PRIVACY POLICY

THE DATA CONTROLLER

Who we are

Winners Warband is the trading name used by Winners Warband Ltd, company number 17346112, registered in England and Wales.

For UK data-protection purposes, we are the controller of personal information collected through the Winners Warband website, competitions, My Warband accounts, support services and related systems.

This policy is intended to reflect the UK General Data Protection Regulation, the Data Protection Act 2018 and applicable UK privacy and electronic-communications law, as amended from time to time.

THE INFORMATION WE GATHER

Personal information we collect

We do not generally seek sensitive personal information. Please do not send health, biometric or similarly sensitive information unless it is genuinely necessary. Where you provide it, we will only use it where a valid legal condition applies.

HOW IT REACHES THE WAR ROOM

How we collect information

• when you enter a competition or place an order;
• when you create or use a My Warband account;
• when you submit a free postal entry;
• when you contact support or make a complaint;
• when you subscribe to marketing;
• automatically through cookies and similar technologies;
• from WordPress, WooCommerce, payment providers and fraud-prevention tools;
• from delivery, fulfilment and prize-supply partners;
• from public sources where reasonably necessary to prevent fraud or confirm eligibility.

WHY WE USE YOUR INFORMATION

Purposes and lawful bases

Where we rely on legitimate interests, those interests include operating fair competitions, protecting customers and the business, preventing fraud, keeping accurate records and improving our services. We consider whether those interests are overridden by your rights and freedoms.

YOUR PLACE IN THE WARBAND

My Warband accounts and rewards

We process information needed to provide and secure My Warband, including order history, ticket numbers, Crowns, Renown, rank, store credit and reward activity.

We may correct reward records where an order is refunded, reversed, charged back, duplicated, fraudulent or otherwise ineligible under the applicable programme rules.

We may review account activity to protect your account, enforce competition and reward rules, and investigate suspected abuse. We do not intend to make decisions producing legal or similarly significant effects solely by automated means without appropriate safeguards.

SECURE TRANSACTIONS

Payments and financial information

Payments are processed by the provider shown during checkout and may also involve WooCommerce, banks, card networks and fraud-prevention services.

Winners Warband does not ordinarily receive or store your full card number, card-security code or full online-banking credentials. We may receive limited information such as payment status, transaction reference, card type, partial card digits, billing details, refunds, risk indicators and chargeback records.

MESSAGES FROM THE WARBAND

Service messages and marketing

Administrative messages

We may send messages necessary to manage an order, account, ticket allocation, draw, prize, reward, support request or security matter. These service messages are separate from marketing.

Marketing

We send electronic marketing only where permitted by applicable law, for example where you consented or where a lawful existing-customer exception applies.

You can unsubscribe through a marketing email or by contacting support@winnerswarband.co.uk. Opting out of marketing does not stop essential competition, order, account or security messages.

We may use Brevo or another email provider to send messages and maintain delivery, bounce, unsubscribe and suppression records.

RESPONSIBLE PARTICIPATION

Responsible play and account restrictions

We may use account, order and communication information to identify possible fraud, excessive participation, financial harm, loss of control, or a request for cooling-off, restriction or self-exclusion.

Where appropriate, we may contact you, restrict entries, suppress marketing, temporarily suspend an account or close an account in accordance with our Terms & Conditions and Responsible Play Policy.

Information about a self-exclusion or responsible-play restriction may be retained for as long as reasonably necessary to honour the restriction, prevent accidental reactivation, protect the individual and meet legal obligations.

Health or welfare information is handled with additional care and only where an appropriate legal condition applies.

TRUSTED ALLIES

Who we share information with

We do not sell personal information. We may share necessary information with:

• WordPress and WooCommerce, which support our storefront, checkout, orders and customer accounts;
• payment providers, banks, card networks and fraud-prevention services;
• Brevo or other email providers, for service messages and permitted marketing;
• Cloudflare, for DNS, website delivery, security, performance and email routing;
• 20i and other hosting providers, where they host Winners Warband, My Warband or connected systems;
• prize suppliers, couriers and fulfilment partners, to deliver prizes;
• professional advisers, including accountants, insurers, lawyers and security specialists;
• regulators, courts, law enforcement and public authorities, where legally required or justified;
• a genuine buyer, investor or successor during a business sale or reorganisation.

Winner information

To demonstrate that a genuine prize was awarded, we may publish or disclose limited winner information where required by law, advertising rules or the competition Terms. We aim to disclose only what is reasonably necessary, such as a first name, surname initial, general location, winning number, prize and draw date.

BEYOND THE REALM

International transfers

Some providers may process information outside the United Kingdom. Where information is transferred internationally, we seek to use a lawful transfer mechanism and appropriate safeguards.

These may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses or another mechanism permitted by law.

HOW LONG RECORDS REMAIN

Data retention

We keep information only for as long as reasonably necessary for the purpose for which it was collected, including contractual, tax, accounting, competition-integrity, fraud-prevention, responsible-play, complaint and legal requirements.

When information is no longer required, we will delete, anonymise or securely dispose of it where reasonably practicable.

YOUR RIGHTS

Your data-protection rights

• the right to be informed;
• the right to request access to your personal information;
• the right to correct inaccurate or incomplete information;
• the right to request erasure in certain circumstances;
• the right to request restriction of processing;
• the right to object to legitimate-interest processing;
• the right to object at any time to direct marketing;
• the right to data portability where applicable;
• the right to withdraw consent where consent is the basis;
• rights relating to certain automated decisions and profiling.

To exercise a right, email support@winnerswarband.co.uk. We may need to verify your identity. Rights are not absolute, and information may be retained or used where the law permits or requires it.

GUARDING THE GATES

How we protect information

We use reasonable technical and organisational safeguards designed to protect personal information against accidental loss, unauthorised access, misuse, alteration and disclosure.

Measures may include access controls, authentication, encryption in transit, trusted providers, backups, monitoring, software updates and restrictions on staff or contractor access.

No online system can be guaranteed completely secure. Protect your email account and devices, and contact us promptly if you suspect unauthorised access to My Warband.

RAISING A CONCERN

Questions and complaints

You may also complain to the Information Commissioner's Office, the UK's data-protection regulator:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113

THE LATEST DECREE

Changes to this policy

We may update this policy when our services, suppliers, laws or data practices change. The latest version will be published here with a revised update date.

Where a change is significant, we may provide an additional notice through the website, My Warband or email where appropriate.