REV COMPS
PRIVACY POLICY
At Rev Comps, we are committed to protecting the privacy and security of our customers and site visitors. We understand the trust you place in us when you provide us with your personal data. This Privacy Policy explains how we collect, use, share and protect your personal data, and the rights you have in relation to it. Please read it carefully.
Rev Competitions Limited is the company that operates the website www.revcomps.com and any associated apps (the "Website"). Rev Competitions Limited is incorporated under the laws of Gibraltar (company number 126588) with registered office at Madison Building, Midtown, Gibraltar, GX11 1AA. Any reference in this Privacy Policy to "Rev Comps", "we", "us" or "our" is to Rev Competitions Limited, which is the data controller responsible for your personal data. We are part of the Winvia group of companies (the "Group").
Because we offer our Services to individuals located in the United Kingdom, Ireland, Northern Ireland, the Isle of Man and the Channel Islands, and because we are established in Gibraltar, we handle your personal data in accordance with both the UK GDPR and the Data Protection Act 2018, and Gibraltar data protection law (the Gibraltar GDPR and the Gibraltar Data Protection Act 2004), as applicable.
1. WHAT THIS POLICY TELLS YOU
• what personal data we collect from you (or which we collect about you) when you use the Website or otherwise interact with us;
• how and why we use that data, and the legal grounds we rely on;
• who we share your data with;
• whether we transfer your data internationally, and how we protect it;
• how long we keep your data and how we keep it secure; and
• your rights over your data and how to exercise them.
2. WHAT INFORMATION DO WE COLLECT AND WHAT DO WE USE IT FOR?
You may provide us with, or we may collect, the following types of personal data when you register with us, enter a Competition, or otherwise interact with us:
• Identity — first name, surname, your login details (username and password), date of birth and country of residence;
• Contact — email address, telephone number, postal address, and the content of messages you send us;
• Financial — payment card or other payment details, billing address, and purchase and payment history (we do not store full payment card details, which are processed by our payment service provider);
• Profile — your marketing preferences, account settings, and any feedback you provide through reviews and surveys;
• Social — if you register or log in using a Facebook, Google or Apple account, the contact information and account identifier associated with that account;
• Verification — information used to verify your age, identity and eligibility, including any documentary evidence we ask you to provide.
We also collect the following information when you use the Website, using cookies and similar technologies (see our Cookie Policy):
• Usage — information about how you use the Website, such as the pages you view, time spent on page and click-throughs; and
• Technical — your IP address, browser type, device information, operating system and other identifiers.
When we use your personal data, we must have a legal ground (a "lawful basis") for doing so. We may rely on more than one lawful basis depending on the purpose. The table below sets out how and why we use your personal data and the legal ground we rely on.
Why we use your data Data used Legal ground Register you as a customer Identity, Contact, Profile, Social Performance of a contract with you Enable you to log in to your account Identity, Contact, Social Performance of a contract with you Enable you to enter a Competition, including by free postal entry Identity, Contact, Financial Performance of a contract with you Process the payments you make Identity, Contact, Financial Performance of a contract with you Verify your age, identity and eligibility, and prevent and detect fraud and underage participation Identity, Contact, Verification, Technical Compliance with a legal obligation; and our legitimate interests (preventing fraud, crime and underage participation) Draw the Competition and arrange delivery or collection of a prize Identity, Contact Performance of a contract with you Operate our Mindful Play tools and help protect customers from harm Identity, Contact, Profile, Financial Our legitimate interests (customer protection); and compliance with applicable codes of practice Internal administration and record keeping All Performance of a contract; compliance with a legal obligation (e.g. tax); and our legitimate interests (effective administration) Notify you of changes to our Terms and Conditions or policies Identity, Contact Performance of a contract; and compliance with a legal obligation Answer your enquiries and handle complaints Identity, Contact, Profile Performance of a contract; and our legitimate interests (responding to and supporting our customers) Send you marketing about our competitions, products and offers Identity, Contact, Profile Consent; or our legitimate interests where permitted by law, in each case with an opt-out Personalise your experience of the Website and the advertising you see Identity, Contact, Profile, Usage, Technical Consent Provide, secure and improve the Website Usage, Technical Our legitimate interests (providing a functional and secure service) Obtain feedback through reviews and surveys Identity, Contact, Profile Our legitimate interests (improving our services) Comply with legal and regulatory obligations and establish, exercise or defend legal claims All Compliance with a legal obligation; and our legitimate interests (protecting our rights)
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 a compatible purpose. If we need to use it for an unrelated purpose, we will notify you and explain the legal ground that allows us to do so. We may also anonymise and aggregate your personal data so that it no longer identifies you, and use that anonymised data for any purpose.
3. WHO DO WE SHARE YOUR DATA WITH?
We do not sell your personal data, and we do not share it with third parties for them to market their own products or services to you without your consent. We do share your personal data with the following categories of recipient, in each case only to the extent necessary and subject to appropriate confidentiality and security obligations:
• our payment service providers, to process your payments;
• the providers of our website, hosting and e-commerce platform;
• our free postal entry handler and our prize delivery and fulfilment partners;
• our analytics, advertising and marketing providers;
• identity, age-verification and fraud-prevention providers;
• our professional advisers, including auditors, lawyers and other advisers, and any independent draw or verification service we use;
• other companies within the Winvia Group, who provide us with support services (including customer service, fraud prevention and technology) and, where you have consented, marketing;
• a buyer or prospective buyer of our business, if we sell or reorganise all or part of it; and
• courts, regulators, law enforcement and other authorities, where we are required or permitted by law to do so.
4. INTERNATIONAL TRANSFERS OF YOUR DATA
We may transfer your personal data between Gibraltar and the United Kingdom. Gibraltar and the UK each recognise the other as providing an adequate level of data protection, so these transfers are permitted without further safeguards. Where we transfer your personal data to a country outside the UK, Gibraltar or the European Economic Area that has not been recognised as providing an adequate level of protection, we put in place appropriate safeguards (such as the UK International Data Transfer Agreement or the European Commission’s standard contractual clauses) to ensure your data remains protected. If you would like more information about these safeguards, please contact us using the details below.
5. HOW WE KEEP YOUR DATA SECURE
We adopt industry-standard security measures to keep your personal data safe and to prevent unauthorised access, use, loss or disclosure, and we require the third parties we work with to apply suitable confidentiality and security standards. However, the transmission of data over the internet is not completely secure, and we cannot guarantee the security of any data you transmit to us over the internet; any such transmission is at your own risk.
6. HOW LONG DO WE KEEP YOUR DATA FOR
We keep your personal data for as long as you hold an account with us and we have a legal ground to do so. We keep personal data that we process to perform our contract with you until that contract has been fully performed, and personal data that we process for our legitimate interests for as long as is necessary to fulfil those purposes. After your account is closed, we may still need to retain certain personal data where we have a legal or regulatory reason to do so (for example, to meet our tax and accounting obligations, to prevent and detect fraud, or to establish, exercise or defend legal claims). Once we no longer need your personal data, we securely delete it.
7. COOKIES
We use cookies and similar technologies on the Website. For full details of the cookies and trackers we use, their purposes, and how you can manage your preferences, please see our Cookie Policy on the Website.
8. LINKS TO THIRD PARTY WEBSITES
The Website may contain links to other websites. Once you leave the Website, we have no control over those third-party websites and are not responsible for the protection or privacy of any information you provide while visiting them. Your use of those sites is not governed by this Privacy Policy, and you should review the privacy and cookie policies that apply to them.
9. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. The current version will always be available on the Website, so please check back regularly. If we make any significant changes, we may also notify you by email where appropriate.
10. YOUR RIGHTS
Subject to applicable law, you have the following rights in relation to your personal data:
• to access a copy of the personal data we hold about you;
• to have your personal data corrected or updated (you can update much of this yourself in your account);
• to ask us to erase your personal data;
• to ask us to restrict our processing of your personal data;
• to object to our processing of your personal data where we rely on our legitimate interests;
• to ask us to transfer your personal data to you or another organisation (data portability);
• where we rely on your consent, to withdraw that consent at any time (although we may continue to process your data if we have another lawful basis); and
• rights in relation to automated decision-making and profiling that produces legal or similarly significant effects.
Some of these rights only apply in certain circumstances. If you wish to exercise any of them, please contact us using the details below. You also have the right to make a complaint to a data protection regulator. In the United Kingdom, this is the Information Commissioner’s Office (ICO) (www.ico.org.uk); in Gibraltar, this is the Gibraltar Regulatory Authority (GRA) (www.gra.gi). We would, however, appreciate the opportunity to address your concerns before you approach a regulator, so please consider contacting us first.
11. HOW TO OPT OUT OF MARKETING
You can opt out of our marketing at any time, either by contacting us or by using the unsubscribe link in any marketing email or the opt-out details in any marketing message. Please note that we may still need to send you service communications (for example, to tell you about changes to our terms or policies, or about a Competition you have entered).
12. CONTACT US
If you have any questions about this Privacy Policy, wish to exercise your rights, or would like to make a complaint, please contact us:
• by email at hello@revcomps.com; or
• by post at Rev Competitions Limited, Madison Building, Midtown, Gibraltar, GX11 1AA.