LEGAL
Privacy Policy
Last updated: 14/10/24
Privacy Policy
Last Updated: December 2024
1. Introduction
Welcome to Luxuries Unlocked ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how Adver Tech Global Ltd, trading as Luxuries Unlocked, collects, uses, shares, and protects your personal data when you use our website at luxuriesunlocked.com (the "Platform").
Our Details:
Company Name: Adver Tech Global Ltd
Trading As: Luxuries Unlocked
Registered Address: 128 City Road, London, United Kingdom, EC1V 2NX
Company Number: 15937555
This Privacy Policy applies to all users of our Platform, including visitors, registered users, and competition entrants. By using our Platform, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
2.1 Information You Provide Directly
When you register, enter competitions, or interact with our Platform, we collect:
Account Information: Name, email address, phone number, username, password (encrypted), date of birth
Payment Information: Billing address, payment card details (processed securely by our payment providers), transaction history
Competition Entry Information: Ticket numbers, competition entries, prize claim details
Verification Information: Identity verification documents (when claiming prizes), age verification data
Communication Data: Your messages to us, customer service interactions, survey responses, feedback
Marketing Preferences: Your choices regarding marketing communications
2.2 Information Collected Automatically
When you use our Platform, we automatically collect:
Device Information: IP address, browser type and version, device type, operating system, unique device identifiers
Usage Data: Pages visited, time and date of visits, time spent on pages, clickstream data, referring websites
Location Data: General location based on IP address (country/city level)
Cookie Data: Information collected through cookies and similar technologies (see Section 9)
2.3 Information from Third-Party Authentication
When you sign in using social media or third-party authentication services, we receive:
Facebook Login: Name, email address, date of birth
Google Login: Name, email address, date of birth
Twitter/X Login: Name, email address, date of birth
Apple Login: Name, email address (or relay email), date of birth
We do not receive your passwords or user IDs from these services. Your use of these authentication methods is also governed by the privacy policies of Facebook, Google, Twitter/X, and Apple respectively.
2.4 Information from Other Sources
We may receive information about you from:
Affiliate Partners: Information about how you were referred to our Platform
Marketing Partners: Information to help us provide targeted advertising
Social Media Platforms: Publicly available information from your social media profiles when you interact with our social media pages
Third-Party Data Providers: Demographic and interest data to enhance your user experience and improve our marketing
Fraud Prevention Services: Information to verify your identity and prevent fraud
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Service Delivery (Legal Basis: Contract Performance & Legitimate Interests)
Creating and managing your account
Processing competition entries and ticket purchases
Conducting prize draws and instant-win competitions
Notifying winners and arranging prize delivery
Processing payments and refunds
Providing customer support
Verifying your identity and age
Preventing fraud and ensuring Platform security
3.2 Marketing and Communications (Legal Basis: Consent & Legitimate Interests)
Email Marketing: Sending you promotional emails about new competitions, special offers, exclusive deals, and platform updates
SMS Marketing: Sending you text messages about time-sensitive competitions, flash sales, and exclusive opportunities (where you have provided consent)
WhatsApp Marketing: Sending you messages via WhatsApp about competitions, special offers, and platform updates (where you have provided consent)
Push Notifications: Sending mobile or browser notifications about competitions ending soon, new prize launches, and personalized offers
Direct Mail: Sending you postal marketing materials about premium competitions and exclusive offers (where you have provided consent)
Social Media Marketing: Showing you targeted advertisements on Facebook, Instagram, Twitter/X, TikTok, and other platforms
Retargeting: Displaying relevant advertisements to you across the internet based on your browsing behavior on our Platform
Personalized Marketing: Tailoring our marketing messages based on your competition entry history, preferences, and engagement with our Platform
You can opt out of marketing communications at any time using the unsubscribe link in emails, by replying STOP to SMS messages, or by updating your preferences in your account settings.
3.3 Analytics and Improvement (Legal Basis: Legitimate Interests)
Analyzing how users interact with our Platform to improve functionality
Understanding user preferences to enhance competition offerings
Conducting market research and user surveys
Developing new features and services
Testing new competitions and prize offerings
Creating aggregated, anonymized data for business intelligence
3.4 Advertising (Legal Basis: Consent & Legitimate Interests)
Displaying personalized advertisements on our Platform
Showing you relevant ads on third-party websites and social media
Measuring advertising effectiveness
Building custom and lookalike audiences for advertising campaigns
Retargeting users who have visited our Platform
Tracking conversions from advertising campaigns
3.5 Legal and Compliance (Legal Basis: Legal Obligation & Legitimate Interests)
Complying with legal obligations under UK gambling and competition law
Responding to legal requests and preventing legal misuse of our Platform
Enforcing our Terms and Conditions
Protecting against fraud, spam, and abuse
Resolving disputes and investigating complaints
Conducting audits and maintaining business records
4. Legal Bases for Processing
Under UK GDPR, we process your personal data based on the following legal grounds:
Contract Performance: Processing necessary to fulfill our contract with you (providing competition services)
Consent: You have given clear consent for specific processing activities (e.g., marketing communications, non-essential cookies)
Legitimate Interests: Processing necessary for our legitimate business interests (e.g., fraud prevention, analytics, direct marketing where permitted)
Legal Obligation: Processing required to comply with legal requirements (e.g., age verification, tax obligations)
Where we rely on legitimate interests, we have balanced our interests against your rights and freedoms and implemented appropriate safeguards.
5. Sharing Your Information
We share your personal information with the following categories of recipients:
5.1 Service Providers
We work with third-party service providers who process data on our behalf:
Payment Processors: Cashflows and other payment gateways to process transactions
Email Service Providers: SendGrid and other email platforms for transactional and marketing emails
SMS Providers: SMS gateway providers for authentication and marketing messages
Customer Relationship Management: HubSpot for managing customer relationships and marketing automation
Cloud Hosting: Supabase, Vercel, and cloud infrastructure providers for hosting our Platform
Analytics Providers: Google Analytics, Meta Pixel, and other analytics tools
Customer Support: Help desk and live chat software providers
Prize Fulfillment: Courier services and prize delivery partners
Identity Verification: Third-party verification services for age and identity checks
5.2 Advertising Partners
We share information with advertising and marketing partners:
Social Media Platforms: Facebook/Meta, Twitter/X, TikTok, Pinterest, Snapchat for targeted advertising
Advertising Networks: Google Ads, display advertising networks, and retargeting platforms
Affiliate Networks: Partners who refer users to our Platform
Marketing Analytics: Tools that help us measure campaign effectiveness
5.3 Business Partners
Competition Prize Providers: Brands and suppliers of competition prizes (name and contact details for prize delivery)
Co-Marketing Partners: Joint competition or promotional partners (where you've entered co-branded competitions)
5.4 Legal and Safety
We may disclose your information:
To comply with legal obligations, court orders, or regulatory requests
To protect our rights, property, or safety, or that of our users
To investigate and prevent fraud, security issues, or technical problems
In connection with business transfers (mergers, acquisitions, or sale of assets)
5.5 Aggregated Data
We may share anonymized, aggregated data that cannot identify you with:
Business partners for market analysis
Advertisers for campaign planning
Industry researchers and analysts
6. International Transfers
Your personal information may be transferred to and processed in countries outside the United Kingdom. When we transfer data internationally, we ensure appropriate safeguards are in place:
Standard Contractual Clauses: We use UK-approved Standard Contractual Clauses with service providers
Adequacy Decisions: We transfer data to countries recognized by the UK as providing adequate data protection
Service Provider Safeguards: Our service providers implement appropriate technical and organizational measures
Countries where your data may be processed include the United States (for cloud hosting, analytics, and advertising services) and the European Economic Area.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy:
Active Accounts: While your account remains active and for 7 years after account closure (for legal and accounting purposes)
Competition Records: 7 years from the competition end date (for legal, tax, and regulatory compliance)
Marketing Data: Until you withdraw consent or for 7 years from your last interaction with our Platform
Payment Records: 7 years from the transaction date (for accounting and tax purposes)
Customer Support Records: 7 years from the last interaction
Cookie Data: As specified in our Cookie Policy (typically 13 months maximum for non-essential cookies)
When we no longer need your information, we securely delete or anonymize it.
8. Your Rights
Under UK GDPR, you have the following rights:
8.1 Right of Access
You can request a copy of the personal information we hold about you.
8.2 Right to Rectification
You can ask us to correct inaccurate or incomplete personal information.
8.3 Right to Erasure ("Right to be Forgotten")
You can request deletion of your personal information in certain circumstances, subject to legal retention requirements.
8.4 Right to Restrict Processing
You can ask us to restrict how we use your personal information in certain situations.
8.5 Right to Data Portability
You can request your personal information in a structured, commonly used format for transfer to another service.
8.6 Right to Object
You can object to:
Processing based on legitimate interests
Direct marketing (including profiling for marketing purposes)
Processing for research or statistical purposes
8.7 Rights Related to Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect you. We do not currently use fully automated decision-making for such purposes.
8.8 Right to Withdraw Consent
Where we rely on consent, you can withdraw it at any time. This won't affect the lawfulness of processing before withdrawal.
8.9 How to Exercise Your Rights
To exercise any of these rights:
Use the contact form on our website
Use the account settings in your user dashboard
Contact us via post using the details in Section 17
We will respond to your request within one month. If your request is complex, we may extend this by two months and will notify you.
8.10 Right to Complain
If you're unhappy with how we've handled your personal information, you have the right to complain to the Information Commissioner's Office (ICO):
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to provide functionality and improve your experience. Our cookie management is handled through CookieYes.
9.1 Types of Cookies We Use
Strictly Necessary Cookies: Essential for the Platform to function (authentication, security, competition entry processing). These cannot be disabled.
Performance Cookies: Help us understand how you use our Platform through analytics (Google Analytics, internal analytics).
Functional Cookies: Remember your preferences and provide enhanced features (language preferences, location data for competitions).
Targeting/Advertising Cookies: Enable personalized advertising and measure advertising effectiveness (Meta Pixel, Google Ads, retargeting pixels).
9.2 Third-Party Cookies
We use third-party cookies from:
Google (Analytics, Ads, Tag Manager)
Meta/Facebook (Pixel, advertising)
Twitter/X (conversion tracking)
Other advertising and analytics partners
9.3 Managing Cookies
You can control cookies through:
Our CookieYes consent management platform
Your browser settings
Your account preferences
Refusing non-essential cookies won't prevent you from using our Platform, but some features may be limited.
For more detailed information, please see our separate Cookie Policy.
10. Security
We implement appropriate technical and organizational measures to protect your personal information:
Encryption: Data transmission is encrypted using SSL/TLS
Access Controls: Strict access limitations and authentication requirements
Secure Storage: Encrypted data storage with industry-standard security
Regular Security Audits: Ongoing monitoring and security testing
Staff Training: Regular data protection training for our team
Incident Response: Procedures for detecting and responding to data breaches
However, no method of transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
If we discover a data breach that poses a risk to your rights and freedoms, we will notify you and the ICO within 72 hours as required by law.
11. Children's Privacy
Our Platform is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If we discover we have collected information from someone under 18, we will delete it immediately.
If you believe we have collected information from a child, please contact us using the details in Section 17.
12. Third-Party Links
Our Platform may contain links to third-party websites, social media platforms, and services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. We will notify you of material changes by:
Posting a notice on our Platform
Sending you an email notification (where we have your email address)
Updating the "Last Updated" date at the top of this policy
Your continued use of our Platform after changes indicates your acceptance of the updated Privacy Policy.
14. Marketing Communications Preferences
You have full control over the marketing communications you receive:
14.1 Email Marketing
Unsubscribe using the link in any marketing email
Update preferences in your account settings
14.2 SMS Marketing
Reply STOP to any marketing SMS
Update preferences in your account settings
14.3 WhatsApp Marketing
Reply STOP to any marketing WhatsApp message
Block our business account if you wish to stop all WhatsApp communications
Update preferences in your account settings
14.4 Push Notifications
Disable in your device settings
Disable in your account settings on our Platform
14.5 Postal Marketing
Update preferences in your account settings
14.6 Social Media Advertising
You can control targeted advertising through:
Your Facebook Ad Preferences
Your Google Ads Settings
Your Twitter/X privacy settings
Individual platform advertising settings
Opting out of marketing does not affect transactional communications necessary for our service (account notifications, competition results, purchase confirmations).
15. Profiling and Automated Processing
We use automated processing and profiling to:
Personalize your user experience and competition recommendations
Tailor marketing communications based on your interests and behavior
Detect and prevent fraud
Analyze user engagement and Platform performance
Create custom audiences for targeted advertising
This processing helps us provide relevant competitions and offers that match your interests. You have the right to object to profiling for marketing purposes at any time.
16. Specific Data Uses
16.1 Affiliate Tracking
We use cookies and tracking technologies to identify which affiliate partners referred you to our Platform. This information is used to credit our partners and may be used for marketing optimization.
16.2 Fraud Prevention
We process your personal information, including device data and behavioral patterns, to detect and prevent fraudulent competition entries, payment fraud, and account misuse.
16.3 Competition Management
We use your information to ensure fair competition operation, verify winner eligibility, prevent multiple entries where prohibited, and maintain competition integrity.
16.4 Prize Fulfillment
Winners' personal information is shared with prize providers and delivery services as necessary to arrange prize delivery. Winners will be asked for specific delivery information at the time of winning.
17. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Post: AdverTech Global Ltd, 128 City Road, London, United Kingdom, EC1V 2NX
Website Contact Form: https://luxuriesunlocked.com/contact
We aim to respond to all queries within 5 business days.
Consent Statement
By using Luxuries Unlocked, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your personal information as described herein.
For marketing communications specifically, we will obtain your explicit consent through opt-in mechanisms (checkboxes, preference centers, or explicit consent requests) before sending you promotional materials. You can withdraw this consent at any time.