Privacy Policy
How your personal data is used in connection with this promotion.
1. Who We Are
[PROMOTER NAME PLACEHOLDER] (“we”, “us”, “our”) is the data controller for personal data collected through this promotion. Registered address: [PROMOTER ADDRESS PLACEHOLDER].
This promotion is administered on our behalf by TBK Agency Ltd, who act as a data processor.
2. What Data We Collect
When you enter this promotion, we collect:
- Name — first name and last name as provided on entry.
- Email address — used to notify you if you win and for marketing if you consent.
- IP address — collected automatically to prevent fraudulent or duplicate entries.
- Device identifier — a browser-based fingerprint used to detect duplicate entries from the same device. No tracking cookies are used.
- Marketing preference — whether you have opted in to receive marketing communications.
3. Why We Collect It
- To administer the promotion and select winners fairly.
- To contact winners and arrange prize fulfilment.
- To prevent fraud and duplicate entries.
- To send marketing communications if you have opted in to receive them.
4. Legal Basis for Processing
- Contract performance — processing your entry and fulfilling a prize is necessary to perform the contract entered into when you submit your entry.
- Legitimate interest — fraud prevention and ensuring the integrity of the draw.
- Consent — if you have opted in to marketing communications, we process your email on the basis of your consent. You can withdraw consent at any time.
5. How Long We Keep Your Data
Entry data is retained for [X MONTHS PLACEHOLDER] months after the promotion closes, after which it will be securely deleted. Winner data may be retained for longer where required by law or for audit purposes.
6. Who We Share It With
Your data may be shared with:
- TBK Agency Ltd — who administer the promotion on our behalf.
- [FULFILMENT PARTNER NAME PLACEHOLDER] — solely to arrange delivery of prizes to winners.
We do not sell, rent, or otherwise share your personal data with third parties for their own marketing purposes.
7. Your Rights
Under UK GDPR you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate data.
- Request erasure of your data (subject to any legal obligations to retain it).
- Object to processing based on legitimate interests.
- Withdraw consent to marketing at any time.
To exercise any of these rights, contact us at: [DATA CONTROLLER CONTACT EMAIL PLACEHOLDER]. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk.
8. Cookies and Session Storage
This website does not use cookies for tracking or advertising purposes. We use browser sessionStorage solely to pass your entry confirmation between pages within the promotion flow. This data is cleared immediately after being read and is never persisted beyond your browser session.
9. Contact
If you have any questions about how we use your personal data, please contact:
[DATA CONTROLLER NAME PLACEHOLDER]
[DATA CONTROLLER ADDRESS PLACEHOLDER]
Email: [DATA CONTROLLER EMAIL PLACEHOLDER]