Ooosch Privacy Policy

Changes to the Privacy Policy This Privacy Policy was last updated on 03 February 2025.

1. Introduction: Important information and who the Promoter is Welcome to the Ooosch Limited (the 'Promoter', or ‘Ooosch’) privacy policy.

Ooosch respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how the Promoter looks after your personal data when you visit the Promoter’s website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Purpose of this privacy policy

This privacy policy aims to give you information on how Ooosch 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 the Promoter’s newsletter or when you register and create a profile; enter a competition; take part in a survey; win a competition; or take part in an event.

This website is not intended for children and the Promoter does not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy. The Promoter may provide on specific occasions when the Promoter is collecting or processing personal data about you so that you are fully aware of how and why the Promoter is using your data. This privacy policy supplements other notices and policies and is not intended to override them.

2.1. Controller This privacy policy is issued on behalf of the Promoter. When it is mentioned Ooosch, the Promoter, "we", "us" or "our" in this privacy policy, it refers to Ooosch Limited, who is responsible for processing your data. Ooosch Limited is the controller and is responsible for this website. The Promoter has appointed a Data Protection Officer (DPO) 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 DPO using the details set out below.

2.2. Contact details If you have any questions about this privacy policy or the Promoter’s privacy practices, please contact the DPO at this email address: [email protected].

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 (https://www.ico.org.uk/), or the data protection regulator in the country where you usually live or work, or where the alleged data protection infringement has taken place. The Promoter would, however, appreciate the chance to deal with your concerns before you approach the ICO or the applicable data protection regulator so please contact the Promoter in the first instance.

2.3. Changes to the privacy policy and your duty to inform us of changes The Promoter keeps its privacy policy under regular review to ensure compliance with current processing activities and legal obligations. It is important that the personal data the Promoter holds about you is accurate and current. Please keep the Promoter informed if your personal data changes during your relationship with the Promoter and your data can be updated by logging onto your account and making amends in the account details page.

3. 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. The Promoter does not control these third-party websites and is not responsible for their privacy statements.

4. The data collected about you 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).

The Promoter may collect, use, store and transfer different kinds of personal data about you which the Promoter has grouped together as follows:

• Identity Data includes first name, last name, or similar identifier;
• Contact Data includes full address, email address and telephone number;
• Technical Data includes internet protocol (IP) address, 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;
• Usage Data includes information about how you use the Promoter’s website;
• Marketing and Communications Data includes your preferences in receiving marketing from the Promoter and your communication preferences;
• Copies of documents you provide to prove your identity (including driving licence and passport) when you are claiming a prize, or where there is a legal reason to request this from you.
• Transaction details including a record of payments made by you and to you (for example prizes), ticket details of Ooosch’s competition entries and the outcomes of the competitions.
• Video footage and photographs of yourself with your prize when contributing to Ooosch’s advertising and/or media content, when completing the contributor’s consent.
• Financial information including your payment card account number and sort code when playing by direct debit. When you make a payment (to enter a competition) your payment card information will be collected, processed securely and separately by a payment processor. The payment processor provides the Promoter with only the last four digits of your card number, your card expiry date and a unique token to represent your card. The Promoter does not store your full payment details and does not have access to the full payment details.
• The Promoter also collects, uses and shares 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, the Promoter may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if the Promoter combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, the Promoter treats the combined data as personal data which will be used in accordance with this Privacy Policy.
• The Promoter does 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 (apart from biometric data)). Nor does the Promoter collect any information about criminal convictions and offences.

4.1. How is your personal data collected? The Promoter uses different methods to collect data from and about you including through: Direct interactions. You give the Promoter, your Identity and Contact Data by registering on the Promoter’s website, corresponding with the Promoter by post, phone, email or otherwise. This includes personal data you provide when you:

• enter a competition;
• create an account and profile on the Promoter’s website;
• request marketing to be sent to you (including newsletters);
• subscribe to an event, webinar or survey;
• give the Promoter feedback, collect a prize, or contact the Promoter.
• Automated technologies or interactions

As you interact with the Promoter’s website, the Promoter will automatically collect Technical Data about your equipment, browsing actions and patterns. The Promoter collects this personal data by using cookies, server logs and other similar technologies. The Promoter may also receive Technical Data about you if you visit other websites employing its cookies. Please see the Cookie Policy for further details.

4.2. Third parties or publicly available sources The Promoter will receive personal data about you from various third parties as set out below: (a) analytics providers such as Google based outside the UK; and (b) third party service providers based in the UK and outside the UK.

4.3. How the Promoter uses your personal data The Promoter will only use your personal data when the law allows to. Most commonly, the Promoter will use your personal data in the following circumstances:

• Where the Promoter needs to perform its contract and duties in relationship to your entries in Competitions you are about to enter into or have entered into.
• Where it is necessary for the Promoter’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where the Promoter needs to comply with a legal obligation. Generally, the Promoter does not rely on consent as a legal basis for processing your personal data although the Promoter will get your consent before sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting the Promoter at [email protected].

4.4 Purposes for which the Promoter will use your personal data The Promoter has set out below, in a table format, a description of all the ways the Promoter plans to use your personal data, and which of the legal bases the Promoter relies on to do so. The Promoter has also identified what its legitimate interests are where appropriate. Note that the Promoter may process your personal data for more than one lawful ground depending on the specific purpose for which the Promoter is using your data. Please contact the Promoter if you need details about the specific legal ground the Promoter is relying on to process your personal data where more than one ground has been set out in the table below.

5. Glossary

Legitimate Interest means the interest of the Promoter’s business in conducting and managing its business to enable the Promoter to give you the best service/product and the best and most secure experience. The Promoter considers and balances any potential impact on you (both positive and negative) and your rights before processing your personal data for its own legitimate interests. The Promoter does not use your personal data for activities where its interests are overridden by the impact on you (unless the Promoter has your consent or are otherwise required or permitted to by law). You can obtain further information about how the Promoter assesses its legitimate interests against any potential impact on you in respect of specific activities by contacting the Promoter.

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 the Promoter is subject to.

External Third Parties

• Service providers who provide IT and system administration services.
• Third parties that are providing the prize to winners for instance and not limited to, travel agents, airlines, hotels, venues.
• Professional advisers including lawyers, bankers, auditors and insurers who may provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other applicable authorities who require reporting of processing activities in certain circumstances.

6. Marketing The Promoter provides you with choices regarding certain personal data uses, particularly around marketing communications from the Promoter. You will receive marketing communications from the Promoter if you have previously entered a competition, and you have not opted out of receiving that marketing.

6.1. Third-party marketing The Promoter does not share your personal data with any third party for marketing purposes. In the event, the Promoter wishes to do so, the Promoter will get your express opt-in consent before the Promoter shares your personal data with any third party for marketing purposes.

6.2. Opting out You can ask the Promoter 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 the Promoter at any time at [email protected]. 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 the website may become inaccessible or not function properly. For more information about the cookies the Promoter uses, please see the Cookie Policy.

7. Change of purpose

The Promoter will only use your personal data for the purposes for which the Promoter collected it, unless the Promoter reasonably considers that it is needed 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 the Promoter. If the Promoter needs to use your personal data for an unrelated purpose, the Promoter will notify you and will explain the legal basis which allows the Promoter to do so.

8. How long the Promoter keeps your personal data

The Promoter will only keep your personal data for as long as necessary to fulfil the purposes the Promoter collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. At the end of that retention period, your data will either be deleted or anonymised (so that it can no longer be associated with you) and used for research or statistical purposes. To determine the appropriate retention period for personal data, the Promoter considers 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 the Promoter processes your personal data and whether the Promoter can achieve those purposes through other means, and the applicable legal requirements.

9. Disclosures of your personal data The Promoter may share your personal data with the parties set out below for the purposes set out in the table

Purposes for which the Promoter will use your personal data above.

• External Third Parties as set out in the Glossary.
• Third parties to whom the Promoter may choose to sell, transfer or merge parts of the Promoter’s business or assets. Alternatively, the Promoter may seek to acquire other businesses or merge with them. If a change happens to the Promoter’s business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• The Promoter requires all third parties to respect the security of your personal data and to treat it in accordance with the law. The Promoter does not allow third-party service providers to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and in accordance with the Promoter’s instructions.

10. International transfers Your personal data may be used, stored and/or accessed by staff operating outside the UK and EEA working for the Promoter, or suppliers. If the Promoter transfers your personal data outside the UK or EEA, the Promoter will take appropriate security measures to ensure the respective receipt protects your personal data adequately in accordance with this privacy policy. These measures may include the following:

• To countries that have been deemed to provide an adequate level of protection for personal data by the UK and/or the EU Commission.
• To entities in countries based outside the UK and EEA, by entering into the European
• Commission’s approved Standard Contractual Clauses and/or the ICO’s approved Addendum or the ICO’s International Data Transfer Agreement, that is equivalent with them.
• To entities, that are US organisations, that are certified under the UK extension to the EU-US Data Privacy Framework (the “UK extension”).

11. Your rights

Your right to complain. The Promoter strives to provide high standards of customer services and is fully committed to protecting the personal information of its customers. If you wish to contact the Promoter to query or complain about the way the Promoter uses your personal data, the Promoter will treat the matter with the utmost seriousness. Please direct your queries or complaints to the Data Protection Officer. If you remain unsatisfied with the handling of your complaint by the Promoter, you can complain to the Information Commissioner's Office (ICO). You can find out more about that right and the complaints process on the ICO website.

Your right to be informed if your personal data is compromised. In the unlikely event that the personal data the Promoter holds is breached or compromised in a significant way that would be a high risk to your rights and personal freedoms, the Promoter will contact you without delay to let you know:

• What happened and how it happened
• What data was affected and what that means to you
• What the Promoter is doing about it and how you can stay informed
• How you can contact the Data Protection Officer

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data the Promoter holds about you and to check that the Promoter is lawfully processing it. Request correction of the personal data that the Promoter holds about you. This enables you to have any incomplete or inaccurate data the Promoter holds about you corrected, though the Promoter may need to verify the accuracy of the new data you provide to the Promoter.

Request erasure of your personal data. This enables you to ask the Promoter to delete or remove personal data where there is no good reason for the Promoter to continue processing it. You also have the right to ask the Promoter to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where the Promoter may have processed your information unlawfully or where the Promoter is required to erase your personal data to comply with local law. Note, however, that the Promoter 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 the Promoter is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where the Promoter is processing your personal data for direct marketing purposes. In some cases, the Promoter may demonstrate that the Promoter has compelling legitimate grounds to process your information which override your rights and freedoms.

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

• If you want the Promoter to establish the data's accuracy.
• Where the use of the data is unlawful but you do not want Promoter to erase it.
• Where you need the Promoter to hold the data even if the Promoter no longer requires it as you need it to establish, exercise or defend legal claims.
• You have objected to the use of your data but the Promoter needs to verify whether the Promoter has overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. The Promoter 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 the Promoter to use or where the Promoter used the information to perform a contract with you.

Withdraw consent at any time where the Promoter is 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, the Promoter may not be able to provide certain products or services to you. The Promoter will advise you if this is the case at the time you withdraw your consent.

12. How the Promoter keeps your personal data safe

At Ooosch, information security is very important to its business. The Promoter is fully committed to ensuring information security, accuracy, confidentiality and integrity.

The methods the Promoter uses to ensure data is safeguarded while being sent over the internet are of the industry standard. When information reaches the Promoter, the Promoter stores it securely and only provides access to authorised personnel or data processors.

Ooosch maintains strict physical, electronic, and administrative safeguards to protect your personal data from unauthorised or inappropriate access. The data the Promoter collects is stored in secure operating environments not accessible by the public.