This policy explains what we do with your personal information when you use majorgolfgiveaways.com, enter a competition, or contact us. It is written to meet the requirements of the UK GDPR and the Data Protection Act 2018.
1. Who is responsible for your information
The data controller is PLACEHOLDER_COMPANY_NAME, trading as Major Golf Giveaways, a company registered in England and Wales with company number PLACEHOLDER_COMPANY_NO, registered office PLACEHOLDER_REG_ADDRESS.
We are registered with the Information Commissioner’s Office under registration number PLACEHOLDER_ICO_NUMBER.
For anything to do with your data, contact PLACEHOLDER_PRIVACY_EMAIL, or write to PLACEHOLDER_PO_BOX, PLACEHOLDER_TOWN, PLACEHOLDER_POSTCODE.
[LEGAL CHECK] Confirm whether a Data Protection Officer is required. On the expected scale and processing it should not be, but the position should be recorded.
2. What we collect, why, and on what legal basis
| What we collect | Why we need it | Our lawful basis |
|---|---|---|
| Name, email address, postal address, telephone number, date of birth | To create your account, take your entry, verify you are 18 or over and eligible, and contact you if you win | Performance of a contract; legal obligation where age checks are required |
| Your competition entries: ticket numbers, question answers, entry times | To run the competition and the draw, and to publish the entry list after the draw | Performance of a contract |
| Payment details | To take payment. Card details are entered directly with our payment provider and we never see or store the full card number | Performance of a contract |
| Purchase history and spending totals | To apply per person ticket limits, monthly credit card limits and any spend limits you set | Performance of a contract; legitimate interests in running the site responsibly |
| Age and identity verification results | To confirm you are 18 or over and to release prizes | Legal obligation; legitimate interests in preventing underage and fraudulent entry |
| Self exclusion and account suspension records | To make sure a self exclusion is honoured | Legitimate interests; substantial public interest |
| Your name, surname initial and county if you win | To show publicly that a valid award took place, as the CAP Code requires | Legitimate interests in the transparency of our draws, and compliance with the advertising codes |
| Photographs or quotes you give us as a winner | To publish on the winners page and social media | Consent |
| Messages you send us, and our replies | To answer you and keep a record of complaints | Performance of a contract; legitimate interests |
| Marketing preferences | To send you what you asked for and nothing else | Consent |
| Website usage data: IP address, device and browser, pages viewed, referring site | To keep the site working and secure, and to understand how it is used | Legitimate interests; consent where cookies are not strictly necessary |
Where we rely on legitimate interests, we have considered whether that interest is outweighed by your rights, and you can object at any time using the details above.
3. Publishing winners
We publish the winning ticket number, the winner’s first name, the initial of their surname and their county on our draw results page, together with the live draw recording. We do this so that anyone who entered can see the draw was genuine, which is a requirement of the CAP Code for prize promotions.
We tell you this before you enter, and you can object. If you win and would rather we did not publish those details, email PLACEHOLDER_PRIVACY_EMAIL before the draw and we will publish only the winning ticket number. Objecting does not affect your entry or your prize.
We also publish the full entry list for each competition after the draw. That list shows ticket numbers only. It does not show names, addresses or any other personal detail.
4. Who we share it with
We share your information only with organisations that help us run the business, and only with what they need:
- Payment providers, to take payment and handle refunds and chargebacks
- Age and identity verification providers, to confirm you are 18 or over
- Our hosting and website providers, who store the site and its database
- Email and messaging providers, to send confirmations and replies
- Prize suppliers and couriers, to deliver a prize to a winner
- Our accountants and professional advisers, where they need it
- Law enforcement, regulators or the courts, where we are legally required to
We do not sell your personal information, and we do not share it with third parties for their own marketing.
[LEGAL CHECK] The named processors need listing once chosen, along with confirmation that a data processing agreement is in place with each.
5. Where your information is held
Our website and database are hosted in PLACEHOLDER_HOSTING_LOCATION. Some of our providers may process data outside the UK. Where they do, we make sure the transfer is covered by UK adequacy regulations or by the International Data Transfer Agreement or Addendum, so that your information keeps the same protection it has here.
6. How long we keep it
| Record | How long |
|---|---|
| Account and entry records | Six years after your last entry, to deal with queries, disputes and chargebacks |
| Transaction and accounting records | Six years after the end of the financial year they relate to, as tax law requires |
| Age and identity verification results | The outcome and date only, for six years. We do not keep copies of identity documents beyond the check |
| Winner details published on the site | Indefinitely as part of the public draw record, unless you object |
| Entry lists (ticket numbers only) | Indefinitely as part of the public draw record |
| Self exclusion records | Indefinitely, because a self exclusion has to outlast the account |
| Marketing preferences | Until you withdraw consent, plus the record of withdrawal |
| Correspondence and complaints | Six years from the last contact |
| Website analytics | PLACEHOLDER_ANALYTICS_RETENTION |
When a retention period ends we delete the information or anonymise it so that it can no longer identify you.
7. Marketing
We will only email or text you about competitions if you have asked us to. Every marketing message has an unsubscribe link, and you can change your preferences in your account or by emailing us. Unsubscribing does not stop the messages we have to send you about an entry you have made, such as a ticket confirmation or a notification that you have won.
If you have suspended your account or self excluded, we will not send you marketing at all while that is in force, even if you had previously opted in.
8. Cookies
We use cookies and similar technologies. Some are strictly necessary to make the site work, such as keeping you logged in and remembering what is in your basket, and these do not need your consent. Anything else, including analytics and any advertising cookies, is only set if you agree through the cookie banner. You can change or withdraw that choice at any time using PLACEHOLDER_COOKIE_SETTINGS_LINK.
[LEGAL CHECK] A full cookie table listing each cookie, its purpose and its lifetime needs adding once the final plugin and analytics setup is fixed. PECR requires consent before non essential cookies are set, not just a banner on display.
9. Your rights
You have the right to:
- be told what we do with your information, which is what this policy is for
- see a copy of the information we hold about you
- have it corrected if it is wrong
- have it deleted, where we do not have a continuing reason to keep it
- restrict what we do with it while a concern is looked into
- object to us using it where we rely on legitimate interests
- take it elsewhere in a portable format, where we hold it on the basis of consent or a contract
- withdraw consent at any time, where consent is what we relied on
Ask us using the contact details in section 1. We will reply within one month. There is no charge. We may ask you to confirm who you are before we act on a request.
Some rights have limits. For example, we cannot delete a record of a completed transaction that tax law requires us to keep, and we cannot delete a self exclusion record, because the whole point of it is that it survives.
10. Complaints about your data
If you are unhappy with how we have handled your information, please tell us first at PLACEHOLDER_PRIVACY_EMAIL and give us the chance to put it right.
You can also complain to the Information Commissioner’s Office:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone 0303 123 1113
ico.org.uk/make-a-complaint
11. Changes to this policy
If we change this policy we will publish the new version here with a new date. Where a change materially affects how we use information you have already given us, we will tell you by email.