Privacy Policy
This Privacy Policy explains how {{brand}} collects, uses, and protects personal data when you use the website and the competition system. Pre-release draft.
Privacy focuses on personal data. Terms focus on website access and competition participation. Read both for a complete picture.
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1. Summary
Key points up front.
We process personal data to operate the Service, secure it, verify results, and communicate with users.
We do not sell personal data. We share data only with service providers and where required to operate or comply with law.
- Minimum necessary data: we collect what is required for integrity and support.
- Security: we use access control and technical safeguards appropriate for an online service.
- Controls: you can request access, correction, deletion, and other rights described below.
2. Data we collect
Categories of personal data.
Depending on your use of the Service, we may collect the following:
- Identity and contact details (for example, name, email) if you create an account or contact support.
- Account data (login identifiers, settings, consent preferences).
- Competition data (Attempts, Results, ranking position, and verification flags).
- Transaction metadata from payment providers (we do not store full card numbers).
- Support interactions and messages you send to us.
- Technical usage data (IP address, device/browser, log events, and performance metrics).
If verification is required to confirm the winner or deliver a prize, we may request additional information as described in Rules or notices on the website.
3. How we use data
Purposes of processing.
We use personal data to operate and protect the Service, including:
- Provide the website, accounts, and competition features.
- Verify Attempts and Results, detect abuse, and maintain leaderboard integrity.
- Maintain security, prevent fraud, and monitor performance.
- Communicate updates, critical notices, and support responses.
- Improve user experience, documentation, and system reliability.
- Comply with legal obligations and enforce Terms and Rules.
4. Legal bases
Why we are allowed to process data.
Where applicable (for example under GDPR), we rely on these bases:
- Contract: processing needed to provide the Service you request.
- Legitimate interests: security, abuse prevention, and service improvement.
- Consent: where you opt in to optional cookies or non-essential communications.
- Legal obligation: record-keeping or compliance when required by law.
5. Sharing and processors
Who may receive data.
We share personal data with service providers who help us run the Service. They process data under agreements and instructions.
- Infrastructure and hosting providers.
- Analytics and monitoring providers (focused on reliability and usage patterns).
- Email delivery providers for transactional messages.
- Support tools used to respond to requests and manage tickets.
- Verification and risk partners to confirm winner eligibility and protect integrity (where applicable).
- Authorities or professional advisors when required by law or to protect rights.
We may disclose limited public information on leaderboards as part of the public ranking concept (for example, nickname and ranking position).
6. International transfers
Where data is processed.
We aim to process data in the EEA where practical, but some providers may process data in other countries.
When transfers occur, we use safeguards such as contractual clauses or equivalent mechanisms where required.
7. Retention
How long we keep data.
We retain personal data as long as necessary to provide the Service and for legitimate operational needs.
- Account data: until you delete your account or it becomes inactive for an extended period.
- Security and access logs: retained for a limited period for integrity and security purposes.
- Records required for legal compliance: retained for the period required by applicable law.
Retention periods may change as the product matures; we update this document accordingly.
8. Security
Protection measures.
We use technical and organizational measures to protect personal data against unauthorized access, alteration, or loss.
- Access control: limited access on a need-to-know basis.
- Encryption in transit and at rest where appropriate.
- Monitoring and logging to detect and respond to incidents.
No system is perfect. If an incident occurs, we will take reasonable steps to mitigate and provide notices when legally required.
9. Your rights
Choices and requests.
Depending on your jurisdiction, you may have rights over your personal data, including:
- Access: request a copy of your data.
- Correction: fix inaccurate or incomplete data.
- Deletion: request deletion in certain circumstances.
- Objection: object to certain processing, including some analytics.
- Portability: receive data in a structured format where applicable.
- Withdraw consent: where processing is based on consent.
We may ask you to verify your identity before fulfilling requests.
10. Cookies and similar technologies
What we store on your device.
We may use cookies or local storage to keep the Service functional and remember preferences.
- Essential: required for core functionality and security.
- Preferences: remember settings such as language.
- Measurement: help us understand usage patterns and reliability (where enabled).
You can control cookies through your browser settings. Disabling essential cookies may affect functionality.
11. Children
Age limits.
The Service is not intended for children. Do not use the Service if you are under the age of majority.
If you believe a child has provided personal data, contact us and we will take reasonable steps to delete it.
12. Changes to this Policy
Updates are versioned.
We may update this Policy from time to time. The “Last updated” date shows the latest published version.
Material changes may be announced on the website before they take effect, where feasible.
13. Contact
How to reach us.
Privacy requests and questions: [email protected] (address and operator details will be published before launch).
If you have a complaint, you may also contact your local data protection authority where applicable.