1. We protect your data
This document explains
– What personal data we may collect about you in connection with: (i) providing you with our prize offers through prize draws, competitions and contests; (ii) your online interaction with us (including via our website(s), email or social media channels); (iii) our in-person interactions with you and (iv) any other related channels (collectively, the “Channels”);
– How we collect, store, disclose, transfer, protect and otherwise process that information and for what purposes; and
– Other important information, such as the lawful bases by which we process your personal data, how long we might retain your personal data, and the rights you have in relation to personal data we hold about you.
This policy is intended to be communicated to you in a concise, transparent and easily accessible way, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email email@example.com and we will respond as soon as possible.
2. The personal data we process
We collect personal data about you through the Channels when you:
– Access and use our website (including by way of “cookies”);
– Enter a prize draw, competition, contest;
– Subscribe to a special event or our mailing list;
– Request technical support or other care support;
– Participate in polls, surveys and questionnaires;
– Contact us (whether in writing, by email, by telephone or otherwise);
– Otherwise interact with us through the Channels.
The type of personal data we process may include:
– Your full name, postal address, country, email address, telephone number and other information provided by you;
– and you should not provide us with any such information through any of the Channels.
3. The purposes for which we process your personal data
We use the personal data for the purposes of:
– Confirmation email and prize draw, competition and email up-dates;
– Contacting you if you are a winner;
– Personalising content on the Channels;
– Sending you promotional and marketing materials, notifications, updates and exclusive news provided you have opted-in to receiving them;
– Responding to any correspondence from you including enquiries, comments, complaints and technical problems;
– Administering any services, questionnaires, contests, or special events which you may have subscribed for;
– Carrying out our business activities in circumstances where you ought reasonably to have an expectation that we will process your personal data for a particular purpose.
We may process your personal data for the purposes set out in above ourselves or in conjunction with our third-party service providers.
4. The lawful bases by which we process your personal data
Other lawful grounds
We may process your personal data in any circumstances where such processing is necessary:
– In order to perform any agreement between us (for example for us to fulfil a prize to you as prize winner);
– To comply with any applicable law or regulation; or
– For the purposes of the legitimate interests pursued by us or third-parties including other general commercial interests and our internal administrative purposes.
5. What if you refuse to provide us with any personal data?
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with your prize). In this case, we may have to cancel the award of the prize to you and choose another winner, but we will notify you if this is the case.
We may lawfully obtain information from third-parties or public sources and we may process that information where it is an essential component of the prize we offer you.
6. Sharing information with affiliates and third-parties
We will not share any of your personal data with third-parties except as set out here or otherwise notified to you or agreed between you and us from time to time.
We may share personal data with our group companies and partnered companies (together, “Affiliates”) in order to provide our goods and services to you and for the other purposes outlined in this policy.
From time to time, we will also need to share personal data with the following types of third-party service providers who we engage to provide services which facilitate our business and who may need to process your personal data to the extent necessary to provide those services:
– email service providers;
– web analytics services such as Google analytics;
– professional service providers, such as marketing agencies, advertising partners and website hosts;
– logistics companies;
– address verification services;
– integration platform providers;
– other third-parties approved by you, such as social media sites which you link to your account (if and when we offer that feature) or share content via or third-parties who administer any competitions or surveys on our behalf which you voluntarily partake in; and
We seek to ensure that any third-party engaged by us who processes your personal data has policies and procedures in place to ensure compliance with the Data Protection Legislation. Unless otherwise disclosed to you from time to time, we will remain the data controller in respect of your personal data notwithstanding that third-parties may be engaged as data processors.
We may share your personal information with third-parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal enquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws, or any usage guidelines for specific products or services, or threaten the rights, property, or safety of us, our users, or others).
7. Your rights as a data subject
Subject to any conditions or requirements set out in the relevant Data Protection Legislation, you may have some or all of the following rights in relation to the personal data we hold about you:
– The right to request a copy of your personal data held by us;
– The right to correct any inaccurate or incomplete personal data held by us. You can update and amend your personal data by emailing us at firstname.lastname@example.org;
– The right to request that we erase the personal data we hold about you;
– The right to request that we restrict the processing of your data;
– The right to object to certain types of processing of your personal data by us; and
– The right to complain.
8. Storage and retention of your personal data
As a minimum, we will store your data for as long as is reasonably necessary to provide you with the prize and, as a maximum, for a period of twelve months from the end of the promotional period of the relevant prize draw, competition, contest in which you are a winner.
If you tell us that you would like to delete your personal data, we will take steps to delete all the personal data we hold about you once it is no longer necessary for us to hold it (e.g. to fulfil any prize, resolve disputes, or as is permitted by applicable law or regulation).
For as long as we do store your data, we will follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. We have security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal data collected by us is stored in secure operating environments that are not available to the public. Despite our efforts to keep your personal data secure, no system can be 100% reliable. We cannot be held liable for any loss you may suffer if a third-party procures unauthorised access to any data you provide through the Channels. We will notify you as soon as possible if we have reason to believe that there has been a personal data breach by us (or your personal data held by us).
9. Links to Third-Parties
If you access such third-party websites, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies or levels of privacy compliance of any website operated by any third-party.
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To find out more about cookies including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org/manage-cookies
11. Questions and complaints
You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner’s Office (ICO) (www.ico.org.uk).