Effective Date: November 2024

  1. Introduction
    1. Welcome to 10TO2, operated by 10TO2 LIMITED (“we,” “us,” or “our” or “Promoter”). We are committed to protecting your privacy and ensuring your personal data is handled in a safe and responsible manner. This Privacy Policy outlines how we collect, use, disclose, and protect information when a user (“you”, “Entrant” or “Winner”) uses our competition and journal platform, www.10to2.co.uk (The “Website”).
  2. Information we collect
    1. Personal Information. We may collect the following personal information:
      1. Contact Information: Full Name, email address, phone number, contact address and contact preferences.
      2. Account Details: Username, password, and profile information.
      3. Payment Information: We do not store any card details. However, we do store billing address (when you make a purchase by entering one of our free or paid competitions). 
      4. Communications: Any information you provide when contacting us or participating in surveys, competitions or feedback.
      5. Demographics: Such as age and gender.
      6. Interest data: Such as affinity categories and in-market segments.
    2. Non-Personal Information. We may also collect non-personal information, including:
      1. Device Information: IP address, browser type, operating system, and device type.
      2. Usage Data: Pages viewed, time spent on the site, cross-device tracking data and links clicked throughout the Website. 
  3. How your personal data is collected
    1. We use different methods to collect data from and about you including through:
      1. 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:
        1. Interact with our Website, including:
        2. Create an account on our Website
        3. Enter a competition
        4. Contact us
        5. Sign up to our newsletter
        6. In-person events
        7. Social media 
      2. Automated technologies or interactions. As you interact with our Website, we will automatically collect technical data (including Usage Data and Device Information) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. 
      3. Payment Information is collected from providers of technical, payment and delivery services.
  4. How we use your information
    1. 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:
      1. 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).
      2. 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.
      3. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
    2. We use the information we collect to:
      1. Provide Services: Facilitate participation in competitions, manage user accounts, and process transactions.
      2. Communication: Announce competition Winners, send personalised updates, newsletters, promotional materials, and respond to any inquiries.
      3. Improvement: Analyse User behaviour to improve Our Website, services, and user experience through aggregated reports.
      4. Legal Compliance: Fulfil legal obligations, resolve disputes, and enforce our terms and conditions.
      5. All information is held for up to 12 months if you decide to close your account. To close your account, please email us at info@10to2.co.uk.
      6. We may hold your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, help deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.
      7. All information used for marketing will remain until you have either opted-out, or explicitly contact us to stop marketing communications.
  5. Sharing your information
    1. We may share your information in the following circumstances:
      1. Service Providers: With third-party service providers who assist in operating our website, operating of our competitions, processing payments, or delivering content.
      2. Legal Requirements: When required by law, legal process, or government request.
      3. Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new owner.
      4. We will never share your data for any purpose other than those outlined in this Section.
  6. GDPR compliance
    1. If you are in the European Economic Area (EEA), We are committed to ensuring your personal data is processed in accordance with the General Data Protection Regulation (GDPR). This includes the following rights:
      1. Lawful Basis for Processing: We will only process your personal data where we have a lawful basis to do so, such as your consent, the necessity to perform a contract, or compliance with legal obligations.
      2. Data Access and Portability: You have the right to request access to your personal data and, where applicable, to request a copy of your data in a commonly used, machine-readable format.
      3. Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or if you withdraw consent upon which processing is based.
      4. Data Processing Restrictions: You can request restrictions on the processing of your data under certain conditions, such as if you contest the accuracy of the data or object to processing.
      5. Objection to Processing: You have the right to object to the processing of your personal data in certain circumstances, including for direct marketing purposes.
      6. To exercise any of these rights under GDPR, or if you have any concerns about how your data is handled, please contact us at info@10to2.co.uk.
  7. Cookies & tracking technologies
    1. What Are Cookies? Cookies are small text files that are stored on your device (computer, smartphone, or tablet) when you visit a website. They help websites recognise your device and store information about your preferences or past actions. Cookies can be “session cookies,” which are deleted after you close your browser, or “persistent cookies,” which remain on your device for a set period.
    2. How We Use Cookies – We use cookies to enhance your experience on our website, provide personalised content, and improve our services. The cookies we use fall into the following categories:
      1. Necessary Cookies – These cookies are essential for the operation of our website. They enable basic functions like page navigation, security features, and access to secure areas. The website cannot function properly without these cookies
      2. Preference Cookies – Preference cookies allow our website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. These cookies help tailor your experience based on your selections.
      3. Statistics Cookies – Statistics cookies help us understand how visitors interact with our website by collecting and reporting anonymous information. This data helps us improve the website’s performance and understand user behaviours.
      4. Marketing Cookies –Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user. These cookies help us deliver targeted advertising and measure the effectiveness of our marketing campaigns.
      5. Third-Party Cookies – We may also use third-party cookies from service providers like analytics tools (e.g., Google Analytics) or advertising networks. These cookies are placed by third-party providers and may track your activities across multiple websites.
    3. Cookiebot and Cookie Management – We use “Cookiebot” to manage cookies on our website. Cookiebot is a tool that provides transparency and control over the cookies used on our site. When you first visit our website, Cookiebot will prompt you with a cookie consent banner, allowing you to choose which categories of cookies you consent to use.
    4. Cookie Consent
      1. Consent Management: Upon your first visit, you will be prompted to accept or reject different types of cookies. You can adjust your preferences at any time by clicking on the “Cookie Settings” link available on our website.
      2. Withdrawing Consent: You have the right to withdraw your consent at any time. You can do this by revisiting the Cookie Settings and adjusting your preferences or by clearing cookies from your browser.
      3. Cookie Declaration – Cookiebot provides a detailed list of cookies used on our website, including their purpose, origin, and duration. You can view this information at any time by accessing the Cookie Declaration section on our website.

  1. Data security
    1. We take reasonable measures to protect your information from unauthorised access, disclosure, alteration, or destruction. However, please note that no method of transmission over the internet or electronic storage is completely secure.
  2. Your rights
    1. You have the following rights regarding your personal information:
      1. Access: Request a copy of the personal data we hold about you at any given time
      2. Correction: Request corrections, updates or amendments to any inaccurate or incomplete data.
      3. Deletion: Request deletion of your personal data, subject to legal obligations the we store.
      4. Opt-out: Unsubscribe from marketing communications at any time.
    2. To exercise any of these rights, please contact us at info@10to2.co.uk.
    3. It is paramount that all data stored against you is accurate and up to date. Please email info@10to2.co.uk if there are any changes. You can also login to your account to update your information without needing to contact us.
  3. Third-party (external) links
    1. Our Website may contain links to third-party websites. We are not responsible for the privacy practices or terms & conditions of these websites. We encourage you to read their privacy policies before providing any personal information.
  4. Children’s & underage privacy
    1. Our website is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will take steps to delete it.
  5. Changes to this Privacy Policy
    1. We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.
  6. Contact us
    1. If you have any questions or concerns about this Privacy Policy, please contact us at info@10to2.co.uk
    2. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with any concerns before you approach the ICO so please contact us in the first instance.