1. Who we are
This promotion is operated by {{PROMOTER_NAME}} ("we", "us", "our") on behalf of {{BRAND_NAME}}. {{PROMOTER_NAME}} is the data controller responsible for your personal information collected through this promotion.
Registered address: {{PROMOTER_NAME}}, [Registered Address], [City], [Postcode].
If you have any questions about how we handle your personal data, please contact us at {{SUPPORT_EMAIL}}.
This policy was last updated on [DATE]. We may update it from time to time — the current version will always be available on this page.
2. What data we collect
When you register your product or make a claim through this promotion, we collect the following information:
- Full name and contact details (email address, phone number)
- Product information (category, model, serial number)
- Purchase information (date of purchase, purchase price, retailer)
- Proof of purchase (a photograph or PDF of your receipt or invoice)
- Marketing consent preference
- Device fingerprint and IP address (used for fraud prevention only)
If you make a claim, we also collect proof of repair documentation and, at the payment stage only, the bank account details necessary to process your refund.
3. Why we collect your data
We collect and use your personal data for the following purposes:
- To administer the {{CAMPAIGN_NAME}} product guarantee and process your registration
- To verify your product's eligibility for the promotion
- To communicate with you about the status of your registration or claim
- To process and pay out approved claims
- To prevent fraud and protect the integrity of the promotion
- To comply with our legal obligations
- To send you marketing communications about {{BRAND_NAME}} products and promotions — only if you have given your explicit consent
4. Lawful basis for processing
We rely on the following lawful bases to process your personal data:
- Contract performance — processing your registration and any claim is necessary to perform the promotion agreement you entered into when you registered.
- Legitimate interests — fraud prevention, security monitoring, and improving the quality of our promotional services.
- Consent — where you have opted in to receive marketing communications. You may withdraw this consent at any time by contacting us at {{SUPPORT_EMAIL}}.
- Legal obligation — retaining financial records for the period required by applicable law.
5. Who we share your data with
We share your personal data only where necessary and with appropriate safeguards in place. Categories of recipients include:
- {{BRAND_NAME}} — as the brand operating this promotion, they receive registration and claim data to fulfil their obligations under the guarantee.
- Cloud infrastructure providers — Supabase (database and API hosting) and Cloudflare (content delivery and security). Both operate under data processing agreements.
- Email service providers — used to send confirmation and communication emails on our behalf.
- Payment processing partners — to facilitate refund payments for approved claims.
- Fraud detection services — including FingerprintJS, used solely to prevent duplicate or fraudulent entries.
We do not sell your personal data to any third parties or use it for advertising purposes.
6. International transfers
Your personal data is primarily processed within the UK and European Economic Area (EEA). Where any transfer outside the EEA is necessary (for example, to a cloud service provider with infrastructure in other regions), we ensure that appropriate safeguards are in place, including the use of Standard Contractual Clauses approved by the relevant data protection authority.
7. How long we keep your data
We retain your personal data only for as long as necessary for the purposes it was collected:
- Registration data is retained for the duration of your protection period plus 12 months, to allow for any late claims or queries.
- Claim and payment data is retained for 6 years after the claim is processed, in line with financial records requirements.
- After the applicable retention period, data is securely deleted or anonymised so it can no longer be attributed to you.
8. Your rights
Under applicable data protection law, you have the following rights regarding your personal data:
- Right of access — to request a copy of the personal data we hold about you.
- Right to rectification — to ask us to correct inaccurate or incomplete data.
- Right to erasure — to request deletion of your data, where we have no lawful reason to continue holding it.
- Right to restriction — to ask us to limit how we use your data in certain circumstances.
- Right to data portability — to receive your data in a structured, machine-readable format.
- Right to object — to object to processing based on legitimate interests or for direct marketing.
- Right to withdraw consent — where processing is based on consent (e.g. marketing), you may withdraw at any time without affecting prior processing.
To exercise any of these rights, please contact us at {{SUPPORT_EMAIL}}. We will respond within 30 days. You also have the right to lodge a complaint with the relevant supervisory authority (in the UK, the Information Commissioner's Office at ico.org.uk).
9. Cookies and tracking
This promotion website uses a minimal set of technical tools:
- Cloudflare Turnstile — a bot-detection and security verification tool used on our registration form to prevent automated abuse. No personal data is stored beyond what is needed to verify that a request is from a real person.
- FingerprintJS — a device fingerprinting library used solely for fraud prevention (detecting duplicate or suspicious registrations). The resulting fingerprint is not used for advertising or cross-site tracking.
- Local storage — used only to remember your cookie consent preference.
We do not use advertising cookies, social media tracking pixels, or any third-party analytics that track your behaviour across other websites.
10. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in law, our services, or our data practices. The date at the top of this page indicates when it was last revised. We encourage you to review this page periodically. Continued use of the promotion website following an update constitutes acceptance of the revised policy.
11. Contact us
For any data protection queries, requests to exercise your rights, or complaints relating to this promotion, please contact:
{{PROMOTER_NAME}} — Data Protection Enquiries
Email: {{SUPPORT_EMAIL}}