ACE HIGH COMPETITIONS

PRIVACY AND COOKIES POLICY

DECEMBER 2020

This Privacy and Cookies Policy (hereinafter referred to as the “Policy“) applies to the website www.acehighcompetitions.com (hereinafter referred to as the “Website”) run by Ace High Competitions (hereinafter referred to as the “Promoter”) whose registered office address is located at [PO BOX…….].

All capitalised terms and expressions used in this Policy shall have the meaning ascribed to them herein or in the Terms and Conditions of the Promoter.

The Promoter recognises the importance of the honest and responsible use of your personal information and is committed to protecting and respecting your privacy. This Policy explains how the Promoter collects, uses and discloses personal information relating to you when you visit the Website, and when you contact the Promoter, whether by e-mail, post, fax or telephone using the contact options on the Website, or via any of the Promoter’s other online services or social media platforms. The information you provide to the Promoter through the Website shall be collected by the Promoter but may subsequently be shared with other companies to the extent that this is necessary to allow the Promoter to operate effectively.

It is important to the Promoter that you feel completely comfortable in visiting and using the Website.

Collection by the Promoter of information relating to your use of the Website may involve the use of cookies and Web beacons. Please see the section “Information about the Promoter’s use of cookies” below for more information.

DATA PROTECTION

For the purposes of the Data Protection Act 2018 (the “Act“) and the General Data Protection Regulation 2016/679 (the “GDPR“), the data controller is the Promoter.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

The legal grounds on which the collection by the Promoter of personal information relating to you is based include, but are not limited to:

  • collection of your personal information with your consent;
  • collection of personal information relating to you, where it is lawful to do so, from public sources, third party service providers, government, tax or law enforcement agencies, and/or other third parties; collection of personal information relating to you from your use of any other online services of the Promoter as the case may be;
  • the use of cookies to collect information relating to your activity on the Website.

In most cases, the information relating to you which is used by the Promoter is required to deal with your request or registration, is required by law, or is necessary for the exercise of the Promoter’s legitimate business interests and needs, in which case special care is taken to safeguard your rights and to ensure that any such use is proportionate to the Promoter’s requirements.

PERSONAL INFORMATION COLLECTED FROM YOU

If you wish to contact the Promoter or to use certain facilities provided on the Website, you shall need to provide certain personal information so that the Promoter can liaise with you and deal with your request, query or application. If you choose to provide the Promoter with your personal information, the Promoter shall collect such information for the exclusive purposes set out in this Policy (or as otherwise notified to you from time to time).

The Promoter may collect, store and process the following personal information when such has been provided by you:

  • when you contact us: your full name, email address and the reason for your contact, which may relate to an enquiry or a request on behalf of yourself or someone else, a comment, or details of a possible or existing competition;
  • when you create an account: your username, email address, account password and contact and marketing preferences;
  • when you complete your first transaction: your full name, full address, telephone number and payment card details;
  • when you complete subsequent transactions: your payment card details;
  • when you take part in a survey or interact with the Promoter in various other ways: your full name, email address, demographics information and information about subjects that may interest you;
  • standard internet and website log information and details of your browsing activity on the Website. The information collected by the Promoter may include, but is not limited to, information about your Internet service provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to the Website, the Web pages you request and the date and time of such requests;
  • instances where you “like” the Promoter or make or comment on posts on its pages on social networking websites.

USES MADE OF YOUR PERSONAL INFORMATION

The Promoter may use your personal information for the purposes set out in this Policy or disclosed to you on the Website or on any other online services of the Promoter as the case may be. For example, the Promoter may use your personal information for the following purposes, all of which it deems to be in its legitimate business interests:

  • to contact you;
  • to operate competitions promoted on the Website;
  • to respond to and/or deal with any request or enquiry you may raise;
  • to improve its products and services and to ensure that content on the Website is presented in the most effective manner for you and for your device;
  • to administer the Website;
  • to comply with record keeping obligations;
  • subject to your consent where required under applicable laws, to carry out direct marketing and/or e-mail marketing requested by you;
  • to perform any contract the Promoter has with you;
  • to comply with legal, regulatory and other best practice obligations in force.

With regard to the use of your personal information for external marketing and regulatory purposes:

  • By entering a Competition, Entrants agree that their order reference number, name and Ticket number(s) shall be displayed on the Promoter’s social media platforms and on its Website.
  • All Winners shall be asked by the Promoter to provide photographs and/or to pose for photographs and/or videos and to consent to have such photos and/ór videos and their personal details (including details of any Prize won by them) included in marketing material of the Promoter relating to its Competitions and identifying them as a Winner of a Competition.
  • For the purposes of complying with its obligation to provide information that a valid Competition has taken place and that a Prize has been awarded, the Promoter shall provide the surname and county of residence of major Prize Winners to anyone who writes to contacts the Promoter by email at win@acehighcompetitions.com or by post to Ace High Competitions, [PO Box [x]] (enclosing a stamped, self-addressed envelope) within one month of the Closing Date of the Competition in question.
  • If an Entrant objects to its surname and county being published or otherwise made available, it should contact the Promoter by email at win@acehighcompetitions.com or by post to Ace High Competitions, [PO Box [x]] prior to the Closing Date. However, the Promoter remains obligated to provide the information outlined above to the Advertising Standards Authority upon request.

Upon collection of a Prize, the Winner shall be required to show proof of identification. Any failure to meet this requirement shall result in the Winner being disqualified and the Promoter retaining the Prize. The following forms of identification shall be accepted: (i) a valid passport, (ii) a valid driving licence or (iii) a valid utility bill or bank statement. In the event that the Prize is a vehicle, a valid driving licence belonging to the person who shall drive it away from the Promoter’s premises shall need to be produced. Proof of identification may be retained by the Promoter but will not be divulged in any way.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Your personal information shall be made available for the purposes mentioned herein (or as otherwise notified to you from time to time), on a ‘need-to-know’ basis and only to responsible employees of the Promoter or of an agent of the Promoter who require such information in order to properly perform their functions within or on behalf of the Promoter. Please note that certain individuals who shall see your personal information may not be direct employees of the Promoter or located in your country of residence (please see below).

Your personal information shall at times be made available to third parties providing relevant services under contract to the Promoter, such as credit and debit card processors, auditors and compliance managers. These entities may use your personal information to perform their functions on the Promoter’s behalf.

The information that the Promoter collects from you may be transferred to and/or stored at a destination outside the European Economic Area (“EEA“). It may also be processed by contractors operating outside the EEA who work for the Promoter or for one of its providers or agents. This may include contractors engaged in, among others, the fulfilment of any contract with you, the processing of your payment details or the provision of support services. By submitting your personal information, you agree to such transfer, storing and/or processing. The Promoter shall take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Policy.

The Promoter may disclose specific information upon lawful request by government authorities, law enforcement and/or regulatory authorities where required or permitted by law and for tax or other purposes. Your personal information may also be released to external parties in response to legal processes, when required to comply with laws, or to enforce the Promoter’s agreements, corporate policies, and terms of use, or to protect the rights, property or safety of the Promoter, its employees, agents, customers and others, as well as to parties to whom you authorise the Promoter to release your personal information.

The Promoter shall not sell your personal information to any third party other than as part of a restructuring or sale of all or part of its business activities.

WHAT CHOICES DOES THE PROMOTER OFFER YOU WITH REGARD TO DIRECT MARKETING?

The Promoter may wish to provide you with information about new products, services, promotions or offers which may be of interest to you, and may invite you to take part in market research or request feedback on its products and services. These means of communication may include, but are not limited to, e-mail, telephone, post, social media or SMS. The Promoter shall request your consent and advise you of how to opt out of receiving such communication.

WHAT SAFEGUARDS ARE IN PLACE TO PROTECT YOUR PERSONAL INFORMATION?

The Promoter shall take all reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While all reasonable efforts shall be made to safeguard your personal information, the Promoter cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of online communication and shall not hold the Promoter responsible for any breach of security unless such breach has been caused by the specific negligence of the Promoter.

WHAT RIGHTS DO YOU HAVE TO REVIEW AND AMEND YOUR PERSONAL INFORMATION?

You have the right to review and access the personal information relating to you held by the Promoter.

You also have the right to ask the Promoter to rectify, update, block, complete or delete your personal information, to restrict its use, or to ‘port’ your personal information (that is, to ask it to provide it to you in a structured, commonly used and machine readable format and/or to transmit it directly to another organisation).

In addition, you have the right to request further information regarding the handling of your personal information.

If you wish to do so, or to notify the Promoter of a change in your details, please contact the Promoter by email at win@acehighcompetitions.com and/or by post to Ace High Competitions, [PO Box [x]].

There are however certain exceptions to these rights. For example, access to personal information may be denied in some circumstances if making such information available would reveal personal information about another person, or if the Promoter is legally prevented from disclosing such information to you. In addition, the Promoter may be able to retain your personal information even if you withdraw your consent if it can be demonstrated that the Promoter has a legal requirement to process and store such information.

If you have any questions regarding the use or storage of your personal information, or wish to file a complaint about such, please contact the Promoter using the contact details set out above.

Finally, if you have concerns relating to the use or storage of your personal information which remain unresolved after contacting the Promoter, you retain the right to make a complaint to the relevant data protection authorities.

DURATION OF STORAGE OF YOUR PERSONAL INFORMATION

Any personal information held by the Promoter shall be stored for as long as is necessary (i) to fulfil the specific purposes for which your personal information was collected as set out in this Policy (or as otherwise notified to you from time to time) and (ii) to comply with the Promoter’s legal and regulatory obligations or to enforce its legal rights.

INFORMATION ABOUT THE PROMOTER’S USE OF COOKIES

The Promoter uses cookies for certain areas of the Website. Cookies are small text files that are used to store small pieces of information. They are stored on your device when the Website is loaded on your browser. These cookies help us make the Website function properly, make it more secure, provide better user experience, understand how the Website performs and analyse the performance of the Website and where it needs improvement. The Promoter may also use cookies for targeting and/or advertising purposes.

The Promoter may use Web beacons on the Website or in its e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of the Website and to tell if an e-mail has been opened and/or acted upon.

The Website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the Website to function properly, and they do not collect any of your personally identifiable data.

The third-party cookies used on the Website are mainly for understanding how the Website performs, how you interact with the Website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with the Website.

The Promoter only uses category D cookies as defined in the International Chamber of Commerce United Kingdom Cookie Guide.

The types and purposes of cookies used by the Promoter are set out below:

  • Essential: Some cookies are essential for you to be able to experience the full functionality of the Website. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your Account and add products to your basket, and checkout securely.
  • Statistics: These cookies store information like the number of visitors to the Website, the number of unique visitors, which pages of the Website have been visited, the source of the visit, etc. This data helps us understand and analyse how well the website performs and where it needs improvement.
  • Marketing: The Website displays advertisements. These cookies are used to personalise the advertisements that we show you so that they are meaningful to you. These cookies also help us keep track of the efficiency of these advertising campaigns. The information stored in these cookies may also be used by the third-party advertisement providers to show you advertisements on other websites on your browser as well.
  • Functional: These are the cookies that support certain non-essential functionalities on the Website. These functionalities include embedding content like videos or sharing content from the Website to social media platforms.
  • Preferences: These cookies help us store your settings and browsing preferences to enhance your experience of the Website.

COOKIE SETTINGS

The Promoter shall ask for your consent to the use of cookies as set out in this Policy when you first access the Website, and if it introduces any new cookies to the Website or to any other of its online services as the case may be.

If you agree to cookies from the Website (by clicking on the “Accept” button), the Promoter shall set cookies on your device.

If you do not agree to cookies from the Website (by clicking on the “Reject” button) or if you do not indicate your preference, the Promoter shall not set cookies on your device. Please note that if you do this you may not be able to benefit from the full functionality of the Website.

Should you decide to change your preferences later, you can click on the “Cookie settings” tab on your screen. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely.

You can usually choose to set your browser preferences to block or delete cookies. Different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more about how to manage and delete cookies, visit http://www.allaboutcookies.org/. Please note that if you choose to block or delete cookies, it may affect many features or services on the Website.

CHANGES TO THIS POLICY

The Promoter shall keep this Policy under regular review. This Policy may be amended from time to time by updating this page in order to reflect changes in the law and/or the privacy practices of the Promoter. The date at the top of this Policy shall be updated accordingly.

The Promoter encourages you to check the date of this Policy when you visit the Website or any other online services of the Promoter, as the case may be, for any updates or changes.

CONTACT DETAILS

If you have any questions about this Policy, please contact the Promoter by e-mail at win@acehighcompetitions.com, or by post to:

Ace High Competitions, [PO BOX XXXX………].