privacy policy

1. Important information and who we are

This privacy policy gives you information about how Cowboy Competitions LTD collects and uses your personal data
through your use of this website, including any data you may provide when you register with us or take part in a
competition.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Cowboy Competitions LTD is the controller and responsible for your personal data (collectively referred to as
“Cowboy Competitions”, “we”, “us”or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights ( paragraph 9 ),
please contact us using the information set out in the contact details section ( paragraph 10 ).

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together
as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital
status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and
services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time
zone setting and location, browser plug-in types and versions, operating system and platform, device ID
and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.

• Usage Data includes information about how you interact with and use our website, products and
services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our
third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as
it does not directly (or indirectly) reveal your identity. For example, we may aggregate ‘individuals’ Usage Data to
calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users
are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by
corresponding with us by post, phone, email or otherwise. This includes personal data you provide when
you:

• apply for our products or services;
• create an account on our website;
• request marketing to be sent to you;
• enter one of our competitions, a promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions.

As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data by
using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.

Third parties. We will receive personal data about you from various third parties as set out below:

• Technical Data is collected from the following parties:
• analytics providers such as Google and Meta based outside the UK; and
• advertising networks such as Google Analytics and Meta based outside the UK.
• Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery
services such as WooCommerce based outside the UK.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the
following legal bases:
• Performance of a contract with you: Where we need to perform the contract we are about to enter into
or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and
pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and
most secure customer experience. We make sure we consider and balance any potential impact on you
and your rights (both positive and negative) before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by the
impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal
obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal
basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal
data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories
of your personal data, and which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.

Purpose/Use	Type of Data	Legal Basis and Retention Period
To register you as a new customer	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent, having obtained your prior consent to receiving direct marketing communications We will retain this data for so long as you remain a customer of ours, except where we are required to hold it for longer as per Clause 8.

Direct marketing

During the registration process on our website when your personal data is collected, you will be asked to indicate
your preferences for receiving direct marketing communications from Cowboy Competitions via email.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products,
services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing
You can ask to stop sending you marketing communications at any time by logging into the website and checking or
unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links within any
marketing communication sent to you or by contacting us at the details set out in paragraph 10.
If you opt out of receiving marketing communications, you will still receive service-related communications that are
essential for administrative or customer service purposes for example updates to our Terms and Conditions, or
checking that your contact details are correct.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the
table Purposes for which we will use your personal data above.

• External Third Parties as set out in Paragraph 13.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit
them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may
involve transferring personal data outside the UK to countries which have laws that do not provide the same level of
data protection as the UK law.
Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of
protection is afforded to it by ensuring that the following safeguards are in place:

• We may use specific standard contractual terms approved for use in the UK which give the transferred
personal data the same protection as it has in the UK, namely the International Data Transfer
Agreement. To obtain a copy of these contractual safeguards, please contact us at the details provided in
paragraph 10 .

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used
or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may
retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a
prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of
the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a “subject access request”). This enables you
to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any
incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy
of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it. You also have the
right to ask us to delete or remove your personal data where you have successfully exercised your right
to object to processing (see below), where we may have processed your information unlawfully or
where we are required to erase your personal data to comply with local law. Note, however, that we
may not always be able to comply with your request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a
third party) as the legal basis for that particular use of your data (including carrying out profiling based
on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate
grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct
marketing purposes (see paragraph 4 for details of how to object to receiving direct marketing
communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the
table in section 4 for details of when we rely on your consent as the legal basis for using your data).
However, this will not affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain products or services to
you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish,
exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at the details provided in paragraph 10.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse
to comply with your request in these circumstances.
What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal
data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if
your request is particularly complex or you have made a number of requests. In this case, we will notify you and
keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to
exercise your privacy rights, please us in the following ways:
• Email address: [email protected]
• Postal address: 2 Plantation Courtyard Ely Road, Hilgay, Downham Market, Norfolk, England, PE38 0HL

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal
with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [DATE].
It is important that the personal data we hold about you is accurate and current. Please keep us informed if
your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party websites and are not responsible for their privacy statements. When you leave our
website, we encourage you to read the privacy policy of every website you visit.

External Third Parties

• Service providers acting as processors based within the United Kingdom who provide IT and system
administration services.
• Credit check and referencing providers acting as processors based within the United Kingdom who
provide credit referencing checks on our behalf.
• Professional advisers acting as processors or joint controllers including payroll providers, lawyers,
bankers, auditors and insurers based in within the United Kingdom who provide consultancy, payroll,
banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based
in the United Kingdom who require reporting of processing activities in certain circumstances.

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