At GoldenDraw, we are committed to protecting the privacy and security of our customers and site visitors. We understand the trust you place in our business when you provide us with personal information. Our Privacy Policy sets out our privacy promise to you. We do not share your data with third parties for them to market their products/services to you. If you have any questions about how we Protect Your Privacy, please contact us at info@goldendraw.com.
Goldendraw.com is the website of Goldendraw Limited
When you interact with us through our website (or otherwise) you may provide, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data). For the purposes of the General Data Protection Regulation or “GDPR” (and all other laws relating to the use your personal data), we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate reasons.
We are committed to protecting your privacy and will take all steps necessary to comply with our legal obligations when using your personal data. This Privacy Policy explains how we fulfil this commitment, so please read this carefully.
WHAT THIS POLICY TELLS YOU
- What types of personal data you provide to us (or which we collect from you) when using our website or when you directly interact with us on other occasions;
- How and why we use this data and the reasons we are legally allowed to do so;
- Who we share your data with;
- Your rights over your data and how you can exercise those rights; and
- How to contact us if you have any issues or want to find out more.
WHAT INFORMATION DO WE COLLECT AND WHAT DO WE USE IT FOR
You may provide us with the following types of personal information when you register with Goldendraw or otherwise when you directly interact with us (when using our website or otherwise):
- Identity– first name, surname, Goldendraw log-in information (password), country of residence
- Contact– email address, telephone numbers and address
- Financial– payment card details, billing address, purchase information, payment history
- Profile– your preferences for marketing, other website preferences and feedback on your Goldendraw experiences through reviews and surveys
- Social– if you choose to open a Goldendraw account using your Facebook, Twitter or Google account, we will use your contact information used for the relevant account to help populate your Goldendraw registration page
We may collect the following types of information from you when you use our website (using Cookies or other tracking technologies):
- Usage– information about how you use our website, including time spent on page, click-throughs, download errors
- Technical– IP address, browser type, hardware type, network and software identifiers, device information, operating system and system configuration
The table below sets out how we use your personal data and our lawful basis for doing so. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using it. Importantly, we will only use your personal data when the law allows us to.
| Reason why we use the data | What data | Legal ground for using the data |
| Register you as a Goldendraw customer | Identity, Contact, Profile, Social | Performance of a contract with you |
| Enable you to log-in to your Goldendraw account | Identity, Contact, Social | Performance of a contract with you |
| Enable you to participate in aGoldendraw competition | Identity, Contact, Financial, Surprise | Performance of a contract with you |
| To process payments which you make through our website | Identity, Contact, Financial | Performance of a contract with you |
| Arrange for the delivery of your prize if you have won a competition | Identity, Contact, Surprise | Performance of a contract with you |
| For internal administration and record keeping purposes | All |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (for effective business administration and service provision) |
| Notify you of changes to our Privacy Policy, our Terms and Conditions or other changes to our services or products | Identity, Contact |
Performance of a contract with you Necessary to comply with a legal obligation |
| Answer your enquiries which may involve contacting you by post, e-mail or phone | Identity, Contact |
Performance of a contract with you Necessary for our legitimate interests (to ensure our customers are informed and satisfied with our services) |
| Get in touch with you about relevant Goldendraw competitions, products and services | Identity, Contact, Profile |
Necessary for our legitimate interests (to develop our business, including our competitions, products and services) Consent |
| Contact you about third party products and services which we believe may be relevant to you or pass your details on to third parties to contact you directly about the same (in each case, only where you have indicated you would like to hear about these) | Identity, Contact, Profile | Consent |
| Improve and personalise your experience of the Goldendraw website by delivering more relevant content and advertising whilst you browse | Identity, Contact, Profile, Usage, Technical | Necessary for our legitimate interests (to develop our business, improve our website and overall user experience and inform our marketing strategy) |
| Administer the Goldendraw website, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our website | All |
Performance of a contract with you Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you) |
| Verify your identity and detect fraud and security issues | All | Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity) |
| Give you the opportunity to provide us with feedback through reviews and surveys | Identity, Contact, Profile, Usage, Technical | Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers to improve our services) |
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 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
Importantly, we do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent.
We do however share your personal data with third parties to help us deliver our products and services to you in the most effective way possible. These include third parties who assist us with:
In addition to the above, we may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.
We adopt industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. By way of example, we use secure server software (EV SSL) which encrypts all information you input before it is sent to us. We also make sure that third parties who need to handle your data when helping us to deliver our services are subject to suitable confidentiality and security standards.
Despite the security measures we implement, please be aware that the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
Our website may contain links to enable you to visit other websites easily. However, once you have used these links to leave our website we do not have any control over these third party websites and are not responsible for the protection and privacy of any information which you provide whilst visiting such sites. Your use of these third party sites are not governed by this Privacy Policy. You should exercise caution and examine the privacy policies and terms of use applicable to the web sites in question.
If you want to exercise any of these rights, please Contact Us. You don’t have to pay a fee to exercise your rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances. Where your request is legitimate, we will always respond within one month (unless there is a legal reason to take longer, such as where your request is particularly complex). We may also need you to confirm your identity before we proceed with your request if it is not clear to us who is making the request.
In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.
We do not pass your data onto any third parties for their marketing purposes. However, if we ever wish to do so in the future we will always get your consent. You can then opt-out from any third party marketing at anytime following the same process as above.