Privacy Policy
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[i1]
FullSendComps respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we process and look after your personal data when you visit our website (regardless of where you visit it from).
[i2]
FullSendComps also tell you about your privacy rights and how the law protects you.
[i3]
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1
Important information and who we are
1.1
Purpose of this privacy policy
(a)
This privacy policy aims to give you information on how PVDraws Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase any products or services or take part in a prize draw or competition.
(b)
This website is not intended for children and we do not knowingly collect data relating to children.
(c)
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
(d)
In particular this document should be read in conjunction with our GDPR policy here.
1.2
Controller
(a)
PVDraws Ltd is the controller and responsible for your personal data (collectively referred to as "FullSendComps", "PVDraws Ltd", "we", "us" or "our" in this privacy policy).
(b)
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3
Contact details
(a)
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: PVDraws Ltd
Name of data privacy manager: Nicholas Hutchins
Email Address: data@fullsendcomps.com
Postal Address: FullSendComps, PVDraws Ltd, Unit A, 82 James
Carter Road, Mildenhall, Suffolk, IP28 7DE
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.4
Changes to the privacy policy and your duty to inform us of changes
(a)
We keep our privacy policy under regular review. This version was last updated on 26-01-2024
(b)
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2
The data we collect about you
2.1
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a)
Identity Data includes first name, last name, title, and date of birth
(b)
Contact Data includes billing address, delivery address, email address and telephone numbers.
(c)
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
(d)
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
(e)
Profile Data includes Profile Data includes your hashed password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(f)
Usage Data includes information about how you use our website, products and services.
(g)
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
2.3
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
2.4
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.5
We may collect the minimum amount of personal data to enable you to enter into any prize draw and competition and allow us to run the promotion. If you are a winner, it may be necessary to collect more detailed information from you in order to award your prize to you. You will be notified of this at the time we notify you if you have won.
2.6
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or to enter you into a competition). In this case, we may have to cancel a product or service you have with us or refuse your entry to a competition. We will notify you if this is the case at the time.
3
How is your personal data collected?
3.1
We use different methods to collect data from and about you including through:
(a)
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
i
create an account on our website;
ii
purchase any competition tickets or merchandise;
iii
subscribe to our service or publications;
iv
request marketing to be sent to you;
v
enter a competition, promotion or survey; or
vi
give us feedback or contact us.
(b)
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy here for further details.
(c)
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
i
Technical Data from the following parties:
1
analytics providers such as Google based outside the UK;
2
advertising networks such as Facebook and Google based outside the UK and
3
fraud prevention providers such as MaxMind based outside the UK.
ii
Contact and Transaction Data from providers of technical, payment and delivery services such as Paypal and Cashflows based both inside and outside the UK.
iii
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4
How we use your personal data
4.1
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a)
Where we need to perform the contract we are about to enter into or have entered into with you. (A legally binding contract is formed between us when you purchase goods or services from us or you enter into a competition.)
(b)
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(c)
Where we need to comply with a legal obligation.
4.2
To find out more about the types of lawful basis that we will rely on to process your personal data, please see the Glossary below.
4.3
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
4.4
Purposes for which we will use your personal data
(a)
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
(b)
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
(c)
(b) Contact
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(b) Contact
(c) Transaction
(d) Marketing and Communications
(b) Necessary for our legitimate interests (to recover debts due to us)
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(b) Contact
(c) Profile
(d) Marketing and Communications
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
(b) Contact
(c) Technical
(b) Necessary to comply with a legal obligation
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(b) Usage
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(d)
If you are the winner of the competition you will be invited to participate in publicity exercises relating to the competition. Your participation is not compulsory but would be greatly appreciated by us. If you do not wish to participate your participation in the competition or chances of winning will not be affected in any way.
(e)
However, if you do not wish to participate in any publicity and decline to be named as the winner, we may still have to provide your details to the Advertising Standards Authority (ASA) as proof that the competition has been properly administered and the prize awarded. This is a legal requirement we must comply with. If you require detail of how the ASA will use and process your personal data, please let us know.
4.5
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.6
Promotional offers from us
(a)
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
(b)
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, entered a competition or prize draw and you have not opted out of receiving that marketing.
4.7
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.8
Opting out
(a)
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
(b)
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
4.9
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.
4.10
Change of purpose
(a)
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
(b)
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
(c)
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5
Disclosures of your personal data
5.1
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
(a)
External Third Parties as set out in the Glossary.
(b)
Specific third parties listed in the table “Purposes for which we will use your personal data” above.
(c)
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
5.2
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6
International transfers
6.1
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
6.2
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a)
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b)
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
6.3
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7
Data Security
7.1
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8
Data retention - How long will you use my personal data for?
8.1
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
8.2
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8.3
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.
8.4
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
8.5
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9
Your legal rights
9.1
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
9.2
If you wish to exercise any of these rights, please contact us.
9.3
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
9.4
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.5
Time limit to respond
We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10
Glossary
10.1
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
10.2
Third Parties External Third Parties
(a)
Service providers acting as processors based in both in the and outside of the United Kingdom who provide web hosting, database and data storage facilities, and other technical infrastructure services.
(b)
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in in the United Kingdom who provide consultancy, banking, legal, insurance accounting and payment services.
(c)
HM Revenue & Customs, regulators and other authorities such as the Advertising Standards Authority acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(d)
Fraud Prevention Services such as Maxmind based outside of the United Kingdom.
11
Your Legal Rights and GDPR.
Nothing in this privacy policy disables, adjusts or overrides your rights as defined by the UK GDPR regulations. You have several rights under GDPR such as the the right to be informed, the right to access, the right to rectification, the right to erasure, the right to restriction, the right to data portability, the right to object and other rights surrounding automated decision making. More information about these can be found on our GDPR page here. However excercising any of these rights may result in our restricted ability to provide service to you. Please bear this in mind when making any request.