.

7. Gatherwell Ltd's employees and their immediate families and household members and employees and their immediate families and household members of Gatherwell's parent company (Jumbo Interactive Limited) and its associated subsidiaries are prohibited from purchasing lottery tickets and shall be ineligible for any prize.