Competition Privacy Notice

This Promotion Privacy Notice (“Notice") is provided by Lacka Foods Limited ("we", "us", or "our"), whose registered office is Weetabix Mills, Burton Latimer, Kettering, Northamptonshire, NN15 5JR in our capacity as an organiser and promoter of the UFIT Sony Ghostbusters Frozen Empire promotion (the "Promotion"). It applies to all individuals in the Republic of Ireland and United Kingdom (UK) who participate or interact with us in relation to the Promotion.

We are a 'controller' for the purposes of applicable data protection laws, including the EU General Data Protection 2016/679 (GDPR) and Irish Data Protection Act 2018 (for Republic of Ireland customers) and the UK General Data Protection Regulation and the Data Protection Act 2018 (for UK customers) (collectively the "Data Protection Laws"), which means that we are responsible for how we use your personal data. 

Scope

We understand that the security of your personal data is extremely important, and we are committed to respecting your privacy and safeguarding your personal data in accordance with Data Protection Laws. 

This Notice is a summary of what we do with your personal data in relation to this Promotion and you should read it together with our main Privacy Policy (which can be found at https://ufitdrinks.com/pages/cookie-policy.  (the “Privacy Policy”). This Notice is supplemental to our Privacy Policy and contains more information about how we process your personal data if you participate in the Promotion. Separately, the terms and conditions of the Promotion can be found at https://ufitdrinks.com/pages/ghostbusters ("Promotion T&Cs"). 

How we Collect Your Personal Data

We collect and process certain categories of personal information direct from you when you register to, and then, participate in the Promotion and, if you are successful, when you contact us.  

These categories of personal information include: Name, address, phone number and email address (together the “Promotion Personal Data”). 

To the extent that we process other categories of personal data (not described above), please refer to our Privacy Policy.

How we Use Your Personal Data

We will use your Personal Data for the following purposes and legal bases:

Purpose(s) for Processing	Legal Basis
to register your entry in our Promotion. to verify your eligibility to participate in the Promotion in line with our Promotion T&Cs. to contact you in connection with the Promotion, if you win and confirm your acceptance of the Prize and in line with our Promotion T&Cs.	We are permitted to process your personal data on the basis that it is necessary for our performance of the contract you have agreed to enter with us (i.e. the Promotion T&Cs).
for marketing research and analytical purposes. to respond to enquiries, complaints and/or requests by you in relation to the Promotion. to publish and/or make available to the Advertising Standards Authority (for UK customers) and Advertising Standards Authority of Ireland (for Republic of Ireland customers) upon request.	This processing is necessary in pursuit of our legitimate interests in managing our business in a commercially prudent manner.

If you do not provide us with your Promotion Personal Data, you will not be able to register your entry and participate in the Promotion. 

Opting out of marketing and communications data

You can ask us UFIT Drinks to stop sending you marketing communications at any time, by unsubscribing from our email communications or by contacting us at any time using the contact details shown at the end of this Notice. 

Recipients of your Personal Data

We will share your Personal Data with external third-party partners (such as our prize provider Elemant London Ltd and our redemption platform and fulfilment partner) that process your Personal Data for this Promotion as part of the services (such as hosting and assisting with running and fulfilment of the Promotion) which they offer to us. We take all reasonable steps to ensure that such third parties process your data in accordance with Data Protection Laws, only use it in accordance with our contract with them and keep it secure. If you would like more information about our third party processors, please Contact Us.

If you are selected as a winner of the Promotion, we (or one of our authorised third party partners) will ask you to provide us with more information. For example, you may be asked about your city, county or region of residence to fulfil the relevant Prize and because we are obliged to make the winner's name and location (city or county) available to people requesting that information in accordance with the Promotion T&Cs and to comply with the requirements under the Code of Standards for Advertising and Marketing Communications in Ireland  (the “ASAI Code”) and UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the "CAP Code"). As provided in the CAP Code, the winner can object to us publishing or making available the name or reduce the amount of information published or made available. If you have any queries about this, please Contact Us. 

Please note that this does not affect our obligation to provide the relevant information and the winning entry to the UK Advertising Standards Authority and Advertising Standards Authority of Ireland if required to do so. 

Data Retention

If you are not selected as a relevant Prize winner of the Promotion, we will retain your Personal Data for 6 months following the completion of delivery of the relevant Prize to the winners (or if there are any relevant complaints or issues relating to the Promotion and if later, promptly following the resolution of those complaints or issues). After this period has elapsed, your Personal Data will be deleted in accordance with our Privacy Policy.

If you are selected as a relevant Prize winner retain your Personal Data for 6 months after the completion of delivery of the relevant Prize to the winners and any related publicity activities (or if there are any relevant complaints or issues relating to the Promotion and if later, promptly following the resolution of those complaints or issues). After this period has elapsed your personal data will be deleted in accordance with our Privacy Policy. 

Transfers of Personal Data

We do not transfer your Personal Data outside the UK and the European Economic Area. Where we transfer your Personal Data to a UK organisation from the EEA (i.e. the Republic of Ireland), we rely on the European Commission’s adequacy decision in respect of the UK (available here).

Security and Storage of Personal Data

We strive to implement appropriate technical and organisational measures in order to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and any other unlawful forms of processing. We aim to ensure that the level of security and the measures adopted to protect your Personal Data are appropriate for the risks presented by the nature and use of your Personal Data. We follow recognised industry practices for protecting our IT environment and physical facilities.

AUTOMATED DECISION-MAKING

Winners of the relevant Prizes will be selected using automated means, i.e. without human involvement in the decision-making process. 

Your Rights in Relation to Your Personal Data

In certain circumstances, you have the right to request access to, rectification, or erasure of your personal data, or restriction of processing or to object to processing of your personal data, as well as the right to data portability. These rights are not absolute and are subject to restrictions as laid down by law. For more information about your rights, please see our Privacy Policy. If you wish to exercise any of these rights, please Contact Us below.

Complaints

You also have the right to lodge a complaint with the Data Protection Commission (DPC) at any time or your local supervisory authority. Contact details of the DPC are available on its website https://www.dataprotection.ie/. You also have the right to complain to the Information Commissioner's Office (ICO). Information about how to do this is available at www.ico.org.uk.

We would, however, appreciate the chance to deal with your complaints before you approach the DPC or ICO, so please feel free to Contact Us in the first instance.

Contact Us 

Find more information about your rights please read our Privacy Policy at https://ufitdrinks.com/pages/cookie-policy 

If you have any questions about how we handle your personal data in relation to the Promotion, and/or want to exercise any of your rights, please contact us at info@lackafoods.com in writing. All requests will be dealt with promptly and efficiently.

Changes to this Notice

We reserve the right to change this Notice from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Notice.  

Last Updated: [  ∙  ] [  ∙  ] 2024