Privacy Policy

INTRODUCTION

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED & USED
4. DISCLOSURES OF YOUR PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Processing Notice

This processing notice aims to give you information on how we collect and process your personal data in a variety of circumstances. It is important that you read this processing notice so that you are fully aware of how and why we are using your data. This version was last updated on [05/12/2023] and previous versions can be obtained by contacting us.

Controller

CMG3 Limited (t/a Avant Prize Draws) (referred to as we, us or our in this processing notice) is the controller of, and responsible for, your personal data. If you have any questions about this processing notice (including any requests to exercise any of your legal rights) please contact us by emailing [avantprizedraws@gmail.com].

Third-Party Links

Our 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 processing notice of every website you visit.

2. THE DATA WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. 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, last name, image, online username or similar identifier, title, date of birth and/or gender;
• Contact Data includes email address, physical address and telephone numbers;
• Financial Data includes bank account and payment card details;
• 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 our website;
• Usage Data includes information about how you use our website and services;
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

Your Duty to Inform us of Changes

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED & USED?

We use different methods to collect personal data from and about you. The ways we collect it, what we collect and how and why we use that personal data is set out below:

Please note that the above lists are non-exhaustive. We will generally only use your Personal Data for the purposes for which we collected it, unless permitted by law or 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 and incompatible purpose, we will notify you where necessary and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Where we rely on legitimate interest, you can contact us for more details on the consideration of these interests.

NOTE:

Legitimate Interest can mean our interest or the interest of another party. 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).

Consent
Whenever we rely on your consent (as noted above), you have the right to revoke such consent at any time by emailing us using the email address noted above]. Unless another basis of use exists, we will collect your consent to use your personal data for our marketing and remarketing purposes generally by using tick boxes or where your actions clearly demonstrate your consent (such as by providing your contact details for a specified purpose).

Marketing
If you are a customer or user of ours, we may contact you from time to time by call or email to provide some information about our products or services. 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 or by contacting us, as appropriate, at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.

We will get your express opt-in consent before we share your personal data with any company outside of our own for marketing unrelated to our company.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties (all established in the UK or EEA unless otherwise stated) set out below for the purposes set out in the table in paragraph 3 above:

• 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 processing notice.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances;
• professional advisers including lawyers, bankers, auditors and insurers based in the European Union or United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
• lawyers involved in legal disputes and/or prosecution/defence of criminal matters; and
• service providers, including (as at the date noted above and who may be updated from time to time):
◦ Cashflows. who is engaged to provide financial services;
• other parties where you ask us to share that data, or we ask you and you consent.

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.

5. INTERNATIONAL TRANSFERS

Other than as noted below we, do not transfer your personal data outside the UK other than to the European Economic Area (EEA). Where we do, or will, make such transfers, we will ensure that a similar degree of protection is enforced as is required within the UK by ensuring that the recipients use and are bound by standard contractual clauses which may be enforceable by you regarding data protection (as well applying appropriate additional security measures), or the recipient countries have been deemed to provide an adequate level of protection by the UK (which currently mirror the decisions taken by the European Commission (further details). For example, as we are a Business User of Cashflows, (who provide us with payment services), it may transfer your Personal Data to other countries other than your own country, including the United States. When transferring such data across borders, Cashflows. ensures to take measures to comply with the applicable data protection laws related to such transfer, which is compliant with EU-US Data Privacy Framework.

6. 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. We have also 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. 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. Please contact us if you would like more information regarding the security measures we use.

7. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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, how long a legal claim may be taken and whether we can achieve those purposes through other means, and the applicable legal requirements.

We will only retain your personal data for as long as you are an active user of Avant Prize Draws and for one further year (after this after which time; it will automatically be deleted, unless we have another reason to retain it).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for other purposes, in which case we may use this information indefinitely without further notice to you.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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.

• 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, 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.

If you wish to exercise any of the rights set out above, please contact us. Note, however, that we may not always be able to comply with your request for specific legal or compelling legitimate reasons which will be notified to you, if applicable, at the time of your request.

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 may 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 may take us longer than a month if your request is particularly complex or we receive a number of requests. In this case, we will notify you and keep you updated.

Supervisory Authority Contact
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.