PRIVACY POLICY

PRIVACY: The collection of personal information provided in connection with this Sweepstakes will be used solely for the purposes of; (a) administering this Sweepstakes; and (b) providing future marketing materials regarding Sponsor’s product and services to Entrants via email and other marketing methods. Entrants may opt out of the receipt of future marketing materials at any time by following the instructions found in the marketing material(s) received. Entrant information will not be sold to third parties or used in any other fashion other than what has been described herein.

1. WHAT DOES THIS POLICY COVER?

This policy describes how Zaffle LLC (“Zaffle”, “we”, or “us”) will make use of your data when you access zaffle.com (the “Zaffle Site”), participate in the promotional prize draws (the “Prize Draws”) offered on the Zaffle Site, or contact us. Zaffle LLC are the controllers for the personal data we collect in this context.

This notice also describes your data protection rights, including a right to object to some of the processing that Zaffle carries out for the Site. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.

2. WHAT INFORMATION DO WE COLLECT?

We collect and process personal data about you when you interact with us, and when you participate in the Prize Draws. This includes:

Where you set up an account or complete a transaction:

name;

contact information, such as postal address, email address, and telephone number;

your payment and delivery details for any purchase, including billing addresses and payment card details (note that your payment card details are processed by our third-party payment vendor);

Where you interact with communications:

your marketing preferences, including any consents you have given us (where applicable);

information related to the browser or device you use to access our Site;

Where you voluntarily participate in any surveys:

survey information such as shopping habits, age, gender, income, or other survey data you may choose to provide us if you participate;

Where you win a Prize Draw:

any personal data necessary to grant the prize (e.g., information included in any tax or ownership transfer documents or as part of necessary background checks);

photographs, video recordings, and information when you choose to provide that information.

3. HOW DO WE USE THIS INFORMATION, AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We detail below the purposes for which we use this information, how we use it and who we share it with, and the legal basis for that use.

At a high level, personal data may be shared with third party service providers, who will process it on behalf of Zaffle for various operational purposes (such as website hosting, maintenance, card processing services, email communication services, and the like). We may also share information with third parties to provide and personalize our communications about the Site and to measure the effectiveness of those communications.

Personal data of winners may be shared for purposes of fulfilling the prize, including as part of a necessary background check or as part of preparing any required ownership documents. With permission, personal data for winners may also be shared publicly on the Site or other outlets, for the purposes of publicising who won the Prize Draws, including names, photographs, and videos.

More specifically, we process and share personal data related to the Site for the following purposes and legal bases:

To fulfil a contract or take steps linked to a contract. Where you enter a Prize Draw, we will use your information:

to verify your identity;

to take payments;

to communicate with you, including sending you automated service messages;

to provide customer service;

to draw the winners; and

to arrange the delivery or other provision of prizes for the winners of the draw.

As required by Zaffle to conduct our business and pursue our legitimate interests, we will use your information:

to provide products and services you have requested;

to help us monitor, improve, and protect our products, content, services, and Site, both online and offline;

to investigate and respond to any complaints received from you or from others, about the Site or our products or services;

where you have transacted with us, to send you direct marketing (e.g. email or text message) in relation to our current activities, future events and Prize Draws. You can opt out of this marketing (i) at the time of the collection of your details, (ii) by using the links within the marketing communications or (iii) by contacting us;

to personalise the Site, our products or services for you;

to provide targeted advertising on the Site, selected partner sites and social networks;

to process payment card details, payments and check the validity of the sort code, account number and card number you submit in order to prevent fraud (which is processed by our third party payment vendor);

to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;

to provide the prize to winners;

in connection with legal claims, compliance, regulatory, and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);

to invite individuals to take part in market research; and

in connection with those cookies and similar technologies that are strictly necessary to make the Site function (which cookies we place in accordance with our Cookies Notice and the information provided to you when those technologies are used).

Where you give us consent, we will use your information:

where you have signed up to our mailing list, to send you direct marketing in relation to Zaffle products and services;

in connection with surveys, where you choose to participate in those surveys and choose to provide us any information;

in connection with cookies and similar technologies that are not strictly necessary for Site to function, which technologies we may use to collect or receive information from your websites and elsewhere on the Internet and use that information to provide measurement services and target ads about Zaffle (as further described in our Cookies Notice) and the information provided to you when those technologies are used;

in connection with photographs, video recordings and information about you if you win a Prize Draw and choose to provide that information; and

to use on other occasions the data for the purpose that we explain at that time we seek your consent.

For purposes which are required by law, we may use your information:

In response to requests from government or law enforcement authorities conducting an investigation or courts

Please note that if you post a comment to the Site or other social media sites, the information that you choose to post, including any personal data that you choose to post, may be available generally to the public.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

4. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO DIRECT MARKETING OR OTHER TECHNOLOGIES

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.

With regard to cookies or other tracking technologies, you can adjust your cookie settings in our Cookie Preference Center . You can also set your browser to refuse all or some browser cookies or alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Learn how to manage the cookies in your browser below:

Chrome (desktop) (mobile)

Safari (desktop) (mobile)

Internet Explorer (desktop) (mobile)

Firefox (desktop) (Android)

Android Browser: Click on the top right corner of the app (labeled with “More” or three dots) -> Settings -> Privacy

To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.

You may be able to opt-out of receiving certain personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt-out directly from providers who participate in those programs. You may also be able to adjust your settings regarding personalized advertisements by adjusting the privacy settings in the applications and/or social media platforms you use. Please note that Zaffle does not control or operate these tools or the choices that advertisers and others provide through these tools.

5. WHAT RIGHTS DO I HAVE?

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights,you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to a data protection authority.

6. HOW DO I GET IN TOUCH WITH YOU?

We hope that we can satisfy queries you may have about the way we process your data and any of the details listed above. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at hi@zaffle.com , by writing to Zaffle LLC, 1737 Bella Lago Drive, Clermont FL 34711.

7. HOW LONG WILL YOU RETAIN MY DATA?

Where we process Zaffle account data, we do this for as long as you are an active user of the Site and for 6 years after this.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.

Where we process personal data in connection with processing your contest entry, we keep the data for up to 6 years from your last interaction with us.