Privacy Notice
Last updated: [date] · Version 0.1 (draft)
1. Who we are
Crazy-Odds ("we", "us", "our") is the data controller for the personal data described in this notice. [Insert registered company name, company number, registered address, and — if required — our Information Commissioner's Office (ICO) registration number.] You can contact us about privacy matters at [privacy email].
2. What personal data we collect
- Account data: full name, email address, mobile number, date of birth, postal address, country, and password (stored as a salted hash, never in plain text).
- Order and entry data: which competitions you've entered, ticket numbers, amounts paid, payment status, and the answer you submitted to each skill question.
- Payment data: our payment provider processes your card details directly — we do not store full card numbers. We retain a payment reference and transaction status.
- Agent data (if applicable): referral code, referred customers, and commission records.
- Communications: messages you send us via the Contact form or support requests, and your marketing preferences.
- Technical data: IP address, browser/device information, and cookies — see our separate Cookie Policy.
3. Why we process your data, and our legal basis
- To create and manage your account, and to process and fulfil competition entries — necessary for the performance of our contract with you.
- To verify your age and identity, particularly before releasing a prize or cash alternative — necessary for legal compliance and to protect against fraud (legitimate interests).
- To run and publish competition draws and winners — performance of our contract with you and legitimate interests in running a transparent, auditable competition.
- To administer the agent referral programme and calculate commission — performance of our contract with agents.
- To send you service communications (order confirmations, winner notifications) — necessary for the performance of our contract with you.
- To send you marketing communications — only where you have opted in (consent), and you may withdraw this at any time.
- To detect and prevent fraud, duplicate accounts, and abuse of the platform — legitimate interests.
- To comply with our legal, tax, and regulatory obligations, including record-keeping for prize competitions.
4. Who we share your data with
- Our payment provider, to process transactions securely.
- Our email and (where applicable) SMS providers, to send order and account notifications.
- Identity verification providers, where used for high-value prize claims.
- Professional advisers (solicitors, accountants) where necessary.
- Law enforcement or regulators, where we are legally required to do so.
- We do not sell your personal data to third parties.
5. International transfers
Where any of the providers listed above are based outside the UK or European Economic Area, we ensure an appropriate safeguard is in place, such as the UK International Data Transfer Addendum or an adequacy decision. [Confirm and list specific providers and safeguards once vendors, including the payment provider and email provider, are finalised.]
6. How long we keep your data
- Account data: for as long as your account is active, and for a limited period afterwards to meet legal, tax, and dispute-resolution obligations.
- Order, entry, and draw records: retained for the period required to demonstrate the fairness and auditability of each competition, and to meet tax obligations — [confirm exact retention period with a solicitor, typically several years].
- Marketing consent records: until you withdraw consent, plus a short period to evidence that withdrawal.
- We will delete or anonymise personal data once it is no longer needed for these purposes.
7. Your rights
Under UK data protection law, you have the right to:
- Access the personal data we hold about you.
- Have inaccurate data corrected.
- Request deletion of your data, subject to our legal retention obligations.
- Object to or restrict certain processing.
- Request a copy of your data in a portable format.
- Withdraw consent to marketing at any time.
- Complain to the Information Commissioner's Office (ICO) at ico.org.uk if you believe we have not handled your data properly.
To exercise any of these rights, contact us at [privacy email] or via our Contact page.
8. Cookies
We use cookies and similar technologies to run the Site and, where you consent, for analytics and marketing. See our Cookie Policy for full details and how to manage your preferences.
9. Children
The Site is not intended for anyone under 18. We do not knowingly collect personal data from children.
10. Changes to this notice
We may update this notice from time to time. Material changes will be highlighted on the Site.
11. Contact
Questions about this notice, or requests relating to your data, can be sent to [privacy email] or via our Contact page.