1 Introduction
1.1 We are committed to safeguarding the privacy of individuals ("you","your") entering competitions and prize-draws by using the www.winmeforfree.com and www.winmeforfree.co.uk website ("Website") or by post. In this Privacy Statement we explain how we will handle your personal data.
2 About winmeforfree.com
2.1 Our Website is owned and operated by winmeforfree LTD.
2.2 We are a company registered in Scotland under registration number SC628188. Our registered office and principal place of business is 116 West Regent Street, Glasgow, G2 2QD. We are also registered with the Information Commisioner's office (Reference number: ZA517838).
2.3 You can contact us by (a) post, to 116 West Regent Street, Glasgow, G2 2QD, (b) or (d) email, using the following email address: Privacy@winmeforfree.com
3 Entering competitions & prize-draws using our Website
3.1 You may enter winmeforfree competitions and prize draws using our Website by first completing the registration form.
4 Our Data Protection Officer
4.1 Our Data Protection Officer is Karen O'Rourke. You can contact our Data Protection Officer in writing using the following contact details Privacy@winmeforfree.com: The tasks of our Data Protection Officer include (for example) monitoring our compliance with applicable data protection laws and acting as contact for individuals whose data is processed by us.
5 Your rights
5.1 In this Section 5, we have summarised the rights that you have under applicable data protection laws. Some of the rights are complex, and not all of the details have been included in our summaries below. Accordingly, you should read the applicable data protection laws and guidance from the UK Information Commissioner for a fuller explanation of these rights. You can do so by using this link https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
5.2 You may exercise any of your rights below in relation to your personal data by contacting our Data Protection Officer in writing using the following contact details: Karen O'Rourke, Winmeforfree, 116 West Regent Street, Glasgow, G2 2QD
5.3 Your principal rights under the applicable data protection laws are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to the UK Information Commissioner; and (h) the right to withdraw consent.
5.4 Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
5.5 Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can ask us to make any necessary changes to ensure that your personal data is accurate and kept up to date. If you wish to do this, please contact our Data Protection Officer in writing using the following contact details: Karen O'Rourke, Winmeforfree, 116 West Regent Street, Glasgow, G2 2QD
5.6 Right to erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
5.7 Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5.8 Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
5.9 Right to object to processing (direct marketing): You have the right to object to our processing of your personal data for direct marketing purposes (including, for example, profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
5.10 Right to object to processing (scientific, historical research or statistics): You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
5.11 Right to data portability: To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.12 Right to complain to the UK Information Commissioner: If you consider that our processing of your personal data infringes the applicable data protection laws, you have a legal right to lodge a complaint with the UK Information Commissioner (www.ico.org.uk) which is the UK data protection regulatory body.
5.13 Right to withdraw consent: To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6 Your data protection questions
6.1 If you have any questions, concerns or issues about your personal data, then please contact our Data Protection Officer in writing by using the following contact details: Karen O'Rourke, Winmeforfree, 116 West Regent Street, Glasgow, G2 2QD
7 Changes to the winmeforfree Privacy Statement
7.1 We may update the winmeforfree Privacy Statement from time to time by publishing a new version on our Website. You should check this page regularly to ensure you are happy with any changes to the winmeforfree Privacy Statement. winmeforfree will obtain your opt-in consent for any updates to this Privacy Statement that materially expand the sharing or use of your personal data in ways not disclosed in this Privacy Statement at the time of collection.
8 How we collect your personal data
We collect your personal data from various sources. These are as follows:
Personal Data you provide us about you
8.1 We collect your personal data that you provide us when you do the following: (a) fill in a webform on our Website e.g. to give feedback; (b) get in touch with us by email, letter, (c) participate in a survey, market research, competition and/or or prize-draw.
Personal Data we collect about you
8.2 We collect your personal data when you access or use our Website and through the use of cookies (see our Cookies Policy).
8.3 The types of personal data we will collect include, for example: (a) name, address and contact details (b) demographic data; (c) the originating IP address; (d) the site that you visited immediately prior to visiting our Website; (e) the type of browser and operating system used (if provided by the browser); (f) URL of the referring page (if provided by the browser); (g) the specific actions that you take on our Website, including, for example, the pages that you visit; (h) the time, frequency and duration of your visits to our Website; and (i) We may also obtain information regarding your survey responses
9 How we use your personal data
9.1 In this Section 9 we have set out (a) the general categories of personal data that we may process, (b) the purposes for which we may process personal data, and (c) the legal bases of the processing. When you have given us clear and unambiguous permission to contact you in certain ways i.e. by email or by telephone, we process your data with your Consent. We may also process your personal data where the benefits of doing so are not outweighed by the interests or fundamental rights or freedoms of individuals Legitimate Interest. Where we rely on this as the basis for processing your data it is in order to allow us to conduct a data business for commercial gain. You can object to us processing your personal information for this purpose as described in section 6 above.
9.2 We may process data about your use of our Website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your Website use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of our Website. The legal basis for this processing is our legitimate interest.
Data we get through the Website
9.5 We may process your personal data that is provided in the course of the use of our Website ("service data"). The service data may include usage data. The service data may be processed for the purposes of operating our Website, ensuring the security of our Website, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is with your consent.
Data you give us when you write to us by post
9.6 We may process your postal data ("postal data"). The postal data may include your name, and postal address. This information will not be used for any prize draws.
Data we use to communicate with you electronically
9.7 We may process information that you provide to us for the purpose of (a) subscribing to our communications (including, for example, direct marketing communications) with you and/or newsletters ("electronic communications data"). The electronic communications data may include your name and email address and telephone number. The electronic communications data may be processed for the purposes of sending you the relevant communications. For example, emails or calls advising you of new competition. The legal basis for this processing is with your consent and the following statement will be featured in a prominent place on the Winmeforfree website prior to you registering with winmeforfree.
By registering and entering you agree to the terms and conditions of the privacy statement that govern how your information will be processed.
Data we get when you get in touch with us
9.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is with your consent.
Data we publish on our Website
9.9 We may process information that you provide us for publication on our Website, if you enter a competition.("publication data"). The publication data may include your name. The publication data may be processed for the purposes of enabling such publication and administering our Website and business. The legal basis for this processing is with your consent.
Statistics
9.10 We may process any of your personal data identified in this Privacy Statement for the purpose of updating and correcting databases and be aggregated at Postcode or other levels for the building of statistical and analytical tables. The legal basis for this processing is our legitimate interest.
Data we use to bring or defend legal claims
9.11 We may process any of your personal data identified in the other provisions of this Privacy Statement where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Data we use to comply with the law
9.12 In addition to the specific purposes for which we may process your personal data set out in this Section 10, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9.13 Winmeforfree will not use or share your personal information in a manner that differs from what is described within this Privacy Statement and within the registration opt-in statement without your prior consent or unless this is in our legitimate interests.
By registering and entering you agree to the terms and conditions of the privacy statement that govern how your information will be processed
10 Providing your personal data to others
We will share your personal data with the following third parties:
Competition & Prize-draw Sponsors
10.1 We share your answers to the questionnaires, your name and contact details with the sponsors of competitions and prize-draws that you entered by filling in their questionnaires for the purposes of (a) processing your entry to a competition or prize-draw and to notify you if you have won, and (b) the relevant sponsors communicating with you after you filled in their questionnaires.
10.2 Every user must agree and opt-in to the following statement before completing their Winmeforfree registration:
By registering and entering you agree to the terms and conditions of the Privacy Statement that govern how your information will be processed.
10.3 Each questionnaire on Winmeforfree is sponsored by one or more Sponsor’s and will request your consent for the Sponsor to contact you. You will be required to take a positive action i.e. provide or confirm your telephone number in order to give your consent. If you do not take this action you will not be giving your consent and the Sponsor will not contact you and you will not be entered into the competition or prize draw. If the Sponsor’s wishes to contact you by more than one method i.e. electronically or by telephone they will ask for your consent for each method of contact.
10.4 Sponsors of Winmeforfree may include Commercial, Not for Profit, Research, Public Regulatory Authorities and Political Organisations that may wish to contact you for marketing or other purposes appropriate to the individual organisation. These Sponsors are clearly identified within the questionnaire they are sponsoring.
10.5 Sponsors of the Winmeforfree questionnaires have their own privacy policies and some have their own opt-in statements, Winmeforfree strongly recommends that you read and understand this information.
Partners
10.6 We share your usage data, profile and service data with Winmeforfree Partners for the purposes of Winmeforfree Partners communicating with you to provide you with information about products and/or services that they think may be of interest to you.
10.7 Each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will make available to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
10.8 Some of the prizes on Winmeforfree may be provided by winmeforfree or a client of Winmeforfree, When a prize is provided the identity of the provider will be clearly identified with the prize.
10.9 Your data may be provided to clients of Winmeforfree to be appended to information they already hold about you for the purpose of contacting you with information about their products and services.
10.10 We will share your data for commercial gain with third parties, listed here. These organisations will have a relationship with you or it may be used where they have a lawful reason. This includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.
10.11 The following sectors are the industry types you can expect to receive communications, products, information, services or special offers from - Automotive, Broadband, Call Centre, Charity, Competition Sites, Debt Tracing Linkage and Collections, Education, Entertainment, Gaming, Leisure, Fashion, Finance, Savings and Investment products, FMCG, Freebie Sites, Gambling, Gardening, Government, Health & Beauty, Home & Lifestyle, Mobility, Home Improvement, Household, IT/Technical, Insurance (Life, Home, Automotive, General, Private Medical, Travel), Legal Services, Lottery, Mail Order, Market Research, Music, Pension, Pharmaceutical, Claims Management Companies - Claims for Financial Product and Services for: mis-sold PPI / PBA, SERPS / Pensions, Loans, Mortgages, Personal Injury (RTA, Holiday Claims and other PI related products), Housing Disrepair, Employment Matters and criminal injury (products regulated by the Claims Management Regulator), Premium Rate, Publishing/Media, Retail, Sport, Telecoms, Toiletries/Cosmetics, Travel, Utilities, Public Sector Organisations.
Others
10.12 We may share your electronic communications data with our suppliers or subcontractors insofar as reasonably necessary for us to send you relevant communications and/or newsletters. For example, newsletters advising you of new competition and the basis for processing this data would be with your consent.
10.13 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
10.14 Except as provided above in this Section 11, Winmeforfree will not provide your personal data to any third party without informing you.
10.15 You will be notified when your personal data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
10.16 The collection of data by Winmeforfree through registration on third party sites may lead to your data also being held by that third party site.
11 Communications
11.1 Once you register with Winmeforfree you will receive a welcome email. You may also receive further emails describing new prizes and specific events relevant to you as a member of winmeforfree
11.2 You have a right to object to such processing see below.
11.3 There is information on how you can un-subscribe at the bottom of every email that Winmeforfree sends out. We provide you the opportunity to 'opt-out' of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you answer questions from one of our loans clients but do to apply for a loan you can state not applicable and you will not receive communication from the loan client.
11.4 If you no longer wish to receive promotional communications, you may opt-out of receiving them by following the instructions included in each email communication or by emailing us, We offer an opportunity to opt-out of certain communications on our website you may contact us 116 West Regent Street, Glasgow, G2 2QD, (b) or (d) email, using the following email address: Privacy@winmeforfree.com
11.5 Winmeforfree holds your data in a central database and this database is only accessed by reference to interest or demographic categories in order to provide you with information that may be of interest to you. The process of supplying you with this information is at all times under the control of winmeforfree although specialist third party suppliers may carry out the dispatch.
12 International transfers of your personal data
12.1 In this Section 13, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom. We do not currently transfer your personal data to countries outside the European Economic Area except where this is transferred to sponsors and/or partners to whom you have consented and where this is transferred to countries outside the European Economic Area in accordance with the privacy policies of the relevant sponsor and/or partner.
12.2 You acknowledge that personal data that you submit for publication through our Website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
13 Security and storage of personal data
13.1 The Internet is not a 100% secure medium for communication and, accordingly, Winmeforfree cannot guarantee the security of any information you send to Winmeforfree via the Internet. Winmeforfree is not responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.
13.2 Winmeforfree is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems with limited access, which are located in controlled facilities.
14 Retaining and deleting personal data
14.1 This Section 15 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
14.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
14.3 We will retain and delete your personal data as follows:
14.4 Usage data, Profile data and Account Data will be retained as long as you remain a member of Winmeforfree and for one month following the date you cease to be a member. At the end of which period it will be deleted from our systems.
14.5 Notification data and Postal data will be retained for six months following the completion of each prize draw. At the end of which period it will be deleted from our systems. Details of winners, Publication data, will be retained for up to ten years.
14.6 In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: The economic life of the personal data.
14.7 the period of retention of Correspondence data will be determined based on the nature of the content of the correspondence and any legal implications.
14.8 Notwithstanding the other provisions of this Section 15, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
15 Third Party websites
15.1 Our Website may contain links to third party websites. Please note that if you follow a link to any such website, we do not accept any liability or responsibility, because these websites have their own terms & conditions and Privacy Policies.
