We are Superb Giveaways, a trading name of McTaggart Thomas & Associates Limited (Registered in England & Wales No. 07156902). Our registered office is at 20 Lansdown, Stroud, Gloucestershire, GL5 1BG.
This Privacy Notice sets out the basis on which we use personal data in accordance with all applicable Data Protection Legislation. It applies to any identifiable individuals about whom we may process personal data in the course of our activities as a promoter of prize draw competitions.
We reserve the right to update this Privacy Notice from time to time. Where appropriate, we shall contact you to notify you of any material changes to the Privacy Notice. You should also refer to our website periodically so that you may access and view our updated Privacy Notice. This will ensure that you understand (i) how we are using your personal data and (ii) your legal rights around our usage of such personal data.
This Privacy Notice uses the following defined terms:
Data Protection Legislation means the Data Protection Act 2018, the retained UK version of the General Data Protection Regulation ((EU) 2016/679) and all other applicable legislation in the United Kingdom relating to data protection, together with any successor legislation.
Entrant: An individual who enters a prize draw competition which we may run from time to time.
Third-Party Services Provider means any relevant third-party business which provides services to us, including our:
- Professional advisers including accountants, tax advisors and lawyers;
- Delivery agents;
- IT services providers and software providers;
- Independent consultants and subcontractors
Website: Our website at www.superbgiveaways.com.
HOW WE OBTAIN PERSONAL DATA
We obtain personal data from a number of different sources, depending on the capacity in which you are dealing with us.
If you are an Entrant, we will obtain data directly from you if:
- You have entered a competition on our Website;
- You have submitted a postal entry for a competition;
- You have entered any other promotion which we may offer from time to time on our website or by social media.
TYPES OF INFORMATION WE HOLD
If you are an Entrant, we may collect, store and process the following types of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
- Your date of birth and country of residence;
- Information about any of our competitions which you have entered; and
- Information about how you have paid to enter our competitions, where applicable. We do not however store your card details.
- Copies of your identification and proof of address;
- Your personal bank details where we require these to make a direct payment to you;
- Your vehicle insurance details; and
- Your photograph.
HOW WE USE PERSONAL DATA
If you are an Entrant, we will use your personal data to:
- Record your entry in our competition and the outcome of such entry;
- Where applicable, contact you to notify you of a prize that you have won and make arrangements to deliver or hand over that prize to you; and
- Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.
Once you have entered a competition with us, we may use your personal data to notify you of other competitions which we are running. You may choose to opt out of these marketing messages during the checkout process on our website. You may also opt out of our marketing messages at any other time by (i) clicking the relevant link in our email message or (ii) sending an email from the relevant email account to firstname.lastname@example.org with UNSUBSCRIBE included within the subject line of your email.
OUR LAWFUL BASIS FOR PROCESSING DATA
We primarily use your personal data to perform the contract which is created when you enter a competition on our Website or via a postal entry.
In respect of any marketing activities which we carry out, we have determined that we have a legitimate business interest to process your data on the basis that the data we process is not sensitive, is not overly intrusive, frequent or unexpected and may ultimately be of benefit to you. In addition, we provide a clear, straightforward way of opting out of our marketing messages at any time.
WHERE WE PROCESS PERSONAL DATA
Your personal data is held and processed by us in the United Kingdom.
We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches. We will therefore only transfer your personal data to jurisdictions outside of the UK and EEA where:
- There is an adequacy decision in respect of such jurisdiction. This means that the European Commission and UK Government have pre-approved the data privacy regime in the relevant non-EEA country. At present, the approved jurisdictions are Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework).
- The transfer of data is subject to model contractual clauses. This means that we have a data-sharing agreement in place which complies with the requirements set out by the UK Government around international data transfers.
PARTIES WITH WHOM WE MAY SHARE DATA
If you are an Entrant, we may share your personal data for legitimate purposes with:
- Third-Party Services Providers who in some cases may use their own subcontractors and sub-processors;
- Governmental departments and agencies where we are permitted or required by law to do so.
We will also include your name and order number in any Entrant Lists which we publish on our Website as part of the process of carrying out a competition draw. You may however ask us to exclude your name from our Entrant Lists in accordance with our Terms & Conditions.
If you win a competition, our Terms & Conditions require you to agree to limited information being published on our Website and social media about you. This is typically limited to (i) your title, forename and initial of your surname or your title, first initial and surname (ii) your town or general location of residence (iii) your photograph and (iv) details of the prize which you have won.
AUTOMATED DECISION MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of our business processes involve human intervention. We do not therefore make any decisions about you using automated means.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from a Director.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Our standard data retention period is two years from the last date on which we are in actual contact with you i.e. from when you last enter a competition with us. If you have won a competition then we reserve the right to retain some personal data for an indefinite period, although this will be limited to part of your name, your town of residence, photograph and details of the competition prize which you have won.
Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for up to seven years.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information. Under certain circumstances, you have the right to:
- Request access to your personal information (a Subject Access Request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You will not usually have to pay a fee to access your personal information but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or you have objected to the processing and there is no overriding legitimate interest for continuing the processing.
- Object to processing of your personal information where we are relying on a legitimate interest and you object on “grounds relating to your particular situation.”
- Request the restriction of processing of your personal information. This enables you to ask us to block or suppress the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it or if you have also objected to the processing as above.
- Request the transfer of your personal information to another party when the processing is based on consent and carried out by automated means. This right is not usually applicable to any data processing carried out by us.
If you want to exercise any of the above rights, please contact a Director in writing. We will consider your request and confirm the actions which we have taken in response to such request.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact a Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We will confirm the actions which we have taken in respect of any such request.
If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the Information Commissioners Office in the United Kingdom. Their details are:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745
If you have any questions about this Privacy Notice, you can write to the Directors at Superb Giveaways, 20 Lansdown, Stroud, Gloucestershire, GL5 1BG. Alternatively, you may email us at email@example.com