COMPETITION PRIVACY NOTICE

RINGPAY CHRISTMAS GIVEAWAY

1. who we are

1.1 McLear Limited is a private limited company at Steel House, Alexander Place, 13-17 Princes Road, Richmond, Surrey, England, TW10 6DQ (Registration no. 08308520).

1.2 McLear Limited is the controller of personal data processed under this fair processing notice (the “Notice”).

1.3 In this Notice, references to “we” or “us” or “our” shall relate to McLear Limited and references to “you” or “your” shall relate to the individual who has provided personal data directly to us, or to whom we have received personal data from third parties in relation to, for the purposes detailed in this Notice.

1.4 This Notice shall apply to the personal data collected by, or provided to, us in respect of the RingPay Christmas Giveaway Competition which ran from 1 December 2020 to 12 December 2020 (“Competition”). By “personal data” we we mean any information about you from which you can be identified.

1.5 The Organiser will process your personal information for the Competition as set out below. By “processing”, we mean the collection, recording, storage, use, disclosure and any other form of operations or dealings with your personal data.

2. the personal data we collect about you

2.1 We may collect, use, store and transfer different kinds of personal data about you as follows:

• (a) Name;
• (b) Social media handle;
• (c) Social media entry details;
• (d) Email address;
• (e) Postal address;
• (f) Phone number;
• (g) Details of your prize;
• (h) Details of your RingPay by McLEAR Ring account; and
  • (i) An image of an entrant, a winner and (as applicable) other individuals included in such images.

3. how your personal data is collected

3.1 We collect information about you:

• (a) When you enter the Competition;
• (b) When you have won the Competition; or
• (c) From you in other general correspondence about the Competition; or
• (d) From individuals making a complaint.

4. how we use your personal data

4.1 We use this information to:

• (a) Identify you,
• (b) To administer the Competition;
• (c) To select a winner;
• (d) Provide the Competition prize;
• (e) For the establishment, exercise or defence of legal claims;
• (f) To handle any complaints or other disputes; and
• (g) Where required to meet our obligation under the CAP Code or applicable law.

5. disclosures of your personal data

5.1 We may share this information with:

• (a) Industry partners including, without limitation, the Advertising Standards Authority;
• (b) Third party suppliers in order to supply you with the prize and to administer the Competition; or
• (c) Our group companies.

6. Lawful basis for using your personal data

6.1 If you have won a prize, we will ask you to consent to the Organiser using some of your information for marketing purposes. You can refuse to allow us to process your data in this way but you acknowledge and accept that, if you agree to this processing and later change your mind, the Organiser may not be able to remove all publications if they have been shared by other parties. You can withdraw your consent at any time by contacting dpo@mclear.com.

6.2 We have a legitimate interest in processing your personal data:

• (a) To comply with the CAP Code regarding promotion marketing;
• (b) For the establishment, exercise or defence of legal claims; and
• (c) To handle any complaints or other disputes.

6.3 We also collect, handle and use your personal data on the legal basis of performance of the contract with you.

6.4 We may also process certain personal data about you to comply with our legal obligations.

7. retention of your personal data

7.1 We will retain your information with respect to this Competition for as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements, save that images and messages provided by you on our social media feed will be kept until you ask for them to be deleted or you delete them.

8. your rights in relation to your personal data

8.1 Under applicable data protection laws, you may have certain legal rights in respect of your personal data, such rights include:

• (a) To request access to your personal data;
• (b) To request correction of your personal data we hold about you;
• (c) To request erasure of your personal data, which enables you to ask us to delete or remove personal information in certain circumstances;
• (d) To object to processing of your personal data where we are relying on a legitimate interest (or the legitimate interests of a third party) to process your personal data;
• (e) To request restriction of processing of your personal data;
• (f) To request the transfer of your personal data to you or to a third party;
• (g) To request a copy, or reference to, the personal data safeguards used for transfers outside the European Union (we may redact data transfer agreements to protect commercial terms); and
• (h) To request to withdraw consent to processing where the legal basis for processing is solely justified on the grounds of consent.

8.2 You can request further information about the rights detailed in this section, or request to enforce such rights by contacting us at the detail set out under Section 9. We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests. We may request that you provide information necessary to verify your identity before responding to any request you make.

9. Contact us

9.1 If you have any queries about the contents of this Notice or you wish to make a request to exercise your rights, you can do so by emailing us at dpo@mclear.com or sending the query or request by mail to: FAO Privacy Compliance Officer,  McLear Ltd, Steel House, Alexander Place, 13-17 Princes Road, Richmond, Surrey, TW10 6DQ, United Kingdom.

10. complaints

10.1 You are entitled to lodge a complaint with our data protection regulator if you consider that we have breached your data protection rights. Our data protection regulator is the Information Commissioner’s Office, which can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

11. How we update or change this NOTICE

11.1 We may change or update parts of this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this Notice on this web page. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Notice so you are fully aware of any changes or updates.

11.2 This Notice was issued on 30 November 2020.