Data protection and privacy is very important to us, LUCKY DIGITAL MARKETING LTD (hereinafter "LUCKY DIGITAL MARKETING LTD" or "we"), 27 Old Gloucester Street, WC1N 3AX, London, United Kingdom, Company Number 076258852. In our position as data controller we would like to inform you of the nature, scope, and purposes of any collection, storage, transfer, and/or use of personal data, complying in the process, already at this time, with the specifications of the EU General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003. For this reason, the relevant standards are already mentioned at this time in this data protection and privacy statement.
This statement provides you with information on all aspects of our offering that are relevant in terms of data protection and privacy, particularly:
1. Which personal data we collect and store
If you utilise our offering and/or use our website by filling out the entry fields and/or contact us and/or merely visit our website, we may collect personal data as follows:
Personal data that you provide us by utilising our offering and/or using our website may be collected. If one or several provisions of this Agreement should be or become lawfully ineffective, this shall not impair the validity of the other provisions. The invalid provision will be replaced as quickly as possible with another provision most closely approximating the economic intent and content of the invalid provision. “Personal data” includes your name, e-mail address, phone number, and any interests, etc., that may be identified in surveys.
To the extent when you enter into a contract on our website or issue a declaration of intent, we store the information for an order and, if any, payment details associated therewith.
To the extent that you answer any questions regarding your preferences, interests, user behaviour, etc. after participating in the prize draw and/or your interests become apparent because you sign up for a sample subscription or similar items, we will also store this information to establish a personal user profile. This user profile enables interest-driven, optimised direct marketing which seems reasonable for both sides to ensure that you will 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 gas provider and have consented for third parties to contact you, we will work with third party brand partners to send you a utility quote tailored to your needs – thus saving you time researching the entire market.
We also collect and process personal data that you provide to us by contacting us.
Personal data that may be collected through your visit to our page, particularly data traffic, location and time information, IP addresses, browser and device ID and other communication information provided through the use of your computer.
Further data – such as local times, time zones, and usage data – may also be stored in addition to the data specified above.
Statistical data may be collected and used in the case of a visit to our website. “Statistical data” means, among other things, data regarding the use of an Internet browser and the browser version.
2. How and why we process and transfer your personal data, and what it is used for
The data collected during registration to the prize draw is used to conduct the prize draw, determine the winner, handle the awarding of prizes and notify the winner and transmit the prize (Article 6(1)(b) GDPR).
If, after the conclusion of the prize draw, declarations of intent for purchase, service, or other contracts with external companies are received, the data collected, where applicable, and further data collected on a contract-specific basis will be disclosed to the external company or companies in question. Otherwise those companies cannot use the data to establish or perform a contract or contracts (Article 6(1)(b) and (f) GDPR).
Based on the participation agreement that is entered into and in the event of an online participation in a prize draw, LUCKY DIGITAL MARKETING LTD will collect and process your personal data. This agreement requires that you provide your personal data if and insofar as you wish to participate in our prize draw offering. The data processing takes place for both our own direct marketing (Article 6(1)(b) GDPR) as well as for our sponsors to also enable them to engage in individual, demand-driven direct marketing that is tailored to you via the channels of e-mail, push notifications, mail, phone, and text message (Article 6(1)(b) GDPR).
Processing your personal data would be in accordance with declaration of consent for advertising and marketing purposes, via phone, text messages, email, push notifications, mail and/or the disclosure of data for direct marketing purposes for the mentioned sponsors of the prize draw that may have been issued separately; this also takes place within the scope of our legitimate interests as established by your relevant consent (Article 6(1)(f) GDPR).
LUCKY DIGITAL MARKETING LTD assumes that the consent to receive advertising by phone, text message, e-mail, push notifications and mail from us and our sponsors, which is to be declared separately, also constitutes consent for purposes of data protection and privacy law to the processing of your personal data with the result that – in addition – the relevant, aforementioned data processing is also permitted pursuant to (Article 6(1)(a) GDPR).
It may be the case that an analysis of your affinities, interests, and preferences is performed before the data is used for direct marketing and/or disclosed to sponsors. To this end, the answers that you will provide after registering to the prize draw may also be analysed, and a profile may be established in order to enable more targeted performance of direct marketing measures by us and our sponsors, if any (Article 6(1)(f) GDPR).
Using the data obtained, particularly those from our surveys following the prize draw registration page, we will create a “user profile” of you in order to be able to offer you an interest-driven service that is geared towards your individual needs and requirements. By creating this profile, we may categorise personal aspects, such as your interests and preferences, through automated processing of your data in order to make it possible for both us and our sponsors to send you exclusive advertising and offers that match you profile.
LUCKY DIGITAL MARKETING LTD frequently receives – provided that your end device supports this function – confirmation of which e-mails from us you open and how you proceed with the e-mail. This helps us to understand your interests and supports us in making the offers more useful interesting, tailor-made to you in the future (Article 6(1)(f) GDPR).
Assertion, if any, of your rights (Article 6(1)(c) and (f) GDPR) as provided in Sec. 5 of this data protection and privacy statement also leads to collection and processing of your personal data.
Disclosure of your personal data may take place in cases in which we are under a legal obligation of disclosure (Article 6(1)(c) GDPR) or to the extent that disclosure should be necessary to enforce other rights/demands or for purposes of legal defence, if and insofar as these are based on the legitimate interests of the organiser or other third parties (Article 6(1)(f) GDPR). The same applies in the event of (also partially) purchase or sale of business assets and/or other assets, in the event that our business is otherwise acquired by a third party, in the event of initiation of insolvency proceedings, or if a request for initiation of insolvency proceedings is denied for lack of sufficient assets (Article 6(1)(f) GDPR).
Profiling
The User's personal data (i.e. personal and contact details, and information relating to the services in which the User has expressed an interest) may also be processed by the Data Controller for profiling purposes, i.e. to reconstruct the User's tastes and consumption habits, identifying the User's consumer profile, in order to be able to send the User commercial offers consistent with the identified profile.
If consent is not given, the possibility of registering on the Site will not be affected in any way.
In the event of consent, the User may revoke it at any time by making a request to the Data Controller sending an email at privacy@luckydigitalmarketing.co.uk
User ID verification
The Controller informs that, in the pursuit of its legitimate interest, the User's personal data (i.e. personal and contact details) may also be processed by the Controller for security purposes, i.e. to verify the User's digital identity and to prevent fraud and abuse of personal data.
The User may at any time object to this processing by making a request to the Data Controller sending an email at privacy@luckydigitalmarketing.co.uk
In addition to the sectors listed, you can expect LUCKY DIGITAL MARKETING LTD to find and run 3rd party offers from Advertisers that we believe will be of interest to our members. The following two Networks allow us to send their third party offers. You can view their Advertisers/Client List here:
We may share your contact information with our partner WINR Data Pty Ltd. (WINR) and their global partners for the purpose of:
ID Protection - preventing others from misusing your details. This may include ID validation for anti-money laundering, anti-fraud, preventing crime, asset recovery, debt collection and reuniting people with unclaimed assets.
Advertising - providing offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.
WINR and their partners will retain your information for as long as necessary to perform these functions. You can opt-out of all WINR activity by contacting their Privacy Officer https://www.winrdata.com/privacy-policy
3. Who we share your personal information with
We license data to third parties who like us, operate in accordance with UK Data Protection Law. These third parties operate in the following business categories and may contact you by email and post for the purposes of Direct Marketing, Debt Collection and Tracing.
Charity
Animals, Children, Clubs & Societies, Conservation, Elderly, Environment, Health & Medical, Human Rights, Life Savers, Military, Museums, Theatres & Art Galleries, Third World and Wildlife.
Finance
Banks & Building Societies, Claims Companies, Credit Cards, Investment & Savings, Loans, Mortgages, Pensions and Vehicle Leasing.
General & Lifestyle
Care & Retirement Homes, Health & Well-being, Magazines & Newspapers, Price Comparison websites, Property, Tracing & Fraud Prevention, Tradespeople Supply and Property Services.
Insurance
Including Car, Home, Life, Medical, Pet, Breakdown and Travel.
Marketing
Marketing Companies, Media & Publishing Companies, Research and Surveys.
Retail
Automotive, Fashion & Clothing, Food & Drink, General Stores & Supermarkets, Home Furnishings, Home Improvement, Mobility, Online Retail and Pharmacies.
Travel
Airlines, Holidays, Holiday Homes & Clubs, Travel Booking.
Utilities
Broadband & Internet Services, Electricity & Gas Providers, Energy Products & Services, Telecommunications Companies and TV Broadcasters.
Online Gambling
Sports betting, Bingo, Casino, Lottery
4. Protection of your personal data
We take corresponding precautions – administrative/organisational, technical, and physical – to protect your personal data against loss, theft, abuse, unauthorised access, unauthorised disclosure, unauthorised modification, and destruction.
LUCKY DIGITAL MARKETING LTD is committed to ensuring security of personal information it holds. Your data is stored in secure servers and we implement a range of measures to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. LUCKY DIGITAL MARKETING LTD holds personal information electronically with the assistance of our service providers including the use of secure enterprise grade servers to store personal information.
Your data is retained for a period of 5 years, after this period the data will be destroyed. Your data is then held for this period of time as a proof of opt-in and proof of data supply which may be required for legal reasons.
5. Your rights
You have the right to obtain information regarding the personal data stored regarding you, including the origin and recipients of your data and the purpose of data processing, at any time pursuant to Article 15 GDPR. Specifically, you have the right to:
You also have the right to demand, at any time, that we correct inaccurate personal information concerning you (Article 16 GDPR). You can restrict the processing of data if any of the prerequisites mentioned in Article 18(1) GDPR are met, e.g. in the event of a dispute concerning the accuracy of your personal data.
Moreover, you have the right to revoke any declaration(s) of consent to the processing of your personal data that may have been issued, with effect for the future (Article 7 GDPR). Such a revocation does not, however, affect the legality of the processing that has taken place up until then.
Furthermore, you have the right to demand the erasure of your data and assert your right to be forgotten pursuant to Article 17 GDPR. If the statutory prerequisites are met, we will proceed in this regard even without such a request having been issued on your part and will erase your personal data.
You may exercise your rights by contacting us directly via abuse@luckydigitalmarketing.co.uk, indicating in the subject line "EXERCISING YOUR RIGHTS"
Your request must include the date, your name and surname(s), your specific request and address for notification purposes.
In the event that LUCKY DIGITAL MARKETING LTD has not resolved your request correctly, you may write to request ownership of the data to the Information Commissioner's Office (ICO), whose details may be consulted at https://ico.org.uk/
6. Right to object and right to revoke; consequences
The participant is permitted to object to the processing of his/her data for advertising purposes and/or to revoke consent, if any, that has been granted for this purpose, without being required to state any reasons. Processing of data for advertising purposes and/or the use of the participants’ data to this end will then be halted without delay. The organiser will also notify its sponsors of any such objection and/or revocation without any undue delay.
You can unsubscribe at any time by emailing us at privacy@luckydigitalmarketing.co.uk
7. Usage data and cookies
You can view our Internet pages without providing personal information. However, certain technical data, known as "usage data", are generated whenever our pages are visited. In addition, we may use one or more cookies and integrate social media plugins in some cases. The text below is intended to provide you with information regarding this as well.
Usage data:
When you visit our Web pages, the only items of information we store by default are the website from which you reached our page, the name of your Internet service provider, which Web pages you visited within our Internet presence, and the date and duration of your visit. The data obtained is fully anonymous.
Your IP address and a time stamp are also stored for security reasons and used for internal purposes. The IP address is a machine-related code that provides information of the computer or Internet gateway used to access the Internet at the time of online retrieval. A time stamp is a value in a defined format that assigns a certain point in time to an event (for example, sending or receiving a message, modification of data, etc.). The purpose of a time stamp is to make it clear to people or computers when events occurred.
Cookies
As part of our Internet pages, we use "cookies". You must consent to the use of cookies if you wish to use our Web pages. These are small files that are stored on your hard drive and store specific information that can be retrieved by the server that has placed the cookie on your computer. The cookies used may be “session” cookies, which are automatically deleted as soon as you close your browser window, and/or cookies that are valid for a longer period. The information stored in cookies may concern, in particular, the login (your visit, if you log in), the date and time of your visit to us, the cookie number, and the URL of the website from which you reached our site.
The use of cookies allows us to recognise you and thereby adapt our offerings optimally to your individual needs and requirements. Cookies also make it possible to record the statistical frequency of retrieval of the various pages of our Internet presence and the general navigation.
If you wish to prevent the use of cookies, however – which has no influence over the performance of our prize draw or other offerings associated therewith on our part – please adjust your browser settings accordingly before you use our pages. You can prevent new cookies from being accepted and stored in these settings. For further information, please consult your browser's help pages or contact the producer or provider of the browser.
Push notifications
You can opt in to receive our push notifications. To send our push notifications, we use the delivery service "CleverPush", which is provided by CleverPush UG (haftungsbeschränkt), Nagelsweg 22, 20097 Hamburg ("CleverPush").
You will receive regular information about exclusive offers from our partners.
To opt in, you must confirm your browser's request to receive notifications. This process is documented and stored by CleverPush. This includes saving the opt in time and your browser ID or device ID. The collection of this data is required so that we can understand the processesUser ID verification in case of misuse and therefore serves our legal protection.
To show you the push notifications, CleverPush collects and processes your browser ID on our behalf and your device ID in the case of mobile access.
By subscribing to our push notifications, you agree to their receipt. Legal basis for the processing of your data after registration for our push notifications is in the presence of your consent Art. 6 para. 1 lit. a GDPR. CleverPush also statistically evaluates our push notifications. CleverPush can detect if and when our push notifications were displayed and clicked by you.
Your consent to the storage and use of your personal information to receive our push notifications and the statistical survey described above may be revoked at any time with future effect. To revoke consent, you can change the setting to receive push notifications in your browser. If you use our push notifications on a desktop PC with the operating system "Windows", you can also unsubscribe our push notifications by right-clicking on the respective push notification in the settings that appear there.
Your data will be deleted as soon as they are no longer necessary to achieve the purpose of their survey. Your data will be stored as long as the subscription to our push notifications is active.
Under the following link, the process of unsubscribing will be explained in detail: https://cleverpush.com/faq
8. Deletion of cookies
As a user, you have the right at any time to decide which cookies – including those for push notifications – you wish to accept or delete. You can adjust the individual settings thereto in the settings menu of your Internet browser. For further information, please contact the provider of your Internet browser.
9. Minors
This site, including the data protection and privacy policy and the general terms and conditions of business, is not aimed at minors. No personal data of minors are knowingly collected, used, and/or disclosed.
10. Data storage and retention
We store your personal data on our UK based server within the European Economic Area. In agreement with our sponsors listed in article 2, it is possible that your data will be transferred to “third countries”. Third countries are countries located outside the European Union. In relation to such data transfers, a secure transfer within the scope of EU specifications on data protection and privacy are ensured.
Your data is retained for a period of 5 years, after this period the data will be destroyed. Your data is then held for this period of time as a proof of opt-in and proof of data supply which may be required for legal reasons. A copy of our data retention policy is available on request.
11. Data Protection Officer
If you would like to contact our Data Protection Officer, please email us a abuse@luckydigitalmarketing.co.uk
We advise to regularly check our privacy policy for amendments