This Privacy Policy explains how WinUTrips Ltd ("we", "us", or "our") collects, uses, shares, and protects your personal data when you use our website and services. We are committed to protecting your privacy in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Introduction
WinUTrips operates a prize competition platform for travel experiences and event tickets. This policy applies to all personal data we collect through our website, mobile applications, and related services.
By using our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our services.
2. Data Controller
WinUTrips Ltd is the data controller for your personal data.
- Company Name: WinUTrips Ltd
- Registered in: England and Wales
- Email: privacy@winutrips.com
- Address: Unit 14 Skyline House, 200 Union Street, London, SE1 0LX, United Kingdom
3. Data We Collect
We collect the following categories of personal data:
3.1 Information You Provide
- Account Information: Name, email address, password, date of birth, phone number
- Profile Information: Display name, avatar
- Transaction Information: Competition entries, ticket purchases, payment details (processed securely by Stripe)
- Communication Information: Messages you send us, customer support enquiries
3.2 Information Collected Automatically
- Device Information: IP address, browser type, operating system, device identifiers
- Usage Information: Pages visited, features used, time spent on site, referral sources
- Location Information: General location based on IP address
3.3 Information from Third Parties
- OAuth Providers: If you sign in with Google, we receive your name, email, and profile picture
- Payment Processor: Stripe provides transaction status and fraud prevention data
4. How We Use Your Data
We use your personal data for the following purposes:
- Service Delivery: To create and manage your account, process ticket purchases, conduct draws, and deliver prizes
- Communication: To send order confirmations, draw results, account notifications, and respond to enquiries
- Legal Compliance: To verify your age and eligibility, comply with gambling regulations, and maintain audit records
- Security: To detect and prevent fraud, protect against abuse, and ensure platform security
- Improvement: To analyse usage patterns, improve our services, and develop new features
- Marketing: With your consent, to send promotional communications about new competitions
5. Legal Basis for Processing
Under UK GDPR, we process your personal data on the following legal bases:
- Contract: Processing necessary to provide our services and fulfil our agreement with you
- Legal Obligation: Processing required to comply with UK gambling laws, tax regulations, and consumer protection laws
- Legitimate Interests: Processing for fraud prevention, security, service improvement, and business operations
- Consent: Marketing communications and non-essential cookies (you may withdraw consent at any time)
6. Data Sharing
We may share your personal data with:
- Payment Processors: Stripe processes payments on our behalf and receives necessary transaction data
- Delivery Partners: Royal Mail, DHL, or other carriers to deliver prizes
- Service Providers: Hosting providers (Vercel), email services (Resend), analytics (Google Analytics)
- Legal Authorities: When required by law, court order, or to protect our legal rights
- Independent Draw Supervisors: Third-party verification for draw integrity
We do not sell your personal data to third parties for marketing purposes.
7. Data Retention
We retain your personal data for the following periods:
- Account Data: For as long as your account is active plus 6 years after closure (for legal and tax purposes)
- Transaction Records: 7 years (as required by UK tax law)
- Draw Records: Indefinitely (for regulatory compliance and dispute resolution)
- Marketing Data: Until you withdraw consent or unsubscribe
- Analytics Data: 26 months (anonymised after this period)
8. Your Rights
Under UK GDPR, you have the following rights:
- Right of Access: Request a copy of your personal data
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure: Request deletion of your data (subject to legal retention requirements)
- Right to Restrict Processing: Request limitation of how we use your data
- Right to Data Portability: Receive your data in a structured, machine-readable format
- Right to Object: Object to processing based on legitimate interests or for direct marketing
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
To exercise your rights, please contact us at privacy@winutrips.com. We will respond within one month.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.
10. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of data in transit (HTTPS/TLS)
- Encryption of data at rest
- Secure password hashing (scrypt)
- Regular security assessments
- Access controls and authentication
- Audit logging of sensitive operations
While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.
11. International Transfers
Your data may be transferred to and processed in countries outside the UK. We ensure appropriate safeguards are in place, such as:
- Transfers to countries with UK adequacy decisions
- Standard Contractual Clauses approved by the ICO
- Binding Corporate Rules for transfers within corporate groups
12. Children's Privacy
Our services are only available to individuals aged 18 or over. We do not knowingly collect personal data from children under 18. If we discover that we have collected data from someone under 18, we will delete it immediately.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through a notice on our website. The "Last updated" date at the top indicates when this policy was last revised.
14. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
- Email: privacy@winutrips.com
- Post: WinUTrips Ltd, Unit 14 Skyline House, 200 Union Street, London, SE1 0LX, United Kingdom