1. INTRODUCTION

1.1. Our Commitment SWAG GIVEAWAYS LTD (“we,” “us,” “our”) is committed to safeguarding your personal information. This Privacy Policy explains how we collect, use, and protect your data when you visit swagcompetitions.com (the “Website”) or participate in our competitions.

1.2. Controller Details Data Controller: SWAG GIVEAWAYS LTD (Company No.16638904) Registered Office: 23a George Street, Luton, England, LU1 2AF. Email: contact@swagcompetitions.com Phone: +447391670954 1.3. Scope This Policy applies to personal data we process about Website visitors, registered users, and competition entrants. By using our services, you acknowledge that you have read this Privacy Policy.

2. DATA WE COLLECT

We collect personal data in two main ways:

2.1. Information You Provide Direct

2.1.1. Identity Data: Name, surname, login details.

2.1.2. Contact Data: Email address, phone number, mailing address.

2.1.3. Financial Data: Payment card details (where applicable) and transaction history.

2.1.4. Profile Data: Marketing preferences, feedback, reviews, or competition entries.

2.2. Automatically Collected Data

2.2.1. Usage Data: How you navigate and interact with our Website (pages visited, time on site).

2.2.2. Technical Data: IP address, browser type and version, device identifiers, operating system, and system configuration details.

2.3. How We Use Your Data We only process personal data if we have a lawful basis. Common uses include:

2.3.1. User Registration & Account Management Purpose: To create and manage your account, authenticate login, and maintain user preferences. Legal Basis: Performance of a Contract (UK GDPR Art. 6(1)(b)).

2.3.2. Competitions & Prize Fulfilment Purpose: To facilitate competition entry, determine winners, and deliver prizes. Legal Basis: Performance of a Contract (Art. 6(1)(b)) and Legal Obligation (Art. 6(1)(c)) where relevant.

2.3.3. Payment Processing Purpose: To handle entry fee transactions securely. Legal Basis: Performance of a Contract (Art. 6(1)(b)).

2.3.4. Service Notifications & Customer Support Purpose: To provide updates on competition status, respond to inquiries, and send administrative emails (e.g., changes to T&Cs). Legal Basis: Performance of a Contract (Art. 6(1)(b)) and/or Legitimate Interests (Art. 6(1)(f)).

2.3.5. Internal Administration & Legal Compliance Purpose: To perform internal audits, detect fraud, ensure compliance with applicable laws. Legal Basis: Legal Obligation (Art. 6(1)(c)) and Legitimate Interests (Art. 6(1)(f)).

2.3.6. Personalization & Analytics Purpose: To improve user experience, analyze usage trends, and tailor content. Legal Basis: Legitimate Interests (Art. 6(1)(f)). Where cookies are involved, we obtain consent in accordance with ePrivacy rules.

2.3.7. Marketing Purpose: If you opt in, to send promotional messages about our competitions or new services. Legal Basis: Consent (Art. 6(1)(a)) or Soft Opt-In (where applicable under PECR), with the right to opt out at any time.

3. HOW WE PROTECT YOUR DATA

3.1. Security Measures We implement industry-standard measures, including SSL encryption, secure data centers, and role-based access controls. Our staff receive data protection training to ensure confidentiality.

3.2. Incident Response We have procedures to handle any personal data breach. Where legally required, we will notify you and the relevant regulator (e.g., the ICO).

4. DATA SHARING

4.1. Third-Party Service Providers We may share your personal data with trusted suppliers who assist us in running our business (e.g., payment gateways, email marketing platforms, web hosts). They act under confidentiality agreements and only process data per our instructions.

4.2. Legal Requirements We may disclose personal data to comply with legal obligations or respond to valid requests from public authorities (e.g., law enforcement).

4.3. No Third-Party Marketing We do not sell or rent your personal data to external parties for their marketing purposes.

5. INTERNATIONAL DATA TRANSFERS

5.1. Transferring Data Outside the UK/EEA Where we must transfer data to a country outside the UK or EEA without an adequacy decision, we rely on Standard Contractual Clauses or equivalent safeguards to ensure your data is protected.

5.2. Further Information You may contact us at contact@swagcompetitions.com if you would like details of the specific safeguards we use.

6. DATA RETENTION

6.1. Retention Period We retain personal data for as long as you maintain an active account or as necessary to comply with legal obligations (e.g., tax, accounting, or regulatory requirements). Typically, competition records are kept for up to 6 years to handle any disputes or regulatory inquiries.

6.2. Account Closure If you request account deletion, we will erase or anonymize your data within a reasonable timeframe unless further retention is required by law.

7. YOUR RIGHTS

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

7.1.1. Access: Request a copy of your personal data.

7.1.2. Correction: Ask us to rectify any inaccurate or incomplete data.

7.1.3. Erasure: Request deletion of data when it’s no longer needed or if processing is unlawful.

7.1.4. Restriction: Ask us to stop processing in certain circumstances.

7.1.5. Portability: Obtain a machine-readable copy of data you provided if processing is based on consent or contract.

7.1.6. Objection: Object to processing based on legitimate interests, or direct marketing.

7.1.7. Withdraw Consent: Where we rely on consent, you can withdraw it at any time. To exercise these rights, email us at contact@swagcompetitions.com.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe we have not complied with your data protection rights.

8. MARKETING & PRIZE PROMOTIONS

8.1. Photo and Prize Details By entering our competitions, you acknowledge that we may publish your first name, initial of surname, and general location (e.g., county) to announce winners. This is based on legitimate interests in running transparent promotions. For broader marketing use of your name, photo, or prize details (e.g., social media posts, website banners), we will either:

8.1.1. Obtain your explicit consent,

or

8.1.2. State in the Competition Official Rules that publicity is a condition of certain high-value prizes.

8.2. Promotional Communications We may send email or WhatsApp marketing if you opt in or if you have previously purchased or participated and have not opted out (soft opt-in). You can unsubscribe at any time by following the link in our emails or contacting us.

9. CHANGES TO THIS PRIVACY POLICY

9.1. We may update this Policy from time to time. The “Last Updated” date at the top indicates when changes were last made.

9.2. Material changes will be posted prominently on the Website and, where appropriate, notified via email or user account alerts.

10. CONTACT US

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:

Email: contact@swagcompetitions.com

SWAG GIVEAWAYS LTD, 23a George Street, Luton, England, LU1 2AF

Phone: +447391670954

We aim to respond to any request or inquiry promptly, usually within one month.

11. CHILDREN’S PRIVACY

We do not knowingly collect personal data from individuals under 18. If you believe a child under 18 has provided us with personal data, please contact us and we will take steps to delete it.

Thank you for reading our Privacy Policy. We value your trust and are continuously working to keep your personal data secure and handled in accordance with UK GDPR and applicable laws.