17. PRIVACY POLICY

17.1 Introduction

This Privacy Policy explains how Combrook Limited trading as Comp Central (“Comp Central”, “we”, “us”, “our”) collects, stores, processes and protects personal data when individuals access or use the Website, enter Competitions, contact us, or otherwise interact with our services.

We are committed to safeguarding personal information and processing it lawfully, fairly and transparently in accordance with:

• UK GDPR;
• Data Protection Act 2018; and
• applicable electronic communications laws.

Our contact details are:

Combrook Limited t/a Comp Central
Company Number: 12789408
Address: 3A Mill Lane, Cheshire, SK11 7NN
Website: comp-central.co.uk
Email: support@comp-central.co.uk

17.2 Information We Collect

We may collect and process the following categories of information:

Identity Information

• full name;
• date of birth;
• photographic identification (where required).

Contact Information

• postal address;
• email address;
• telephone number.

Account Information

• username;
• account preferences;
• login activity.

Competition Information

• Competition entries;
• ticket allocations;
• winnings;
• free postal entries.

Payment Information

Payments are processed by third-party payment providers.

We do not store complete debit or credit card information.

We may retain:

• payment references;
• transaction identifiers;
• partial payment information;
• billing records.

Technical Information

• IP address;
• browser type;
• device identifiers;
• cookies;
• operating system;
• browsing behaviour.

Marketing Information

• marketing preferences;
• consent records;
• communication history.

17.3 How We Use Personal Data

We use personal information to:

Competition Administration

• process Competition entries;
• verify eligibility;
• allocate entry numbers;
• select Winners;
• fulfil Prize delivery.

Identity & Fraud Prevention

• verify age and identity;
• prevent fraud;
• investigate suspicious activity;
• comply with anti-money laundering obligations.

Customer Support

• respond to enquiries;
• resolve disputes;
• administer accounts.

Website Security

• maintain Website integrity;
• monitor misuse;
• prevent cyber threats.

Marketing (Only Where Consent Has Been Given)

• provide offers;
• send promotions;
• notify users of Competitions.

Marketing is entirely optional.

Entering a Competition does not automatically opt a person into marketing communications.

17.4 Lawful Basis for Processing

We rely upon the following lawful bases under UK GDPR:

Contract

Processing required to administer Competitions and fulfil obligations.

Legal Obligation

Compliance with fraud prevention, accounting, tax, regulatory and legal obligations.

Legitimate Interests

To operate and improve the business, Website security, fraud prevention and customer management.

Consent

Marketing communications and non-essential cookies.

Consent may be withdrawn at any time.

17.5 Sharing Information

We may share personal data with:

Service Providers

• payment processors;
• hosting providers;
• customer support systems;
• email service providers;
• fraud prevention systems.

Delivery Partners

For Prize fulfilment.

Professional Advisers

Including accountants, insurers, auditors and solicitors.

Regulatory Bodies

Law enforcement, regulators or government authorities where legally required.

We do not sell personal information to third parties.

17.6 International Transfers

Where personal data is transferred outside the United Kingdom, appropriate safeguards shall be implemented to ensure lawful protection.

17.7 Data Retention

Personal information shall be retained only for as long as reasonably necessary.

Retention periods may vary depending upon:

• legal obligations;
• fraud prevention;
• accounting requirements;
• dispute resolution.

We may retain records for up to six years where legally or commercially necessary.

17.8 Your Rights

Individuals have rights to:

• access personal data;
• request correction;
• request deletion;
• restrict processing;
• object to processing;
• request portability;
• withdraw consent.

Requests should be sent to:

support@comp-central.co.uk

We may request proof of identity before responding.

Individuals also have the right to complain to the:

Information Commissioner’s Office.

18. MARKETING COMMUNICATIONS

18.1 Separate Consent

Marketing consent is entirely separate from Competition entry.

Users shall only receive promotional communications where they have actively opted in.

Marketing May Include:

• Competition launches;
• promotions;
• special offers;
• Winner announcements;
• exclusive discounts.

Communication Methods

• email;
• SMS;
• push notifications;
• telephone (where consented).

18.2 Withdrawal of Consent

Consent may be withdrawn at any time by:

• clicking the unsubscribe link;
• updating account preferences;
• contacting:

support@comp-central.co.uk

Withdrawal of consent shall not affect lawful processing undertaken before withdrawal.

18.3 Service Communications

The Promoter may still send service-related communications necessary for:

• account management;
• Competition updates;
• payment confirmations;
• Winner notifications;
• legal notices.

Such communications do not constitute marketing.