Privacy Policy
Last updated: [Insert date]
1. Who We Are
This Privacy Policy explains how Daniel Lyons trading as TopDraw collects, uses and protects your personal data.
For the purposes of UK data protection law, the Promoter is the controller of your personal data.
2. Personal Data We Collect
We may collect:
(a)your name;
(b)your date of birth;
(c)your email address;
(d)your phone number;
(e)your postal address;
(f)account login information;
(g)payment and transaction information;
(h)competition entries and ticket numbers;
(i)wallet activity;
(j)identity and age verification information;
(k)winner information;
(l)communications with us;
(m)device, browser, IP address and website usage data;
(n)marketing preferences.
We do not store full card details. Card payments are processed by Stripe or another payment provider.
3. How We Use Your Data
We use your data to:
(a)create and manage your account;
(b)process entries and payments;
(c)allocate tickets;
(d)administer competitions;
(e)run draws;
(f)contact winners;
(g)verify identity, age, address and eligibility;
(h)deliver prizes;
(i)operate wallet features;
(j)prevent fraud, abuse, chargebacks, underage entry and unlawful activity;
(k)respond to enquiries;
(l)send service emails;
(m)send marketing emails where permitted;
(n)improve the Platform;
(o)comply with legal, tax, accounting and payment-provider obligations.
4. Legal Bases
We process personal data using one or more of the following legal bases:
(a)contract, where processing is needed to provide your account, entries, wallet, draws and prizes;
(b)legal obligation, where processing is needed for tax, accounting, consumer law, fraud prevention or legal compliance;
(c)legitimate interests, where processing is needed to operate, secure, improve and protect the Platform and competitions;
(d)consent, where you opt in to marketing or optional promotional activity.
5. Sharing Your Data
We may share personal data with:
(a)payment providers such as Stripe;
(b)delivery companies;
(c)prize suppliers;
(d)identity or age verification providers;
(e)website, hosting, analytics and technology providers;
(f)email and marketing providers;
(g)fraud-prevention providers;
(h)professional advisers;
(i)regulators, law enforcement, courts or public authorities where required.
6. Winner Information
If you win, we may publish limited winner information, such as your first name, surname initial, town or county, prize won and competition entered.
We may ask you to take part in photographs, videos or interviews, but you are not required to provide photos or videos unless you choose to do so.
7. Marketing
We may send marketing emails where you have opted in or where we are otherwise permitted by law.
You can unsubscribe at any time by using the unsubscribe link in our emails or contacting hello@topdrawprizes.co.uk.
8. Cookies and Analytics
We use cookies and similar technologies as explained in our Cookie Policy.
9. Data Retention
We keep personal data only for as long as reasonably necessary for the purposes set out in this Privacy Policy.
We may keep certain records for longer where required for legal, tax, accounting, fraud prevention, payment dispute, winner verification or regulatory reasons.
10. Your Rights
Under UK data protection law, you may have rights to:
(a)access your personal data;
(b)correct inaccurate personal data;
(c)request deletion of your personal data;
(d)restrict processing;
(e)object to processing;
(f)request data portability;
(g)withdraw consent where processing is based on consent;
(h)complain to the Information Commissioner’s Office.
To exercise your rights, contact hello@topdrawprizes.co.uk.
11. Security
We use reasonable technical and organisational measures to protect personal data. However, no website or online system can be guaranteed to be completely secure.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will be posted on the Platform.