Privacy Policy

C LEE PROMOTIONS – WEBSITE PRIVACY POLICY

C Lee Promotions is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy). 

This privacy policy gives you information about how C Lee Promotions collects and uses your personal data through your use of this website or your participation in any prize draw.

This website is not intended for children and we do not knowingly collect data relating to children.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us via social media by sending a direct message to the Facebook account under the name C Lee Promotions LTD, or by writing to us at Free Post C Lee Promotions Ltd, 9 Aspen Close, Walesby, Newark, Nottinghamshire, NG22 9WA.

The Types of Personal Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier such as the name on your Facebook profile, and date of birth

• Contact Data includes delivery address, email address and telephone numbers

• Transaction Data includes details about payments from youin relation to the prize draws.

• 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, device ID and other technology on the devices you use to access this website.

• Usage Data includes information about how you interact with and use our website, products and services.

• Communications Data includes your communication preferences.

How Is Your Personal Data Collected?

We collect your personal data directly from you when you correspond with us by post, email, phone or via social media. This includes personal data you provide when you enter a prize draw or give us feedback or contact us. 

How We Use Your Personal Data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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)

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use the various categories of 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.

• To list you as a participant in a prize draw, we collect your identity and contact data. The legal basis for this processing is the performance of a contract with you. 

• To manage our relationship with you which will include notifying you about changes to our terms or privacy policy and dealing any requests, complaints and queries, we collect your identity, contact and communications data. The legal basis for this processing is the performance of a contract with you, it is necessary to comply with a legal obligation and it is necessary for our legitimate interests (to keep our records updated and manage our relationship with you). 

• To enable you to partake in a prize draw, we collect your identity, contact and communications data. The legal basis for this processing is the performance of a contract with you and it is necessary for our legitimate interests (to study how customers use our services and to develop them and grow our business).

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see [LINK TO COOKIE POLICY].

Disclosures of Your Personal Data

We do not share your personal data with any third parties.

Data Security

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. 

Data Retention

How long will you use my personal data for?

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. 

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.

Usually, this means we will delete any personal data we hold about you after the prize draw you entered has taken place, and the winner has taken possession of the prize. However, 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.

Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

• If you want us to establish the data’s accuracy;

• Where our use of the data is unlawful but you do not want us to erase it;

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us. 

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.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular review. 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, for example a new address or email address.

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.

12