Privacy Policy

• Identity and eligibility information, including name, date of birth, address and verification documents
• Contact information, including email address, telephone number and communication preferences
• Account information, login records, security settings and account balances
• Orders, payments, refunds, chargebacks, entries, ticket numbers, game results and prize history
• Bank details or payment instructions needed to pay a cash prize
• Spend limits, cool-offs, account suspensions, self-exclusion requests and related player-protection records
• Support messages, complaints, survey responses and communications
• IP address, device identifiers, browser data, approximate location, cookies, referral source and technical logs
• Marketing consent, message delivery, opens, clicks and campaign engagement
• Winner images, video, voice, testimonials and publicity preferences where supplied or agreed

Information may come directly from you, from your use of the website, from payment and fraud-prevention providers, from delivery or prize partners, from social-login providers, from advertising and analytics services, from postal entries, from customer-support interactions or from publicly available sources where lawful.

• To create and secure accounts and provide requested website services
• To process payments, entries, ticket allocation, instant-win results, refunds and site credit
• To conduct draws, contact and verify winners, publish valid award information and deliver prizes
• To enforce entry limits, spend limits, cool-offs, suspensions and self-exclusion
• To prevent fraud, promotion abuse, duplicate accounts, payment misuse and cyber-security threats
• To provide support, investigate complaints and establish, exercise or defend legal claims
• To meet tax, accounting, legal, regulatory and record-keeping obligations
• To analyse and improve website performance, products, communications and player experience
• To send optional marketing where consent or another lawful permission applies

Depending on the purpose, we rely on performance of a contract, compliance with a legal obligation, legitimate interests and consent. Legitimate interests may include operating and improving the service, keeping auditable competition records, preventing fraud, protecting customers, securing systems, managing complaints and understanding business performance.

Where consent is the basis, you can withdraw it at any time without affecting processing already carried out lawfully.

We may analyse entry history, spend, preferred competition types, visit source, time of activity, campaign engagement, prize history, device information and responsible-play signals. This may be used to create customer segments, personalise services, measure marketing, identify fraud or promotion abuse and support player-protection reviews.

We do not intend to make decisions based solely on automated processing that produce legal or similarly significant effects without appropriate safeguards. Where such a decision is made, you may request human review, express your point of view and challenge the result where the law provides those rights.

A responsible-play conversation may reveal health or other sensitive information. We will only use such information where necessary, proportionate and supported by an appropriate legal condition. Please avoid providing more sensitive information than is needed for the request.

Payment-card processing is handled by authorised payment providers. Proper Wins does not intentionally store full card numbers or security codes. We may receive payment status, limited card metadata, fraud signals, chargeback information and transaction references.

Bank account details supplied for a prize payment are used to verify and complete that payment, prevent fraud and keep appropriate financial records.

Information may be shared where necessary with payment processors, hosting and security providers, website and database providers, email and SMS providers, analytics and advertising services, identity or fraud-prevention providers, delivery companies, prize suppliers, professional advisers, insurers, auditors, regulators, courts, law enforcement or public authorities.

We do not sell personal information. Service providers are expected to use information only for the agreed service and protect it appropriately.

Some service providers may process information outside the United Kingdom. Where required, we use an applicable adequacy regulation, contractual safeguards such as the UK International Data Transfer Agreement or Addendum, or another lawful transfer mechanism. You may ask for further information about relevant safeguards.

To demonstrate that a valid award took place, we may publish or make available limited winner information, ordinarily a surname and county, subject to applicable promotion rules. At or before entry, entrants should be informed of this intention and may object or ask for the amount published to be reduced.

Where required, valid award information may still be provided confidentially to the Advertising Standards Authority. Photos, video, interviews and testimonials are optional unless a specific promotion lawfully and clearly states otherwise, and will normally be used with consent.

Optional email, SMS or similar direct marketing is sent only where permitted. You can unsubscribe using the message link or by contacting support. We may keep a minimal suppression record so that your opt-out continues to be respected.

• Order, payment, prize, complaint and core competition records are normally retained for up to six years after the relevant transaction or relationship, where needed for tax, accounting, fraud and legal claims
• Identity documents are kept only for as long as reasonably necessary for verification, fraud prevention and legal obligations
• Responsible-play and self-exclusion records may be retained for the restriction period and afterwards where necessary to maintain the protection and demonstrate compliance
• Marketing data is kept until consent is withdrawn or it is no longer needed, with limited suppression data retained to honour opt-outs
• Technical and analytics records are retained according to security, troubleshooting, consent and provider requirements

Where no fixed period applies, we consider the purpose, sensitivity, legal duties, risk of harm and whether the information can be deleted or anonymised.

We use proportionate technical and organisational measures intended to protect information, including access controls, secure service providers, logging, backups and security monitoring. No online system is completely risk-free. You are responsible for keeping account credentials confidential and notifying us promptly of suspected unauthorised access.

Depending on the circumstances, you may have rights of access, rectification, erasure, restriction, data portability and withdrawal of consent. Some rights are limited where information must be retained for legal obligations, fraud prevention, self-exclusion, prize records or legal claims.

Email support@properwins.co.uk. We may request proportionate identity verification. We normally respond within one month, although the law allows an extension for complex or numerous requests.

Proper Wins services are for adults aged 18 or over. We do not knowingly permit under-18s to enter. If we reasonably believe an account belongs to a child, we may restrict it, investigate and delete information where appropriate while retaining any record required for safeguarding, fraud prevention or legal compliance.

Please contact us first so that we can investigate. You also have the right to complain to the Information Commissioner’s Office through ico.org.uk or by using the ICO’s published contact details.

We may update this policy when our services, providers, data uses or legal obligations change. Material changes will be reflected in the updated date and, where appropriate, brought to users’ attention.