Privacy Policy
This policy explains what personal data Project32 Group Ltd (referred to as "we", "us", or "our" throughout this policy) collects about you, why we collect it, how long we keep it, and the rights you have over it. We are the data controller for the personal data we process about our players.
1. Who We Are
Controller: Project32 Group Ltd, registered office Henleaze House Business Centre, 13 Harbury Road, Henleaze, Bristol, BS9 4PN.
For data-protection queries, contact us at privacy@footycomps.com. We aim to acknowledge requests within five working days.
2. What Personal Data We Collect
We collect the following categories of personal data:
Identity data — your name, date of birth, and (where required) information used to verify your age
Contact data — email address, telephone number, postal address
Account data — username, hashed password, account preferences
Transaction data — details of raffles you have entered, payment metadata supplied by our payment processor (we do not see or store your card number)
Communications data — your support tickets, complaints, and any correspondence with us
Marketing data — your marketing preferences, the channels you have opted into, and a record of which messages we have sent you
Technical data — IP address, device and browser information, and cookies (see our Cookie Policy)
3. Why We Use It and on What Legal Basis
Under UK GDPR we have to tell you the lawful basis we rely on for each purpose. The bases we use are:
Contract — to create and run your account, take your entries, process payments, run draws, and deliver prizes. Without this data we cannot enter you into a raffle.
Legitimate interests — to keep the site secure, to detect and prevent fraud, to recover debts, to maintain analytics in aggregate, and to handle queries from people who are not yet customers. We have weighed our interest against your rights and consider the processing proportionate; you can object at any time using the contact details above.
Consent — to send you marketing emails or other promotional communications. You give consent during signup or in your account settings, and you can withdraw it at any time without affecting any other use of your data.
Legal obligation — to keep records we are required by law to retain (for example, tax and accounting records, complaint files, age-verification evidence).
4. Who We Share It With
We do not sell your personal data. We share it only with the following categories of recipient and only to the extent necessary for the purposes above:
Payment processors — to take payment for paid entries and process refunds
Email and SMS providers — to deliver transactional and (with your consent) marketing messages
Hosting and infrastructure providers — to run the site itself
Identity-verification providers — where we need to confirm you are 18 or over, or your address for prize delivery
Prize-fulfilment partners — where a third party is delivering a prize directly to you
Professional advisers — accountants, auditors, and lawyers, bound by confidentiality
Law enforcement, regulators, or courts — when we are required to disclose by law
5. International Transfers
Some of our service providers (notably parts of our hosting and email infrastructure) are based outside the UK, including in the United States. Where personal data leaves the UK we rely on UK-government-recognised adequacy decisions, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism. You can request a copy of the safeguards we have in place at the data-protection email above.
6. How Long We Keep It
We keep your data only for as long as we need it.
Active account data — for as long as you have an account with us
Account closed by you or by us — up to seven years after closure, to satisfy financial-record-keeping obligations
Marketing consents and the record of messages we have sent — until you withdraw consent, then for two further years to evidence the prior consent
Complaint files — at least three years from the date the complaint was resolved
Age-verification evidence — for as long as you have an account, then for two further years
Aggregated analytics — indefinitely (it cannot identify you)
7. Your Rights
Under UK GDPR you have the following rights, free of charge in most cases:
Access — request a copy of the personal data we hold about you
Rectification — ask us to correct anything that is wrong or incomplete
Erasure — ask us to delete your data, subject to any obligation we have to keep it (such as financial records)
Restriction — ask us to pause processing while a query or dispute is being resolved
Portability — receive a machine-readable copy of the data you provided to us, or have it transmitted to another controller
Object — object to processing we carry out under legitimate interests
Withdraw consent — for any processing based on consent (including marketing) at any time
To exercise any of these rights, email privacy@footycomps.com. We will respond within one calendar month. We may need to verify your identity before we can act on a request.
8. Automated Decision-Making
We do not make automated decisions that produce legal or similarly significant effects on you. The draws themselves are random and do not assess any personal characteristic. We may use automated tools to flag suspicious activity for human review, but a person decides the outcome.
9. Marketing
Marketing emails go out only to people who have opted in. Every marketing message includes an unsubscribe link that takes effect immediately. You can also manage your preferences from your account settings — opt out of one channel or all channels at any time. Unsubscribing from marketing does not unsubscribe you from transactional messages (purchase confirmations, draw results, account notices) which we are required to send.
10. Cookies
We use cookies and similar storage technologies to keep you signed in, remember your preferences, and (with your consent) measure how the site is used and serve relevant advertising. You control non-essential cookies through the consent banner that appeared on your first visit and can revisit your choices at any time from the Cookie Policy page.
11. Under-18s
This site is for adults only. You must be 18 or over to enter any raffle. We do not knowingly collect personal data from anyone under 18; if we discover we have, we delete it.
12. Complaints to the ICO
You have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. We would prefer you talk to us first so we can try to put things right, but you can contact the ICO at any time at ico.org.uk or on 0303 123 1113.
13. Changes to This Policy
We update this policy when we change how we use your data or when the law changes. The "last updated" date below tells you when. If we make a change that materially affects your rights we will tell you by email or by an in-account notice before the change takes effect.