Privacy Policy

Raffle IT & Competitions Limited
Privacy Policy 
 

CONTENTS
____________________________________________________________
CLAUSE
1.    Important information and who we are    
2.    The data we collect about you    
3.    How is your personal data collected?    
4.    How we use your personal data    
5.    Disclosures of your personal data    
6.    International transfers    
7.    Data security    
8.    Data retention    
9.    Your legal rights    
10.    Glossary    
 

Introduction
Welcome to Raffle IT's privacy policy. 
Raffle IT respects your privacy and is committed to protecting your personal data. This privacy policy will 
inform you as to how we look after your personal data when you visit our website (regardless of where you 
visit it from) and tell you about your privacy rights and how the law protects you. 
This privacy policy is provided in a layered with the specific areas set out below. Please also use the 
Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?] 
4. [HOW WE USE YOUR PERSONAL DATA] 
5. [DISCLOSURES OF YOUR PERSONAL DATA] 
6. [INTERNATIONAL TRANSFERS] 
7. [DATA SECURITY]
8. [DATA RETENTION] 
9. [YOUR LEGAL RIGHTS] 
10. [GLOSSARY] 

1.    Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Raffle IT 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 our newsletter, create an account on our website, purchase a product or service or take part in a 
competition or host a competition on our website. 
This website is not intended for children and we do 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 we may provide on specific occasions when we are collecting or processing personal data about you 
so that you are fully aware of how and why we are using your data. This privacy policy supplements other 
notices and privacy policies and is not intended to override them. 
Controller
Raffle IT & Competitions Limited is the controller and responsible for your personal data (collectively 
referred to as "Raffle IT", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, 
please contact the us using the details set out below. 

Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the 
following ways:
Full name of legal entity: RAFFLE IT & COMPETITIONS LIMITED (Registration Number: 695061)
Email address: info@raffleit.ie
Postal address: Sicily, Balrath, Navan, Meath, Ireland
Telephone number: (041) 981 4391 
You have the right to make a complaint at any time to the Data Protection Commission 
https://www.dataprotection.ie/. We would, however, appreciate the chance to deal with your concerns 
before you approach the DPC 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.

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.

2.    The data we collect 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).
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, maiden name, last name, username or similar identifier, 
marital status, title, date of birth and gender.
*    Contact Data includes billing address, delivery address, email address and telephone numbers.
*    Financial Data includes bank account and payment card details.
*    Transaction Data includes details about payments to and from you and other details of 
products and services you have purchased from us.

*    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, and other technology on the devices you use to access this website. 
*    Profile Data includes your username and password, purchases or orders made by you, your 
interests, preferences, feedback and survey responses.  
*    Usage Data includes information about how you use our website, products and services. 
*    Marketing and Communications Data includes your preferences in receiving marketing from 
us and our third parties and your communication preferences.
We also collect, use and share 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, we may aggregate your Usage Data 
to calculate the percentage of users accessing a specific website feature. However, if we combine or 
connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat 
the combined data as personal data which will be used in accordance with this privacy policy.

We do 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 and biometric data). Nor do we collect any 
information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you 
fail to provide that data when requested, we may not be able to perform the contract we have or are trying 
to enter into with you (for example, to provide you with goods or services). In this case, we may have to 
cancel a product or service you have with us but we will notify you if this is the case at the time. 

3.    How is your personal data collected?
We use different methods to collect data from and about you including through:
*    Direct interactinos. You may give us your Identity, Contact and Financial Data by filling in 
forms or by corresponding with us by post, phone, email or otherwise. This includes personal 
data you provide when you:
*    apply for our products or services;
*    create an account on our website;
*    subscribe to our service or publications; 
*    request marketing to be sent to you;
*    enter a competition;
*    host a competition; or
*    give us feedback or contact us. 
*    Automated technologies or interactions. As you interact with our website, we will 
automatically collect Technical Data about your equipment, browsing actions and patterns. We 
collect this personal data by using cookies, server logs and other similar technologies.

*    Third parties or publicly available sources. We will receive personal data about you from 
various third parties and public sources as set out below: 
Technical Data from the following parties:
(a)    analytics providers such as Google based outside the Republic of Ireland; 
(b)    advertising networks; and
(c)    search information providers;
*    Contact, Financial and Transaction Data from providers of technical, payment and delivery 
services.
*    Identity and Contact Data from data brokers or aggregators.
*    Identity and Contact Data from publicly available sources.

4.    How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal 
data in the following circumstances:
*    Where we need to perform the contract we are about to enter into or have entered into with you.
*    Where it is necessary for our legitimate interests (or those of a third party) and your interests 
and fundamental rights do not override those interests.
*    Where we need to comply with a legal obligation.

*  The host and winner will be notified of each others contact details after the competition they have entered has taken place. 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get 
your consent before sending third party direct marketing communications to you via email or text message. 
You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific 
purpose for which we are using your data. Please contact us if you need details about the specific legal 
ground we are relying on to process your personal data where more than one ground has been set out in 
the table below. 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-
out links on any marketing message sent to you. 
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to 
us as a result of a product/service purchase, warranty registration, product/service experience or other 
transactions.

Cookies
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 this website may become 
inaccessible or not function properly. For more information about the cookies we use, please see Click here for cookie-policy.

Change of purpose 
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the 
original purpose, please contact us. 
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 so.
Please note that we may process your personal data without your knowledge or consent, in compliance 
with the above rules, where this is required or permitted by law.

5.    Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
*    We may disclose your personal data to our professional advisers insofar as reasonably 
necessary for the purposes of managing risks, obtaining professional advice, or the 
establishment, exercise or defence of legal claims, whether in court proceedings or in an 
administrative or out-of-court procedure.
*    Financial transactions relating to our website and services are handled by our payment services 
providers, (Stripe) We will share transaction data with our 
payment services providers only to the extent necessary for the purposes of processing your 
payments, refunding such payments and dealing with complaints and queries relating to such 
payments and refunds. You can find information about the payment services providers' privacy 
policies and practices at Click here for Stripe privacy-policy.
*    In addition to the specific disclosures of personal data set out in this Section 5, we may disclose 
your personal data where such disclosure is necessary for compliance with a legal obligation to 
which we are subject, or in order to protect your vital interests or the vital interests of another 
natural person. We may also disclose your personal data where such disclosure is necessary for 
the establishment, exercise or defence of legal claims, whether in court proceedings or in an 
administrative or out-of- court procedure.

*    Third parties to whom we may choose to sell, transfer or merge parts of our business or our 
assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change 
happens to our business, then the new owners may use your personal data in the same way as 
set out in this privacy policy. 
We require all third parties to respect the security of your personal data and to treat it in accordance with 
the law. We do not allow our third-party service providers to use your personal data for their own purposes 
and only permit them to process your personal data for specified purposes and in accordance with our 
instructions.

6.    International transfers
Many of our external third parties are based outside the Republic of Ireland so their processing of your 
personal data will involve a transfer of data outside the EU. 
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is 
afforded to it by ensuring at least one of the following safeguards is implemented: 
*    We will only transfer your personal data to countries that have been deemed to provide an 
adequate level of protection for personal data. 
*    Where we use certain service providers, we may use specific contracts approved for use in the 
EU which give personal data the same protection it has in the EU.
Please contact us if you want further information on the specific mechanism used by us when 
transferring your personal data out of the UK.

7.    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. In addition, we limit access to your 
personal data to those employees, agents, contractors and other third parties who have a business need to 
know. They will only process your personal data on our instructions and they are subject to a duty of 
confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and 
any applicable regulator of a breach where we are legally required to do so.

8.    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. 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.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and 
Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further 
information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with 
you) for research or statistical purposes, in which case we may use this information indefinitely without 
further notice to you. 

9.    Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 
These rights include:
*    Request access to your personal data.
*    Request correction of your personal data.
*    Request erasure of your personal data.
*    Object to processing of your personal data.
*    Request restriction of processing your personal data.
*    Request transfer of your personal data.
*    Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us using the contact details set out in 
Section 1. 

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. 

10.    Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to 
enable us to give you the best service/product and the best and most secure experience. We make sure we 
consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate 
interests against any potential impact on you in respect of specific activities by contacting us.

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 we are subject to.

THIRD PARTIES
Internal Third Parties
Other companies in who provide IT and system administration services and undertake leadership reporting. 
External Third Parties
*    Service providers acting as processors based who provide IT and system administration 
services.
 

*    Professional advisers acting as processors including lawyers, bankers, auditors and insurers 
based who provide consultancy, banking, legal, insurance and accounting services.
*    The Revenue Commission, regulators and other authorities acting as processors based in the 
Republic of Ireland who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS
You have the right to:
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 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. 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) 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 we are processing your personal data for direct marketing purposes. In some 
cases, we may demonstrate that we have 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 us to suspend the 
processing of your personal data in 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. 
*    You have objected to our use of your data but we need to verify whether we have overriding 
legitimate grounds to use it. 
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.