This policy describes how Raforte Ltd (also referred to as “Raforte“, “we” or “us“) will make use of your data when you use [•](“our website”), enter our competitions as an entrant (“Interact with us as an Entrant”), engage with us to provide prizes in our competitions as a lister (“Interact with us as a Lister”), sign-up for our newsletter or contact us.
It also describes your data protection rights, including the right to object to some of the processing which Raforte carries out. More information about your rights, and how to exercise them, is set out in the “Your choices and rights” section.
Personal data we may collect about you
Generally, we collect and process personal data about you use our website. This includes:
| Category | Details |
| Identification Information | Your name, username, password and date of birth |
| Contact Information | Your home address, email address and phone number |
| Payment and Delivery Details | Your payment and delivery details, including billing and delivery addresses and credit card details, where you contract with us to enter a competition or provide a prize for a competition |
| Marketing Information | Your marketing preferences, including any consents you have given us |
| Device and Cookie Information | Information related to the browser or device you use to access our website, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform; |
| Communications Information | Any other information you may provide in your communications with us |
We may also collect and process the following personal data about you when Interact with us as an Entrant:
| Category | Details |
| Images and Video Footage | Photos and video recordings that identify you, particularly where you win a prize |
We may also collect and process the following personal data about you when Interact with us as a Lister:
| Category | Details |
| Prize Information | Information you provide about the Prize you wish to list that contains your personal data, such as photos or prize descriptions |
| Verification Information | Proof of your ID, address and bank statement |
Sometimes, we receive information about you from third parties and publicly available sources such as analytics providers, social media companies and data brokers/aggregators.
How do we use this information and what is the legal basis for this use?
Generally, we will use your personal data for the purposes and legal bases set out below:
| Purpose | Legal Basis |
| We will collect, use and store your Identification Information and Contact Information to register and create your account on our website. | It is necessary for us to process your personal data in order to perform our contract with you, or to take steps at your request prior to entering into a contract with you as part of your account registration. |
| We collect and use your Identification Information and Contact Information to verify your identity. | We have a legitimate interest in ensuring the security of our services and data. |
| We will use your Identification Information, Contact Information, Delivery Details and Device Information to monitor accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law. | We have a legitimate interest in preventing and detecting fraud or other wrongdoing. |
| We will collect and analyse your Device Information in order to manage and operate our website, including to keep it updated and relevant, to develop our business and to inform our marketing strategy. | Your consent. |
| We will collect, use and store your Identification Information, Contact Information and Communications Information to manage our relationship with you. | We have a legitimate interest in managing our business and our relationship with you and providing our services, including facilitating and promoting the competitions on behalf of Listers. |
| We will collect and use your Identification Information and Contact Information to send you our newsletter or other direct marketing. | Your consent. |
When you Interact with us as an Entrant, we also use your personal data for the purposes and legal bases set out below:
| Purpose | Legal Basis |
| We may use your Identification Information, Contact Information, Delivery Details, Device Information and Communications Information to check whether you are eligible to enter our competitions. | We have a legitimate interest in ensuring that we only permit entry into the competitions where this meets our terms and conditions of entry. |
| We may use your Identification Information, Contact Information and Delivery Details to facilitate entry and participation into competitions and to pay/deliver any prizes due as a result of winning those competitions. | It is necessary for us to process your personal data in order to perform our contract with you including allowing you to enter the competitions. |
| We may publish your Identification Information and your Images and Video Footage on our website to publicise the winner of a competition. | We have a legitimate interest in complying with the UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code) and in promoting the outcomes of competitions. |
When you Interact with us as a Lister, we will also use your personal data for the purposes and legal bases set out below:
| Purpose | Legal Basis |
| We may use your Identification Information, Prize Information, Contact Information, Delivery Details and Verification Information to contract with you and pay for prizes that we agree to list. | It is necessary for us to process your personal data in order to perform our contract with you. |
There are instvary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individual’s interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
How we share your personal data
We may share your data with the following categories of recipients:
| Category of Recipient | Why? |
| Third party service providers | We employ other companies and individuals to perform functions on our behalf. Examples include website hosting and maintenance (HandsDigital), customer service operations, identity checking, fulfilling orders for products or services, delivering packages, sending postal mail and e-mail, processing payments and providing customer service. We use www.randomdraws.co.uk to assist us in selecting competition winners. |
| Credit reference agencies, law enforcement and fraud prevention agencies | To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law. |
| Prospective Buyer/Seller | In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business. |
International Transfers
Your personal data may be processed outside the UK to or by one of the third parties mentioned above. Where your personal data is transferred outside of the UK, we require that appropriate safeguards are in place. To find out more about the appropriate safeguards that we have in place, please contact us at the details set out below.
Your choices and rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in UK data protection law. We will inform you of relevant exemptions we rely upon when responding to any request you make.
If you wish to exercise any of these rights, please contact us at the contact details set out below.
Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. We may however have other legal grounds for processing your data for other purposes, such as those set out above.
In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
If you have unresolved concerns, you have the right to complain to the Information Commissioner’s Office.
Where we collect personal data to enter into a contact with you or to comply with our legal obligations, this is mandatory and we will not be able to provide our services without this information. In other cases, the failure to provide the requested personal data may affect your ability to enter competitions or provide prizes for our competitions.
How long we retain your personal data
Where we process registration data, we do this for as long as you are an active user of our sites until you choose to delete your action. We will continue to retain information in relation to your listings and/or your entries and any other contractual matter for 6 years.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period of after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
Where we process personal data for site security purposes, we retain it for [no more than 12 months].
Updates to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
Contact us
The data controller for your personal data is Raforte. If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at info@raforte.com.