Privacy policy

INTRODUCTION

Welcome to the privacy policy of Competition Guru Limited.

Competition Guru Limited values your privacy and is dedicated to safeguarding your personal information. Our privacy policy serves to outline how we manage and protect your personal data when you visit our website, regardless of your location.

Furthermore, this policy elaborates on your privacy rights and the laws that are in place to protect them. We recommend that you refer to the Glossary section to comprehend the significance of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

The purpose of this privacy policy is to provide you with comprehensive details on how Competition Guru Limited collects and handles your personal data when you use our website. This includes any information you provide when subscribing to our newsletter, purchasing our products or services, or participating in a contest or prize draw.

We do not intentionally collect data relating to children, and our website is not intended for their use.

We recommend that you read this privacy policy in conjunction with any other privacy policy or fair processing policy we may provide when gathering or processing your personal data. This will ensure that you have a complete understanding of how and why we are utilizing your data. This privacy policy is not intended to override any other notices or privacy policies and is meant to supplement them.

CONTACT DETAILS

If you have any inquiries regarding our privacy practices or this privacy policy, please do not hesitate to contact our data privacy manager by using the following methods:

Full legal entity name: Competition Guru Limited

Email address: info@com-guru.com

Postal address: Unit 13 Osberstown Business Park, Naas Co. Kildare. Ireland. W91 D659

You reserve the right to file a complaint with the Information Commissioner’s Office (ICO), which is the UK’s supervisory authority for data protection matters (www.ico.org.uk) at any time.

When you submit data through a form, such as a contact page or comment form, cookies may be utilized to recall your user information for future correspondence. However, we would appreciate the opportunity to resolve your concerns before you approach the ICO, so please contact us first.

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

At Competition Guru Limited, we frequently review our privacy policy to ensure that it remains up to date. This particular version was last revised on November 15th, 2022. It is critical that the personal information we have on file for you is accurate and up to date. Please notify us of any changes to your personal information during your interaction with us.

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.

2: The data we collect about you

Personal data or information pertains to any information that can identify an individual. However, it excludes data that does not reveal the identity of an individual (anonymous data).

At Competition Guru Limited, we may collect, store, use and transfer various personal data types which are classified into the following groups:

• Identity Data, which includes your first and last name, username or other similar identifiers, and title;
• Contact Data, which includes your billing and delivery address, email address, and telephone numbers;
• Financial Data, which includes your payment card details;
• Transaction Data, which includes information about your payments and other details of products and services you purchased from us;
• Technical Data, which includes your internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
• Profile Data, which includes your username and password, purchases or orders made by you, interests, preferences, feedback, and survey responses;
• Usage Data, which includes information about how you use our website, products, and services; and
• Marketing and Communications Data, which includes your preferences for receiving marketing from us and our third-party partners, as well as your communication preferences.

We also collect, use, and share Aggregated Data, which is statistical or demographic data that is not considered personal data as it does not directly or indirectly identify you. We may derive Aggregated Data from your personal data, but we will not use it to reveal your identity. For example, we may calculate the percentage of users who access a particular website feature using your Usage Data. However, if we connect Aggregated Data with your personal data, we will treat the combined data as personal data, which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you. This includes data related to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data. We also do not collect any information about criminal convictions and offences.

If you participate in a prize draw or competition, we may collect the minimum amount of personal data necessary to allow you to enter and enable us to run the promotion. If you win, we may need to collect more detailed information from you to award the prize. If we require additional information, we will notify you at the time we notify you of your win.

We aim to keep your personal data accurate and up-to-date. If your personal data changes during your relationship with us, please inform us accordingly.

If you fail to provide personal data

In certain circumstances, we may require you to provide personal data to us by law, or under the terms of a contract we have with you. If you fail to provide the necessary information when requested, we may not be able to provide you with our products or services or enter you into a competition. In this event, we will notify you accordingly.

3: How is your personal data collected?

We utilize various methods to gather data from and about you, including:

Direct interactions. You may give us your Identity, Contact, and Financial Data by completing forms or communicating with us via post, phone, email, or other means. This includes personal data that you provide when you:

• Apply for our services or products;
• Create an account on our website;
• Subscribe to our publications or service;
• Request to receive marketing materials;
• Enter a survey, competition, or promotion; or
• Provide us with feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing patterns, and actions. We collect this personal data by utilizing cookies and other similar technologies. We may also receive Technical Data about you when you visit other websites that use our cookies.

Third-party sources or publicly available sources. We may obtain personal data about you from several third-party sources, as outlined below:

• Technical Data from analytics providers like Google located outside the EU;
• Contact, Financial, and Transaction Data from payment, delivery, and technical service providers located inside or outside the EU;
• Identity and Contact Data from data brokers or aggregators located inside or outside the EU;
• Identity and Contact Data from publicly available sources such as the Electoral Register and Companies House situated within the EU.

In the event that you are declared the winner of our competition, we may invite you to participate in promotional activities related to the competition. While your participation is not mandatory, we would greatly appreciate it. Please note that your decision not to participate will not affect your chances of winning or your participation in the competition in any way.

However, if you choose not to participate in any promotional activities and decline to be identified as the winner, we may still be required to provide your information to the Advertising Standards Authority (ASA) as proof that the competition was properly administered and the prize awarded. This is a legal obligation that we must comply with. If you require further details about how the ASA will use and process your personal information, please let us know.

MARKETING

We value your privacy and strive to give you control over your personal information, particularly in regards to marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may analyse your Identity, Contact, Technical, Usage, and Profile Data to better understand what products, services, and offers may interest you (referred to as “marketing”). You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or entered a competition or prize draw, unless you have opted out of receiving such communications.

THIRD-PARTY MARKETING

We will obtain your express opt-in consent before sharing your personal information with any third party for marketing purposes.

OPTING OUT

You may ask us or third parties to stop sending you marketing messages at any time by following the opt-out links provided in any marketing communication or by contacting us.

Please note that opting out of receiving marketing messages will not affect personal information provided to us as a result of a product or service purchase, warranty registration, product or service experience, or other transactions.

COOKIES

You may configure your browser to refuse some or all cookies or to alert you when websites set or access cookies. If you choose to disable or refuse cookies, some parts of our website may become inaccessible or may not function properly. Please refer to our cookie policy for more information about the cookies we use.

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which it was collected, unless we reasonably determine that we need to use it for another compatible purpose. If you wish to receive an explanation of how the new processing purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will inform you and explain the legal basis that permits us to do so.

Please note that we may process your personal information without your knowledge or consent in compliance with the above rules, where required or permitted by law.

5. DISCLOSURE OF YOUR PERSONAL INFORMATION

We may share your personal information with the following parties for the purposes specified in the “Purposes for which we will use your personal data” table above:

External Third Parties as defined in the Glossary. Specific third parties listed in the “Purposes for which we will use your personal data” table above. Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change in ownership occurs, the new owners may use your personal information in the same manner as set out in this privacy policy.

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

6. INTERNATIONAL TRANSFERS

Many of our external third parties are located outside of the European Economic Area (EEA),

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.

In some circumstances you can ask us to delete your data: see “Your legal rights” 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

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of these rights, please contact us.

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. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

EXTERNAL THIRD PARTIES

Service providers acting as processors based the United States of America and Europe provide IT and system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities such as the Advertising Standards Authority acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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. 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.