PRIVACY POLICY
OUR PRIVACY POLICY
Welcome to Yaldi Competitions and our website www.yaldicompetitions.co.uk. This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the web sites, functions and content associated with it, as well as external online presences, such as our social media profiles. (collectively our “online offer” and “Yaldi Competitions”).
General Information
The Controller
The responsible entity in accordance with the UK’s Data Protection Act (DPA) and the General Data Protection Regulation (GDPR) is:
Yaldi Competitions Ltd
Technology House, 9 Newton Place,
Glasgow, Scotland, G3 7PR
Company number SC696751
(hereinafter also referred to as “we” or “us”).
You can reach us at hello@yaldicompetitions.co.uk, our postal address or on 0141 248 7676
Definitions
This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum to make sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. However, to achieve this objective we would like to explain you the following two concepts.
Personal Data
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Relevant legal basis
In accordance with the DPA the GDPR, we inform you of the legal basis for our data processing.
Consent
This is where we have asked you to provide explicit permission to process your data for a particular purpose.
Contract
This is where we process your information to fulfil a contractual arrangement we have made with you.
Answering your business enquiries
This is where we process your information to reply to your messages, e-mails, posts, calls, etc.
Legitimate Interests
This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
Legal Obligation
This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime.
Your Rights
You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them. There is more information on each right on the Information Commissioners (ICO) website and you can simply follow the links provided to learn more.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information. You do however also have the right to lodge a complaint directly with the ICO, their contact details can be found on their website.
Please direct all requests for information, requests of information or objections to data processing to us.
Obligation to provide the data
As a rule, the provision of your data is not obligatory. Only in the context of concluding a contract do you have to provide certain data. Without this data, we will otherwise not be able to conclude or execute the contract with you.
Passing on data to third parties
We will only pass on your data to third parties if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in passing on the data or if we have your consent to do so. In addition, data may be passed on to third parties if we are obliged to do so by law or by an enforceable official or court order.
Service providers
We sometimes use service providers for the processing of data. The access of service providers to your data is limited to the necessary extent. Service providers are usually integrated as so-called order processors who may only process data according to our instructions.
Transfer of data to non-EEA countries
Data may also be transferred to third parties or processors based in non-EEA countries. In this case, we ensure that the recipient has an appropriate level of data protection before transferring the data. We have concluded so-called standard contractual clauses with various companies. Further information on this is available from our data protection officer on request.
Duration of storage
We store your data for as long as is necessary for the provision of our online offer and the associated services or for as long as we have a legitimate interest in continuing to store it. In all other cases, we delete your personal data with the exception of such data that we must continue to retain in order to comply with statutory (e.g. tax or commercial) retention periods (e.g. invoices).
Pseudonymous data processing
The data processing listed below is essentially carried out on a pseudonymous basis. This means that we or third parties cannot assign the data to you directly, e.g. via a name or an e-mail address, but a profile is created, e.g. using an ID or a cookie.
Data processing by us when using our offers
User account and registration for Competitions
It is also possible for you to register an account. For this purpose, you will need to provide us with the following: Username, Email address and Password. Providing those will enable you to log in more easily without having to enter your data again when you use our services next. We store the data you enter to set up a customer account. We will hold your data for further orders as long as you maintain your registration. You have the right to access, correct or delete your registration data at any time.
Entering Competitions
When you place an order to enter in our competitions, we store the following information in order to fulfil the contract concluded between you and us or to carry out pre-contractual measures.
Online Payment, Secure data transmission and Credit card information
The transmission of your personal information during an order transaction is encrypted using industry standard Secure Socket Layer (“SSL”) technology, (SSL encryption version 3). Any credit card information you provide will not be stored by us, but will be encrypted and collected directly from our payment service provider via hypertext transfer protocol secure (“https”).
We may share information with our payment service provider, and you may need to provide credit or debit card information directly to the provider in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to our payment service provider’s own Privacy Notice and Terms and Conditions.
Newsletter
We send newsletters, e-mails and other electronic notifications with promotional information and only with the consent of the recipients or a legal permission. Apart from that, our newsletters contain information about our products, offers, promotions. Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address.
Processing of data that you provide to us via contact forms or by email.
You have the option of contacting us via various channels for different purposes (e.g. enquiries about products and programmes, as well as support). We use the data you provide in this way solely to process your request. It will be deleted after it has been processed, unless it is necessary to keep it for other reasons.
Communication by mail, e-mail, or telephone
We use means of distance communication, such as post, phone or e-mail, for business and marketing purposes as well as notifications abut our competitions, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
The processing is based on the performance of a contract when notifying the winners of competitions and in case of advertisement and marketing based on our legitimate interest in connection with legal requirements for advertising communications. Contact shall only be established with the consent of the contact partners or within the scope of the statutory permissions and the processed data shall be deleted as soon as they are not required and otherwise with objection/ revocation or discontinuation of the basis for authorisation or statutory archiving obligations.
Online presences in social media
We maintain online presences in Facebook, Instagram and Twitter on the basis of our legitimate interests and in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Social Media Functions and Widgets
Within our online offer, functions and widgets of Facebook, Instagram and Twitter are integrated. When you click on or use any of those functions and widgets, your browser establishes a direct connection to Facebook, Instagram and Twitter. The function or widget then transmits log data to Facebook, Instagram and Twitter. This log data may contain your IP address, the address of the visited websites, type and settings of the browser, date and time of the request, your usage of Facebook, Instagram and Twitter ,as well as cookies. Those may also include the display of our post, the link to our profile, the possibility to interact with the posts and functions, as well as to measure users reach (so-called conversion measurement).
Google Re/Marketing Services
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer we use the marketing and re-marketing services of Google.
Google’s marketing services allow us to target advertisements for and on our website in order to present users only with ads that potentially match their interests. For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the web site. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which web sites the user has visited, which content he or she is interested in and which offers he or she has clicked on, as well as technical information on the browser and operating system, referring web sites, time of visit and other information on the use of the online offer.
The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened and only in exceptional cases is transmitted in full to a Google server and shortened there. The IP address will not be merged with user data within other Google offerings. The aforementioned information may also be combined by Google with such information from other sources. If the user subsequently visits other web sites, he or she may be shown ads tailored to his or her interests.
The user’s data is processed pseudonymously as part of Google’s marketing services. This means that Google does not store and process the name or email address of the user, for example, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. I.e. from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected about users by Google marketing services is transmitted to Google and stored on Google’s servers.
Facebook Pixel, Custom Audiences and Facebook Conversion
Within our online offer, the so-called “Facebook pixel” of the social network Facebook is used due to our legitimate interests in the analysis, optimisation and economic operation of our online offer and for these purposes.
With the help of the Facebook pixel, it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the web sites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”).
Transfers to third countries
If we process data in a third country (i.e. outside the UK) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with the DPA the GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
Changes
This policy and our commitment to protecting the privacy of your personal data can result in changes to this policy. Please regularly review this policy to keep up to date with any changes.
Queries and Complaints
Any comments or queries on this policy should be directed to us. If you believe that we have not complied with this policy or acted otherwise than in accordance with data protection law, then you should notify us.