Privacy Policy
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Privacy Policy including UK GDPR Statement
Urban Competitions
We protect your data
This Privacy Policy sets out our policy concerning the collection, processing, storage, disclosure, and recording (using "cookies") of personal information supplied by you.
Urban Competitions, Company Number [Insert], registered office at [Insert registered address] ("we", "us", "our"), respects your privacy and is committed to treating any information we obtain about you with care, and in a manner compliant with applicable data protection legislation, including the UK General Data Protection Regulation, the EU GDPR (where relevant), and the Data Protection Act 2018 (collectively, "Data Protection Legislation").
Before accessing our website or entering a competition, we want you to understand what data we collect, why, and what your rights are.
This document explains:
- what personal data we may collect about you in connection with (i) our prize draws, competitions, and instant win games; (ii) your online interaction with us, including via our website, email, or social media channels; (iii) free postal entries; 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, including the lawful bases by which we process your data, how long we retain it, and your rights regarding the personal data we hold about you.
This policy is intended to be clear and accessible, but if you have any questions, please email [email protected] and we will respond as soon as possible.
We may update this Privacy Policy from time to time to reflect changes in Data Protection Legislation or our own practices. We recommend checking this page periodically.
In this Privacy Policy, terms defined in UK GDPR, including "data subject," "personal data," and "processing," carry the same meaning.
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The personal data we process
We collect personal data about you through the Channels when you:
- access and use our website, including via cookies;
- enter a competition, prize draw, or instant win game, whether by paid entry or free postal entry;
- create an account with us;
- subscribe to our mailing list or marketing communications;
- contact us, whether by email, Messenger, Instagram, telephone, or post;
- engage with our social media pages or Facebook group;
- request a prize claim or cash withdrawal of site credit.
The personal data we may process includes:
- information collected through cookies when you use our website;
- your full name, date of birth, postal address, email address, and telephone number;
- your account username and password (stored encrypted);
- competition entry records, including ticket numbers and entry method (paid or free postal);
- limited payment transaction information (processed by our payment provider — see "Sharing information with affiliates and third parties" below);
- identity verification documents (such as a copy of your passport or driving licence), where required to verify a cash withdrawal or high-value prize claim;
- correspondence you send us, including prize claims and customer service enquiries.
You should not provide us with any personal data beyond what is requested through the Channels.
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The purposes for which we process your data
We use your personal data to:
- create and manage your account;
- process competition and instant win entries, including matching free postal entries to your account;
- process your entry payment via our payment provider;
- conduct prize draws and instant win allocations, and select winners;
- contact you if you are a winner, and administer your prize claim;
- verify your identity before processing a cash withdrawal of site credit, or before releasing a high-value prize;
- arrange delivery of physical prizes;
- send you confirmation emails, entry receipts, and service updates;
- send you promotional and marketing material, where you have opted in;
- respond to correspondence, including enquiries, comments, and complaints;
- comply with our legal and regulatory obligations, including those arising under the Gambling Act 2005 and requirements set by our payment provider and bank;
- prevent and investigate fraud.
We may process your data for these purposes ourselves or in conjunction with our third-party service providers.
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The lawful basis by which we process your data
Your consent
By accepting the terms of this Privacy Policy, you give us your express, freely given consent to process your data in accordance with this policy. You may withdraw consent at any time by emailing [email protected]. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, or processing carried out under another lawful basis.
Other lawful grounds
We may also process your data where necessary:
- to perform our agreement with you (for example, to deliver a prize you have won, or process a site credit withdrawal);
- to comply with an applicable law or regulation, including gambling, payment processing, and tax-related obligations;
- for our legitimate interests, or those of third parties, including fraud prevention, business administration, and improving our services.
What if you refuse to provide personal data?
Where we need to collect personal data by law, or under the terms of an agreement with you, and you do not provide it when requested, we may be unable to fulfil that agreement — for example, we may be unable to verify your identity and release a cash prize to you. In this case, we will notify you and may need to withhold or reallocate the prize in accordance with our Terms & Conditions.
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Sharing information with affiliates and third parties
We will not share your data with third parties except as set out here, or as otherwise notified to or agreed with you.
We share personal data with the following categories of third-party service provider, only where necessary for them to provide their service to us:
- our payment processor, Cashflows, to process card payments, Apple Pay, and Google Pay transactions;
- our banking provider, Zempler Bank, in connection with our business banking operations;
- our competition platform provider, RaffleX, who host and operate our website and entry system;
- email service providers, for sending confirmation and marketing emails;
- web analytics services, such as Google Analytics;
- social media platforms, including Meta (Facebook and Instagram), where you interact with us via those channels, or where we use tools such as the Meta Pixel for advertising;
- professional service providers, such as solicitors, accountants, or auditors;
- delivery or logistics providers, where a physical prize requires fulfilment;
- regulators and authorities, where required by law, including the Gambling Commission, HMRC, and the Information Commissioner's Office.
We seek to ensure that any third party we engage to process your data has appropriate policies and safeguards in place to comply with Data Protection Legislation. Unless otherwise disclosed to you, we remain the data controller in respect of your data even where third parties act as data processors on our behalf.
We may also share personal data with third parties where required by law or regulation, such as in connection with a fraud investigation or other legal proceedings, or where we believe your actions may violate applicable law or threaten the rights, property, or safety of us, our users, or others.
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Your rights as a data subject
Subject to the conditions set out in Data Protection Legislation, you may have the right to:
- request a copy of the personal data we hold about you;
- correct any inaccurate or incomplete personal data we hold — you can request this by emailing [Insert contact email];
- request that we erase the personal data we hold about you;
- request that we restrict our processing of your data;
- object to certain types of processing;
- complain to the Information Commissioner's Office (ICO), if you believe we have not handled your data properly.
Information Commissioner's Office
https://ico.org.uk
Telephone: 0303 123 1113
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Storage and retention of your data
As a minimum, we will store your data for as long as is reasonably necessary to administer your entry and, where applicable, deliver your prize.
As a general rule, we retain account and entry data for 6 years to meet our accounting and legal obligations, and free postal entry records for 6 months following the relevant competition's draw date, to handle any queries or disputes.
If you ask us to delete your account, we will take steps to delete the personal data we hold about you once it is no longer necessary for us to retain it — for example, once any prize has been fulfilled, any dispute resolved, or as otherwise required by law.
While we store your data, we follow generally accepted industry standards and maintain reasonable safeguards to protect the security, integrity, and privacy of your information. We have measures in place designed to protect against loss, misuse, and unauthorised alteration of data under our control. Despite these efforts, no system is completely secure, and we cannot guarantee absolute protection against unauthorised third-party access. We will notify you as soon as reasonably possible if we become aware of a personal data breach affecting your data.
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Links to third parties
Our website may link to other websites outside our control. Such links are not an endorsement of, or representation of any affiliation with, those websites, and they fall outside the scope of this Privacy Policy. Please review the privacy policy of any third-party website before providing it with personal data. We are not responsible for the privacy practices of any third-party website.
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Cookies
A cookie is a small file of letters and numbers stored on your browser or device. Our website uses cookies to distinguish you from other users, improve your experience, and help us improve our website.
Some cookie data is collected on an anonymous or aggregated basis. Where cookies contain personal data, we process that data in accordance with this policy.
You can block or delete cookies through your browser settings. If you block essential cookies, parts of our website may not function correctly.
For more information on managing cookies, visit www.allaboutcookies.org/manage-cookies.
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UK GDPR Statement
We have reviewed our activities across the business and how data is processed. Our activities fall within these key areas:
- as a data controller of our own employee data;
- as a data controller or processor of third-party data, such as direct marketing activity;
- as a data processor or controller of customer personal data, in connection with competition entries and prize fulfilment.
What we need
We only collect personal data necessary to verify your eligibility to enter our competitions, and to enable us to deliver prizes to winners. This includes name, age, address, phone number, and email address.
Why we need it
We need your basic personal data to confirm your eligibility (including that you are 18 or over and a UK resident) and to ensure we can deliver any prize you win. We do not collect personal data beyond what is needed to provide our services to you.
What we do with it
Your data is processed and stored securely, and is not made available to other parties unless required by law, or as set out in the "Sharing information with affiliates and third parties" section above.
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Frequently asked questions
What personal data do you process?
Any data relating to an identifiable person: name, age, address, phone number, email address, and related account and entry information.
For what purpose do you process this personal data?
To operate our prize draws and instant win competitions in accordance with the free entry route exemption under Section 339 of the Gambling Act 2005, and to allow our customers to enter competitions on our website while verifying their eligibility to do so.
What are the risks to data subjects' rights and freedoms if personal data is destroyed, lost, altered, or disclosed without authority?
We aim to keep these risks minimal. Personal data is held in our database and shared only with the third parties listed in this policy, each of which maintains its own data protection policies. In the event of unauthorised loss, alteration, or disclosure, a data subject could report this to the ICO, which may result in fines of up to 4% of our turnover, as well as potential compensation claims and reputational harm. We take our data protection obligations seriously and have processes in place to minimise these risks.
What happens to my data once it is no longer needed?
Where you ask us to delete your data, we will discuss this with you and remove your records accordingly, subject to any legal retention requirements. Otherwise, we retain your data for the periods set out in "Storage and retention of your data" above.
You may request a copy of the personal data we hold about you. To do so, please email us at [email protected] from your registered contact email address.
If you believe any information we hold about you is incorrect or incomplete, please contact us and we will promptly correct it.
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Text message marketing
By checking the text message marketing box at checkout, you consent to receive marketing text messages (such as promotions and competition updates) from Urban Competitions at the number provided. Consent is not a condition of entering any competition. Message and data rates may apply, and message frequency may vary. You can unsubscribe at any time by replying STOP. See our Terms & Conditions for further information.