RAISE YOUR GAME - PRIVACY NOTICE

RAISE YOUR GAME LTD

PRIVACY NOTICE

1. ABOUT THIS NOTICE
1. Raise Your Game Ltd is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
2. Data protection law says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely

1. If you have any questions about this notice or how we collect and use personal information about you please contact us.

1. INFORMATION ABOUT US
1. We are Raise Your Game Ltd. Our registered office is at Raise Your Game, Woolpack House, 70 Brinksway, Stockport, Cheshire, SK3 0BY.Our registered company number is 16023811 (referred to “we”, “us”, “our” throughout this private notice).
2. If you have any questions, contact as follows:
1. Post - Raise Your Game, Woolpack House, 70 Brinksway, Stockport, Cheshire, SK3 0BY.
2. Email and Phone – the contact details displayed on our website atRaise Your Game
2. DATA WE COLLECT ABOUT YOU

Personal Data

1. We will collect personal data about you.
2. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, which is anonymous data.
3. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a) Identity Data includes title, first name, maiden name, last name, username or similar identifier, age and/or date of birth, gender, town of residence, and photo(s) and/or video(s) of You.

(b) Contact Data includes billing address, delivery address, email address and telephone numbers.

(c) Financial Data includes bank account and payment card details.

(d) Transaction Data includes details about transactions (completed or in process), payment amounts/dates to and from you and other details of products and services (including subscriptions for prize draws) you have purchased from us.

(e) 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, and other technology on the devices you use to access our website and/or any host landing page(s).

(f) Profile Data includes your username and password, purchases or orders made by you (including details of prize draws and/or subscriptions entered into by you, and/or Prizes won by you, in connection with the same), your interests, preferences, feedback and survey responses.

(g) Usage Data includes information about how you use our website and/or any host landing page(s), services, and prize draws entered into by you.

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

Aggregated Data

1. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
2. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

1. We do not collect any Special Categories of Personal Data.
2. Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
1. HOW IS YOUR PERSONAL DATA COLLECTED?
1. We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact by making purchases on our website (including via any host landing page(s)), or by telephone or by corresponding with us by email, telephone, post or otherwise. This includes personal data you provide when you:
• purchase our products or services;
• create an account on our website (including via any host landing page(s));
• subscribe or request marketing to be sent to you;
• complete a survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website and/or any host landing page(s), 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy (on our website at Raise Your Game) for further details.
• Third parties or publicly available sources. We will not receive personal data about you from third parties or public sources unless stated otherwise in this privacy notice.
• Technical Data from the following parties:
• our analytics provider (e.g. Google Analytics);
• advertising networks (such as Meta, Google, Pinterest, based inside and outside the UK); and
• search information providers (such as Google Adwords based inside and outside the UK).

1. HOW WE USE YOUR PERSONAL DATA
1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract - where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interest - where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal Obligation – where we need to comply with a legal obligation.
• Consent – where we have obtained your active agreement to use your personal data for a specified purpose (e.g. where you subscribe to marketing and/or give us permission to use photos and videos of You).

1. Please click here Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending (and/or permitting third parties with whom we share your personal data, to send) direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
1. We have set out below, in a table format, a description of all the ways we plan to use 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.
2. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
Register you as a new customer	Identity Contact	Performance of a contract with you
Process and deliver your subscriptions/draw purchases: (a) Manage payments and charges (b) Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to receive and recover debts due to us)
Notify you of prize wins	Identity Contact Transaction	Performance of a contract with you Necessary for our legitimate interests
Publicise on our website and/or relevant host landing pages, that you have won a Prize	Identity (first name, surname, town of residence and Photo / short video of you)	Consent
Manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Enable you to complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Administer and protect our business and this website and any host landing page(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	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) Necessary to comply with a legal obligation
Deliver relevant website and/or host landing page(s) content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Technical Profile Usage Marketing and Communications	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)
Data analytics to improve our website and the host landing page(s), products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and/or any host landing page(s) updated and relevant, to develop our business and to inform our marketing strategy)
Suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Profile Usage Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

1. MARKETING

Marketing

1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

1. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
2. You will receive marketing communications from us if you have expressly opted in to receive marketing from us.

Third-party marketing

1. We will get your express opt-in consent before we share your personal data with any third party (including any hosts and/or nominated charities we work with) for marketing purposes. This does not apply to our use of marketing organisations operating directly on our behalf.

Opting out

1. You can ask us or third parties to stop sending you marketing messages at any time by:

• following the opt-out links on any marketing message sent to you;
• contacting us at any time via email; or
• logging into the website (and/or the relevant host’s landing page where applicable) and checking or unchecking relevant boxes to adjust your marketing preferences.

1. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

1. CHANGE OF PURPOSE
1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
2. DISCLOSURES OF YOUR PERSONAL DATA

Disclosure of your personal data

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

• Group Companies
• External Third Parties.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Group Companies

1. We may share your personal data within our group of companies for strategic direction and operational management purposes.

External Third Parties

1. We may share your personal data with the following external third parties:

• Draw hosts and nominated charities – third party organisations who we partner with for the purposes of host prize draws and subscriptions for the same (e.g. football clubs).
• Service providers - who provide IT and system administration services.
• Third party payment providers – we use third party payment providers to manage payments (e.g. Stripe).
• Suppliers - in relation to resolving a product issue you have raised or in the event of a product recall.
• Professional advisers - including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities - who require reporting of processing activities in certain circumstances.

Disclosure requirements for their parties

1. 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.

1. WEBSITE INFORMATION

Cookies

1. Please see our Cookies Policy (on our website at Raise Your Game) regarding the use of cookies on our website and/or the host landing pages.
2. You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this website and/or the host landing pages may become inaccessible or not function properly.

Third Party Links

1. This website and/or the host landing pages 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.
1. INTERNATIONAL TRANSFERS
1. We are based in England and our main data centre is located in the UK.However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the European Economic Area (EEA).It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers.
2. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
3. Some countries or organisations outside of the UK which we may transfer your information to will have an "adequacy decision" in place, meaning the UK considers them to have an adequate data protection regime in place.These are set out on the Information Commissioner’s website.
4. Where we transfer data to countries or organisations outside of the UK and the EEA which is not considered to have an adequate data protection regime in place, we will ensure that appropriate safeguards. For example, ensuring UK government approved standard international data transfer clauses are put in place where required.
5. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
2. DATA SECURITY
1. 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.
2. 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.
3. DATA RETENTION
1. 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.
2. 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.
3. By law we have to keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes.
4. In some circumstances you can ask us to delete your data. Please see “Your Rights” section below for further information.
5. 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.
4. YOUR RIGHTS

Your Rights

1. Data protection law gives you a number of rights when it comes to personal information we hold about you.The key rights are set out below.More information about your rights can be obtained from the Information Commissioner's Office (ICO).Under certain circumstances, by law you have the right to:

• Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights.This is why we are providing you with the information in this notice.If you require any further information about how we use your personal information, please let us know.
• 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.
• Lodge a complaint.If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).

1. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required

1. 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

1. 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

1. 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.

1. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
1. We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
2. 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.
2. GLOSSARY

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.

Version: 16 January 2025