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Fourleaf Privacy Policy

Privacy Policy including UK-GDPR (GDPR) Policy

  1. We protect your data

This Privacy Policy sets out the policy concerning the collection, processing, storage, disclosure, and recording (using so-called “cookies”) of personal information supplied by you. We are FourLeaf

79 Freestone Way,
Barrow-in-Furness,
LA14 4RW

”, “we”, “us” or “our”). We respect your privacy and are committed to treating any information that we obtain about you with as much care as possible and in a manner that is compliant with all applicable data protection legislation including the EU General Data Protection Regulation 2016/679 (“GDPR”) (DPA 2018) and any national implementing laws concerning the same (collectively, “Data Protection Legislation”). Before accessing our website, we would like to inform you of what data we may request from you and for which purposes such data is collected and used.

This document explains

  • What personal data we may collect about you in connection with (i) providing you with our prize offers through prize draws, competitions, and contests; (ii) your online interaction with us (including via our website(s), email, or social media channels); (iii) our in-person interactions with you and (iv) any other related channels (collectively, the “Channels”);
  • How we collect, store, disclose, transfer, protect, and otherwise process that information and for what purposes; and
  • Other important information, such as the lawful bases by which we process your data, how long we might retain your data, and the rights you have about personal data we hold about you.

This policy is intended to be communicated to you in a concise, transparent, and easily accessible way, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please email jamie@fourleaf.me and we will respond as soon as possible.

We reserve the right to make changes to this Privacy Policy to reflect any changes in Data Protection Legislation and best practices from time to time. We will notify you of such changes, but you are advised to check for an updated version of this policy on our website each time you interact with us.

In this Privacy Policy, terms defined in the GDPR, including “data subject”, “personal data”, and “processing”, have the same meaning.

  1. The personal data we process

We collect personal data about you through the Channels when you:

  • Access and use our website (including by way of “cookies”);
  • Enter a prize draw, competition, or contest;
  • Subscribe to a special event or our mailing list;
  • Request technical support or other care support;
  • Participate in polls, surveys, and questionnaires;
  • Contact us (whether in writing, by email, by telephone, or otherwise);
  • Otherwise, interact with us through the Channels.

The type of personal data we process may include:

  • Information obtained through the use of cookies when you use the site;
  • Your full name, postal address, country, email address, telephone number, and other information provided by you;
  • and you should not provide us with any such information through any of the Channels.

 

  1. The purposes for which we process your data

We use the personal data for:

  • A confirmation email and prize draw, competition, and contest entry receipts, and email updates;
  • Processing your entry payment into a prize draw, competition, or contest;
  • Contacting you if you are a winner;
  • Personalising content on the Channels;
  • Sending you promotional and marketing materials, notifications, updates, and exclusive news provided you have opted-in to receive them;
  • Responding to any correspondence from you including inquiries, comments, complaints, and technical problems;
  • Administering any services, questionnaires, contests, or special events which you may have subscribed for;
  • Carrying out our business activities in circumstances where you ought reasonably to expect that we will process your data for a particular purpose.

We may process your data for the purposes set out above ourselves or in conjunction with our third-party service providers.

  1. The lawful basis by which we process your data

Your consent
By accepting the terms of this Privacy Policy, you give us your express, freely given consent to process any of your data following the terms of this policy. You may withdraw your consent at any time by emailing us at jamie@fourleaf.me. The withdrawal of your consent will not affect the lawfulness of processing based on consent before withdrawal or the lawfulness of processing based on other lawful grounds as set out below.

Other lawful grounds
We may process your data in any circumstances where such processing is necessary:

  • To perform any agreement between us (for example for us to fulfil a prize to you as prize winner);
  • To comply with any applicable law or regulation; or
  • For the legitimate interests pursued by us or third parties including other general commercial interests and our internal administrative purposes.

 

  1. What if you refuse to provide us with any personal data?

Where we need to collect personal data by law, or under the terms of an agreement 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 your prize). In this case, we may have to cancel the award of the prize to you and choose another winner, but we will notify you if this is the case.

We may lawfully obtain information from third parties or public sources and we may process that information where it is an essential component of the prize we offer you.

  1. Sharing information with affiliates and third-parties

We will not share any of your data with third parties except as set out here or otherwise notified to you or agreed between you and us from time to time.

We may share personal data with our group companies and partnered companies (together, “Affiliates”) to provide our goods and services to you and for the other purposes outlined in this policy.

From time to time, we will also need to share personal data with the following types of third-party service providers who we engage to provide services that facilitate our business and who may need to process your data to the extent necessary to provide those services:

  • email service providers;
  • web analytics services such as Google Analytics;
  • professional service providers, such as marketing agencies, advertising partners, and website hosts;
  • logistics companies;
  • address verification services;
  • integration platform providers;
  • other third parties approved by you, such as social media sites that you link to your account (if and when we offer that feature) or share content via or third-parties who administer any competitions or surveys on our behalf which you voluntarily partake in.

We seek to ensure that any third party engaged by us who processes your data has policies and procedures in place to ensure compliance with the Data Protection Legislation. Unless otherwise disclosed to you from time to time, we will remain the data controller in respect of your data notwithstanding that third parties may be engaged as data processors.

We may share your personal information with third parties where we are required to do so by law or regulation (such as in connection with an investigation of fraud or other legal inquiry) or in connection with other legal proceedings (including where we believe that your actions violate applicable laws or any usage guidelines for specific products or services, or threaten the rights, property, or safety of us, our users, or others).

  1. Your rights as a data subject

Subject to any conditions or requirements set out in the relevant Data Protection Legislation, you may have some or all of the following rights concerning the personal data we hold about you:

  • The right to request a copy of your data held by us;
  • The right to correct any inaccurate or incomplete personal data held by us. You can update and amend your data by emailing us at jamie@fourleaf.me
  • The right to request that we erase the personal data we hold about you;
  • The right to request that we restrict the processing of your data;
  • The right to object to certain types of processing of your data by us; and
  • The right to complain.

 

  1. Storage and retention of your data

As a minimum, we will store your data for as long as is reasonably necessary to provide you with the prize and, as a maximum, for twelve months from the end of the promotional period of the relevant prize draw, competition, or contest in which you are a winner.

If you tell us that you would like to delete your account, we will take steps to delete all the personal data we hold about you once it is no longer necessary for us to hold it (e.g. to fulfil any prize, resolve disputes, or as is permitted by applicable law or regulation).

For as long as we do store your data, we will follow generally accepted industry standards and maintain reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. We have security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal data collected by us is stored in secure operating environments that are not available to the public. Despite our efforts to keep your data secure, no system can be 100% reliable. We cannot be held liable for any loss you may suffer if a third party procures unauthorised access to any data you provide through the Channels. We will notify you as soon as possible if we have reason to believe that there has been a personal data breach by us (or your data held by us).

  1. Links to Third-Parties

Our website may link or redirect to other websites that are beyond our control. Such links or redirections are not endorsements of such websites or representation of our affiliation with them in any way and such third-party websites are outside the scope of this Privacy Policy.

If you access such third-party websites, please ensure that you are satisfied with their respective privacy policies before you provide them with any personal data. We cannot be held responsible for the activities, privacy policies, or levels of privacy compliance of any website operated by any third party.

  • Cookies

A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our website.

Some data collected by cookies is collected on an anonymous and/or aggregated basis. Where we use cookies that contain personal data, we will only process that personal data as set out in this policy.

Your browser may give you the ability to block all or some cookies by activating a setting in your browser’s options. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. Except for essential cookies, all cookies will remain unless the cookie cache is cleared (unless otherwise indicated in the table above).

To find out more about cookies including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org/manage-cookies.

FourLeaf may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

 

 

 

FourLeaf – UK-(GDPR) Statement

In conjunction with GDPR compliance, FourLeaf have reviewed all activities across the business and how data is processed. The companies activities fall within three key areas:

  • A data controller of its own employee data.
  • A data controller or processor of third-party data such as activity relating to direct marketing.
  • A data processor or controller of customer personal data.

Activity

  • Following the review of GDPR, FourLeaf has designed it’s company policies and procedures to ensure compliance with regulations.
  • FourLeaf  has reviewed its policy and you can see in this section FourLeaf  activity in respect of GDPR.

What we need

FourLeaf only collect personal data which may include information about you personally for the purposes of verifying eligibility to use our services, and to enable us to deliver Prizes to Winners of our Competitions. This includes name, age, address, phone number, email address etc.

Why we need it

We need to know your basic personal data in order to check your eligibility to use our services and also to ensure that we can deliver any Prizes to you that you Win in any of our Competitions. We will not collect any personal data from you that we do not need in order to provide our services to you.

What we do with it

All data is processed in the UK and all servers we use online are based in the UK also, for the purposes of hosting and maintenance, this information is located on our servers and no other parties have access to your personal data unless the law allows them to do so. From time to time we may need to share your data with other third-party service providers such as:

  • Email service providers such as Mailchimp and WordPress;
  • Website/Online analytics such as Google Analytics;
  • Delivery and/or logistics companies;
  • Social Media websites such as Facebook and Instagram in order to share content.

We reasonably endeavour to ensure any third parties that we use have their own complaint policies and procedures in place for dealing with personal data.

Frequently asked questions

What personal data do you process?

Any data which relates to an identifiable person (Customer). Name, Age, address, phone number, email, etc.

For what purpose do you process this personal data?  

Data is collected for specific, legitimate and explicit purposes of providing skill, judgement or knowledge based competition services in order to allow our customers to enter competitions on our Website whilst ensuring their eligibility to do so.

What are the risks to data subjects’ rights and freedoms if the personal data is destroyed, lost, altered, disclosed without authority, or accessed without authority?

Following the review of our policies/procedures and also a full review of GDPR guidelines, we believe the risks are minimal as the information we obtain is contained solely in our database. It is not shared with any outside third parties, except for email service providers, website analytic services, delivery/logistics services, competition draw services and social media website, all of which have their own complaint policies and procedures for processing personal data. In the event data is lost, altered or disclosed without authority etc the customer could report us to ICO which could mean fines of up 4% of our turnover. There could also be potential compensation claims that can be made by the data subject. Non-financial risks include reputational damage as the ICO will name non-compliant organisations which would effect our reputation in the industry with our customers. The risks are high in relation to penalties, but this is the same for all UK companies and we believe the risks are low. The worst case scenario is that the ICO could stop us processing personal data.

What provisions do you have in place to either delete or return the personal data once the service comes to an end?

When a data subject requests this, we will contact the data subject, discuss the deletion or return of records, and then remove accordingly. Otherwise it is our intention to keep the customers details on our system for 12 months from the last time they either replied to an email, accessed our website/app or commented on our social media, as this coincides with our “legitimate business interests”.

Do you understand the GDPR requirements in detail and are you satisfied that you are aware of the impact these will have on your business?

Yes, we are happy that we have a good understanding of GDPR requirements and the impact they have on our customers and business.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee of £10 will be payable. If you would like a copy of the information held on you please contact us by emailing from your contact email at jamie@fourleaf.me

If you believe that any information we are holding on you is incorrect or incomplete, please contact us. We will promptly correct any information found to be incorrect.

Contact us

I consent to my data from this form being collected and stored to be used according to our privacy policy

To enter the competition:

a) send your entry by first- or second-class post to the Promoter at the following address:

fourleaf c ltd, 28 Lapstone Road, Millom, Cumbria, LA18 4BU

(b) hand delivered entries will not be accepted and will not be entered into the random draw;

 

(c) include with your entry the following information:

    (i) your full name;

    (ii) your address;

    (iii) a contact telephone number and email address; and

    (iv) your answer to the Competition Question (if there is one).

(d) incomplete or illegible entries will be disqualified;

(e) you may make multiple free entries for any competition (up to any limit placed on entries by the Promoter) but each free entry must be submitted and posted to the Promoter separately. Bulk entries in one envelope will not be accepted as multiple entries and if a bulk entry is received, it will be counted as one single entry;

(f) by entering the competition, you are confirming that you are eligible to enter and accept these terms and conditions;

(g) your entry must be received by the Promoter prior to the Closing Date. Entries received after the Closing Date will not be entered into the random draw. Proof of posting does not guarantee that you will be entered into the random draw;

(h) the Promoter will not acknowledge receipt of your entry nor confirm if your answer to the Competition Question is correct;

(i) if the number of entries received reaches any cap or limit before your free entry is received, you will not be entered into the random draw.

(j) Entrants must have created an account on the Website for the free entry to be processed. All details on the postcard must correspond to the details on the account to receive the order confirmation and ticket number. Postal entries received without a registered account cannot be processed. Entrants must add an address to the related account for entries to be processed.