Privacy Policy

2.1 Personal Information You Provide

When you enter our competitions or interact with our services, we collect:

• Contact Information: Name, email address, phone number, postal address
• Demographic Information: Date of birth, gender
• Competition Entries: Entry form data, preferences, and responses
• Communication Records: Customer service interactions, feedback, and enquiries

2.2 Information We Collect Automatically

• Technical Data: IP address, browser type, device information, operating system, Internet Service Provider (ISP), local time, and location data
• Usage Data: Pages visited, time spent on site, click patterns, referral sources
• Cookies and Tracking: See our Cookie Policy section below for detailed information on how we use cookies and similar technologies

2.3 Information from Third Parties

We may receive information from:

• Social media platforms (if you choose to connect your accounts)
• Marketing partners and affiliates for promotional purposes (with your consent)
• Public databases and directories for verification and fraud prevention
• Identity verification partners to ensure the security of your data

3.1 Legal Basis for Processing

We process your personal data based on the following legal grounds under UK GDPR:

• Contract Performance: To administer competitions and deliver prizes
• Legitimate Interest: To improve our services and prevent fraud
• Consent: For marketing communications (where you have opted in)
• Legal Obligation: To comply with applicable UK laws and regulations

3.2 Purposes of Processing and Lawful Basis

Under UK GDPR, you have the following rights regarding your personal data:

• 🔍 Right of Access — Request a copy of the personal data we hold about you.
• ✏️ Right to Rectification — Request correction of inaccurate or incomplete data.
• 🗑️ Right to Erasure — Request deletion of your personal data in certain circumstances.
• ⏸️ Right to Restrict Processing — Request limitation of how we process your data.
• 📤 Right to Data Portability — Request transfer of your data to another organisation.
• ❌ Right to Object — Object to processing based on legitimate interests or for marketing.

4.1 Exercising Your Rights

To exercise any of these rights, please contact us at contact@winwined.com. We will respond within one month of receiving your request. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe we have not handled your data properly.

5.1 When We Share Your Data

We may share your personal information with:

• Service Providers: Third-party companies that help us operate our competitions (e.g., prize fulfilment, email services)
• Legal Authorities: When required by law or to protect our legal rights
• Business Transfers: In the event of a merger, acquisition, or sale of assets
• Marketing Partners: Only with your explicit consent for promotional purposes across various sectors including Retail, Automotive, Lifestyle, Charity, Utility, Telecommunications, Insurance, Media, Entertainment, Financial Services, Travel, Health/Beauty, and more

5.2 Sharing with Identity Verification Partners

We may share your personal information on the basis of legitimate interests with FIOR, an identity verification organisation, to help verify your identity, stop others from misusing your data, and prevent fraud. This data will be processed securely and will not be shared beyond verification purposes. You can object to this processing and request removal of your data by emailing: contact@fiordata.com

5.3 Sharing with Marketing Service Providers

We may share your data with Marketing Service Providers who use it for direct marketing, research, and product development purposes. These providers may combine your data with information from other sources (including public data) to create predictive models for behaviour and preferences, enhancing the relevance of marketing communications. For a list of these providers and to exercise your data protection rights, including opting out, please refer to our detailed partner list on our website or contact us directly.

5.4 International Transfers

Your data may be transferred to and processed in countries outside the UK. When this happens, we ensure appropriate safeguards are in place, including:

• Adequacy decisions by the UK government recognising certain countries as providing an adequate level of data protection
• Standard contractual clauses approved by the ICO to ensure data protection standards are met
• Binding corporate rules or certification schemes to guarantee consistent data protection across international operations

6.1 Security Measures

We implement appropriate technical and organisational measures to protect your personal data against loss, theft, misuse, unauthorised access, transmission, amendment, and destruction, including:

• SSL encryption for data transmission with 128-bit encoded security
• Secure servers and databases located in controlled environments
• Access controls and authentication with individual passwords and employee authorisation
• Regular security assessments, updates, and virus protection programs
• Staff training on data protection and supervision by data protection officers
• Entry and admission controls ensuring secure access to data facilities
• Backup systems and nightly mirroring to ensure data availability and recovery

Despite these precautions, due to the inherent insecurity of the Internet, we cannot guarantee the security of data transmission to our website. Any transmission is undertaken at your own risk.

6.2 Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy:

• Competition Data: 7 years after competition ends (for legal and tax purposes)
• Marketing Data: Until you unsubscribe or withdraw consent, or for a maximum of 4 years if no further interaction occurs
• Customer Service Records: 3 years after last contact
• Website Analytics: 26 months maximum

Following withdrawal of consent or objection, your data will be moved to a blocking list, used only for legal purposes (e.g., burden of proof), and deleted after 4 years unless compelling reasons or renewed consent dictate otherwise.

7.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. We use cookies to improve your experience and analyse website usage.

7.2 Types of Cookies We Use

• Essential Cookies: Required for website functionality (cannot be disabled)
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used to deliver relevant advertisements (with your consent)

7.3 Managing Cookies

You can control cookies through your browser settings or our cookie consent banner. Note that disabling certain cookies may affect website functionality.

8.1 Opt-in Consent

We will only send you marketing emails if you have explicitly opted in during registration or through our website. Marketing communications include:

• Information about new competitions
• Special offers and promotions
• Company news and updates

8.2 Unsubscribing

You can unsubscribe from marketing communications at any time by:

• Clicking the unsubscribe link in any email
• Contacting us at contact@winwined.com
• Updating your preferences on our website

Our competitions are only open to individuals aged 18 and over. We do not knowingly collect personal information from children under 18. If we become aware that we have collected data from a child, we will delete it immediately.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. When we make material changes, we will:

• Post the updated policy on our website
• Update the "Last Updated" date
• Notify you by email if the changes significantly affect your rights

We encourage you to review this policy periodically to stay informed about how we protect your information.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Tadads Limited
Email: contact@winwined.com
Address: UNIT B 11/F, Yam Tze Commercial Building, 23 Thomson Road, Wan Chai, Hong Kong

11.1 Regulatory Authority

If you are not satisfied with our response to your data protection concerns, you can lodge a complaint with:

Information Commissioner's Office (ICO)
Website: https://ico.org.uk/
Phone: 0303 123 1113