Privacy Policy

Last updated: March 2019

Who is Processing Your Personal Data?

Dalma Media Sp. z o. o.( Dalma Media Sp. z o. o.a, we, us, our) is the registered owner of these prize draw service websites and owns all rights, including the sitesʼ respective IP, copyrights and trademarks. We are registered with the ICO office (The Information Commissioner's Office in the United Kingdom) as a Data Controller and Data Processor under the Trading Name Dalma Media Sp. z o. o. Ltd, with Registration Number. This privacy policy applies to the following websites owned and operated by us (collectively to be called the sites):
www.luckybritain.co.uk
Our Commitment to Protecting Your Personal Data
Dalma Media Sp. z o. o. is committed to protecting your data. We collect your personal data to help us understand your needs and guides the way in which we interact and communicate with you about ours, and our trusted third parties (subject to your consent) products and services. We ensure policies and procedures are in place to protect the data you provide when registering to our sites, and we process it in order to provide you with the services you have requested or, where you have given us your permission to do so, to send you information that we think you'll find interesting, and thereafter when we store your data on our secure servers.We work within the guidelines and advice provided by and made available by the Information Commissioner's Office, the regulator of the Data Protection Act 2018 and abide by the ICOʼs requirements.
We seek to fully comply with the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003, the Electronic EU Regulations 2011 and the EU General Data Protection Regulations (GDPR). If you wish to find out more, please visit ico.org.uk/.

Purpose of this Privacy Policy

This Policy sets out how we manage, use and protect your personal data collected while using our sites.
We will only use or share your personal data in a manner that is in accordance with this Privacy Policy, and as stated within the registration opt-in definition, and only where we have obtained your prior active consent. Consent is obtained using clear and specific statements that are prominently displayed as part of the registration process on the sites.

Our Purpose for Processing Your Personal Data

Dalma Media Sp. z o. o. has 3 main business purposes;
1. To manage the participation of the registered individual in draws and/or promotions organised by us;
2. To meet the purposes of funding our free websites. The commercial use of our competition website prizes are mainly funded by advertising and through the sending of commercial communications of named third parties, the carrying out of branded surveys, market and/or product/item reviews etc. To this end, it is necessary to submit the data of a consumer that registers on our site (registered individual) to standardisation, filtering and verification. The categories and methods of marketing communication which the registered individualʼs may receive will be determined, subject to their active consent. All Companies and Partners are listed on our site (except for our branded surveys, which would rely on your explicit consent prior to agreeing to your details being shared), prior to registering.
3. To communicate, (via email, telephone or the chosen contact method) the data of interest to LuckyBritain selected companies and trusted partners (named third party companies). Advertising will be sent by these named third party companies, subject to explicit, active consent by the registered individual prior to signing up or registering to our websites.
4. We will only minimize the data and process only where it is adequate relevant and limited to what is necessary in relation to the purposes stated above, in accordance with Art. 5 (1), (c) of the GDPR);

Our Legitimization for Processing Your Personal Data

Our legitimate interest basis for obtaining and processing of your data is to:
1. manage your (as the registered individual) participation in our draws, promotions and/or device testing campaigns on our owned sites – such as maintaining your registration to our site;
2. improve and personalise our site to you, and this could be where we may market directly to you, about other relevant offers that may be of interest to you;
3. determine whether any of our trusted Partners we work with may have services, products and offers that may be of interest to you based on your preferences; and
4. where appropriate, relevant (and with consent) communicate your data to our trusted Partners. You may object to this processing at any time by emailing us: dpo@dalmamedia.com

Collection and Use of Your personal data

We collect your details when you register or visit on one of our websites; subscribe to our service; correspond with us by phone, e-mail or otherwise. ‘personal dataʼ or ‘personal dataʼ means the information you provide during the registration process and any information you provide when entering prize draws, quizzes, surveys or competitions. Registration is required to participate in any of the branded surveys on the site, however merely browsing does not require registration.
The categories of personal data we may collect from you upon registration of via visiting our website:
- Your name
- Your title
- Your date of birth
- Your contact information, including email and phone numbers
- Demographic information
- Your address and postcode
- Your IP address or other online identifiers such as Cookies

Use of Your Personal Data

We use your personal data collected via the Dalma Media Sp. z o. o. sites to:
- Provide you with information about the products and services we offer
- Provide you with a more personalised service
- Conduct market research
- Run prize draws and promotions
- Pass on your details to selected Companies and Trusted Partners which provide you with other offers and promotions of interest to you
- For analysis purposes or to build data products. In these instances, the information is aggregated and wherever possible anonymised in line with the ICOʼs code of practice. Again, these products are of a marketing nature.
We may process your personal data ourselves or through data processors that will process data on our behalf (we retail full responsibility) for ensuring the data processor complies with this policy and all current data protection regulations).
Depending on the consents that you set up at the time of registration and what personal data we hold about you, we may pass your personal data to Site Sponsors, Brand Partners or Data Partners (collectively athird partiesa) who may contact you by post, email and telephone for direct marketing purposes.
Email and Telephone data will only be released to third parties where you have given your positive consent (usually at the time of registration) allowing you to fully understand your registration preferences.
You can change or update your communication preferences at any time here dpo@dalmamedia.com
Telephone data will only be rewww.luckybritain.co.uklly selected partners where it has been TPSʼd (see ‘Opting Outʼ below). Note: if you request a call from one of our sponsors or brand partners this will override the TPS.
We will only store your data in accordance with our Data Retention Policy. View our privacy policy here
For more information on how your Data is passed on when participating in a Branded Survey, refer to 27-33.

Profile Matching (aka Profiling)

To enhance the services we provide, we aim to match your profile to third companies that we determine from analysis, that will have goods or services that would be of interest to you. It makes sense for us to ensure that you only receive offers that are relevant to you and fit within the context of your lifestyle and available purchasing power. For example, if you have provided your car insurance renewal data and have consented for third parties to contact you about one month before your renewal date, we will work with third party brand partners to send you a car insurance quote tailored to your needs – thus saving you time researching the entire market.
The data that we provide our third parties may be added to the information that they already hold about you. So, a car insurance company will check whether you have been a customer of theirs before. This is to ensure that they provide the right types of products, services and pricing to you. When first contacting you, they always will seek your appropriate opt in and consent.
Data sharing in this way allows them to contact you in their own name about their products, services, promotions, offers and competitions, and/or to update their records for fraud prevention, debt tracing and anti-money laundering purposes.
We will share your data with the Marketing Services Providers listed below, who will use it to create products and services to help organisations better understand the likely characteristics of their customerʼs characteristics and communicate with them more effectively, and enhan find others like them across a range of marketing channels. This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website. To understand more please visit through to the websites of the companies below;
Experian Ltd- http://www.experian.co.uk/marketing-services/about/marketing-data.html

Marketing to Children

We do not knowingly, deliberately or aim to, collect personal data from children under the age of 18, either for registration or for marketing purposes. Our sites all ensure that a ‘You Must Be 18+ To Enterʼ disclaimer is included in the registration section.

Our Partners and their Industry Sectors

Our trusted Partners, both sponsors of the site and particular surveys, may wish to contact you based on your profile, but will only do so subject to your consent and preferences. They operate within the following industry sectors:

Sector	Description & Examples
Retail	General Stores Online retail Utilities
Finance	Banking Claims companies Loans, credit cards and mortgages
Gambling	Lottery, casino, betting
Insurance	Personal
Travel	Holidays
Lifestyle	Online sweepstakes
General	Call centre Data processor
Utilities	General

You may choose to restrict the collection or use of your personal data in the following ways:
- Our website forms will always have an unticked box for third party telephone marketing, which you can optionally select upon registration so that your personal data can be passed on to our third parties for direct marketing purposes. Our website forms will always have an unticked box for offer base email marketing, which you can optionally select upon registration so that Dalma Media Sp. z o. o. can send you emails from selected companies (listed at collection) for direct marketing purposes.
- You can control the channels of which you receive marketing, whether by email, phone, SMS by selecting the appropriate unticked box in our website forms, which determine the method by which you wish to be contacted;
- Where consent has been previous obtained to us or our trusted partners to using your personal data for direct marketing purposes, you can change your mind at any time by emailing our Data Protection Officer: dpo@dalmamedia.com
- WhatsApp - When joining our WhatsApp messaging list, a user provides explicit consent to receive WhatsApp messages from us by following these steps:
  - Adding the phone number stated on the signup page to their address book
  - Actively sending a message to that number that says ‘Startʼ
- Push Notifications- When joining our push notification list for sending offers you provide us with direct consent to send you push notifications by explicitly turning on this browser-level permission.

Your Rights

You have the right to:
1. obtain access to your personal data;
2. receive information about us and the purposes for which we process your personal data;
3. prevent processing which may cause you damage or distress;
4. object to direct marketing and select the contact channels by which we market
5. object to purely automated decision-making in certain cases;
6. you have the right to seek compensation through the civil courts for a breach of a data controllerʼs obligations
7. ask us to correct any errors and/or delete the information we hold
8. Be forgotten by requesting all personal data collected from you, by us, be deleted completely from our database, systems and servers
9. opt out of any further contact by us or selected brand partners or sponsors
10. Be notified in the event of a data breach, where data lost or stolen involves your personal data and
11. Write to, report, or complain to your relevant supervisory authority, depending on your EU Member State (example, for UK data subjects, it is the ICO).
  If you would like to amend/delete details or contact us in relation to the above, please contact using the ‘Contact Usʼ page.

(*) We may reserve the right to retain personal data where a reasonable expectation exists in order to fulfill an obligation. This may include suppression, ie. to block future communications received by request of the data subject, a regulatory authority or by law. In this event,the data subject will be informed accordingly of our reliance on this expectation(s).

Your Data and our Data Partners

Your 'Registration Details' (and other details depending on which activities you chose to participate in on the Site) will be shared, by way of either single or multiple use data licences, with selected Data Partners who may then contact you by email, telephone or post depending on the consents that you supplied us at the time of registration or subsequently.
We usually only permit Data Partners to use these details to contact you for a pre-specified limited period And they, like us, are obliged to comply with all relevant data protection requirements regarding their holding and use of these details including screening (according to the method used to contact you) against the Telephone Preference Service (TPS) and Mailing Preference Service (MPS) prior to use. Your IP address (see 'Cookies' section 46 for more details) will not be shared with our Data Partners unless you participate in their Branded Survey (see below).
Participating Data Partners may also use your personal data for the purposes of fraud prevention, e.g.: anti-money-laundering and debt tracing according to their privacy policies.

Branded Surveys on the Site

If you take part in a branded Survey on the site, then we will, in addition to the Registration Details referred to above, provide the Survey Sponsor (who will be clearly named) with your personal data as follows ('Survey Details')
IP address (the unique numbers that identify the computer you are using to participate in the Survey)
Your responses to the Survey and date of response and any other information specific to the Survey that you are asked to provide
Cookies captured from your use of the Site generally and in completing the Survey.
The Survey Sponsor will use your responses and the Registration Details to identify what future competitions, surveys, offers, and information about their products and services you may be interested in, and to contact you by the methods referred to above. We do not place a specific timeframe on their use of the Registration and Survey Details
Please note as part of the registration process and completing the branding surveys and giving your consent you are agreeing to be contacted by the companies running the Branded Surveys by the methods referred to in 6.2, including by telephone. This will take preference over any registration that you may have with the TPS (Telephone Preference Service) of the number you have provided to us or updated with us. It is always your choice as to whether you want to receive such calls, so if you are registered with the Telephone Preference Service and decide you no longer wish to hear from Dalma Media Sp. z o. o., you can leave the Dalma Media Sp. z o. o. Scheme at any time.
If you no longer wish to hear from any of the companies running the Surveys who have received your personal data, you will need to contact each of them directly to request this. This also applies to any other preference service you may have registered with such as the Mailing Preference Service.

Entering a Prize Draw

All prize draws on the Site will be clearly marked as either being sponsored by us or a named third-party sponsor ('Competition Sponsor'). Your Registration Details, that you submit when entering the competition will be used to administer the competition and as follows:

If you enter a prize draw which is sponsored by us, this personal data may be, subject to your consent, shared with our Data Partners.
Some prize draws have additional provisions for how your personal data is used. Please ensure you read the particular terms and conditions for each prize draw before taking part in that prize draw.

Opting In / Opting Out

You have the option of Opting In or Out of receiving marketing communications from ourselves and our various partners at any time - including at registration by choosing the To enter without receiving marketing messages.
When registering your details, you will be required to actively opt in to;
1. receive offers and updates by email, telephone and post from selected third party companies which we believe will be of interest.
2. Agree that our trusted partners may contact you with more interesting offers by telephone
3. Acknowledge that you have read, understood and agreed to our terms prior to registration.
Dalma Media Sp. z o. o. will always remain transparent in disclosing how we intend to process your data, and where your data may be passed on, subject to your consent and preferences upon registration. All companies and partners we work with will be named, and the categories in which they operate in will be made available to you. These opt-ins are optional and only when you put a tick in the box will you consent to receive additional marketing communication.
By registering or signing up, it is made clear, in plain english that by doing so, you have read, acknowledged and agreed to the terms and conditions and this privacy policy, which governs how your information will be processed, and that consent upon registration to receive marketing communications from LuckyBritain
You may change your preferences at any time via the How to Unsubscribe pages once you are registered.
Third-party providers are able to send you communications via email, post or telephone only until such time as you exercise your right to opt out of receiving such communications. However please be aware that marketing campaigns are often planned well in advance, so your changes will be accepted immediately, but may not be effective immediately.
In addition, Website Sponsors have their own privacy policies and some have their own opt-in statements. It is strongly recommended that you read and understand this information.

Opting Out – Additional Information

You can unsubscribe or opt out from any communications from our scheme or any third-party brand at any time as indicated above, but you may also wish to consider the following for a more general Opt-Out.
Opting Out – Postal Contact You can withdraw your consent for postal marketing from anyone by adding your details to the Mail Preference Service.

Opting Out – Email or SMS (text message) Contact You can unsubscribe from receiving e-mail or SMS marketing communications from any individual third-party by using the instructions in any email communication such third-party sends you (usually an ‘unsubscribeʼ or ‘STOPʼ link).

Opting Out – Telephone calls To withdraw your consent for live or automated calls from anyone, you can add your name to the Telephone Preference Service which is maintained at this website address: www.tpsonline.org.uk

Opting Out – Social Media. You can configure your advertising preferences on social media such as Facebook, Twitter, Instagram or Pinterest by accessing your settings or preference options on the relevant platform.
You may unsubscribe from our WhatsApp mailing list at any time. To unsubscribe you may do any of the following:
- Reply to any of our messages with 'Stop' to unsubscribe
Push Notification - You may unsubscribe from our browser notification mailing list at any time. To unsubscribe you may: Follow the instructions on this page

Data Safety Outside the European Union

You should be aware that some external data processors may be based outside the European Union, whose laws provide a different standard of protection than that provided under English law. We will not release your data to a non-EU country processor without performing proper due diligence as to the standards of data protection within the specified country and proof of compliance with the standards of the UK Data Protection Act 2018 and other relevant legislation. Such requirements will be part of a formal and legally binding Data Processing agreement.

Security and Storage of Your personal data

We store all data collected in an encrypted environment and only for as long as is necessary However, despite our best efforts the Internet is not 100a secure and we cannot guarantee the security of any information you send to us via the Internet. We will not be responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.

IP Address/Cookies

We automatically collect your IP address and record the web page from which you originated if you are using the serviceʼs website.
Cookies are used to increase your security, not infringe on your privacy. Cookies are needed to monitor, facilitate, administer and optimise the website and service for users and to earmark any possible technical issues that may arise within the website or the service. We may use your IP address to help identify you, tend to any difficulties and to gather demographic and profile information. We also use the ‘cookiesʼ to collect information about your online activity on our website, such as the web pages you visit, the links you click, and the searches you conduct on our website.
Most browsers automatically accept cookies, but you can modify your web browser setting to decline cookies. If you choose to do this, you may not be able to avail yourself of some or all of the functionalities that the website or the service may offer.
The type of cookies that we use on our sites are:

Cookie	Name	Purpose
Google Analytics	_ga __utma __utmb __utmc __utmv __utmz	These cookies allow LuckyBritain to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google
Google Adsense	__gads _drt_ id	Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Googleʼs advertising services, Google may set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain adoubleclick.neta.
Pingdom	PRUM_EPISODES	Allows us to monitor user experience
Essential site cookies	cookiesenabled cookietest ASP.NET_SessionId qb:nnnn	These cookies are essential for the operation of the LuckyBritain website.

Access, Rectification and Erasure of your personal data

You may request access to, rectification and/or erasure of any personal data which we hold about you under the Data Protection Act 2018 and the GDPR.
If you believe that any information we are holding on you is incorrect or incomplete, or you would any data we may hold about you to be completely deleted, please write to or email us as soon as possible, at address below. We will promptly endeavour to correct any information found to be incorrect.
If you have questions regarding this Privacy Policy, please contact us by following: Email - dpo@dalmamedia.com or by post: The Data Protection Officer
Dalma Media Sp. z o. o. ,
Jana Matejki 65A/3
Poznan 60-771
Poland

Changes to this Policy

We 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. This policy is effective from 10th March 2019.

Terms & Conditions

Organiser

Entrants

Winners

Prize

Prizes

Personal Information