When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
It would be helpful to start by explaining some key terms used in this policy:
|we, us, our||Marty Pumbien|
|Personal data||Any information relating to an identified or identifiable individual|
|Special category personal data||Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership|
Genetic and biometric data
Data concerning health, sex life or sexual orientation
Personal data we collect about you
Personal data we will collect:
Your name and postal address
Electronic contact details, e.g. your email address and mobile phone number
Information included in your competition entry
This personal data is required to enable us to enter your details into the Win a House competition on our website (the Competition). If you do not provide personal data we ask for you cannot enter the Competition.
How your personal data is collected
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so. In this case the reason is so that we can process your entry into the Competition and to administer the Competition in accordance with the Competition Terms and Conditions. By entering into the Competition you consent to our use of your personal data in this way.
We do not collect special category personal data.
We may use your personal data to send you updates (by email, text message, telephone or post) about the Competition.
We have a legitimate interest in processing your personal data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us – see below: ‘How to contact us’
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share your personal data with
In connection with the Competition we will share personal data with:
- our professional advisers; and
- third parties who collect, monitor and analyse data on our behalf in connection with the competition;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We will not share your personal data with any other third party.
Where your personal data is held
Information may be held on our servers and those of our advisors and service providers as described above (see ‘Who we share your personal data with’).
How long your personal data will be kept
We will keep your personal data for up to 12 months after the Competition closes. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
We will not transfer your personal data outside of the EEA.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:|
– at any time to your personal data being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us —see below: ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name and address);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
How to contact us
Our contact details are shown below:
Post: 26 Abington Park Crescent, Northampton NN3 3AD, UK