1. Who We Are

Ruby Competitions Ltd is a UK-registered company operating prize draws.

2. What Data We Collect

We may collect and process the following personal data:

• Full name
• Date of birth
• Email address
• Phone number
• Postal address
• Payment details (handled securely via third-party processors)
• Answers to competition questions
• IP address and browser/device information
• Information submitted via contact forms or postal entries

• Photographic identification documents (e.g. passport, driving licence, national identity card, PASS card) — collected from winners only, for age and identity verification purposes

3. How We Use Your Data Updated

We use your data for the following purposes:

• Processing competition entries and payments
• Contacting winners and arranging prize delivery
• Verifying the age and identity of winners prior to prize release (see below)
• Displaying winner names/towns with consent
• Responding to customer queries
• Fraud prevention and anti-money laundering compliance
• Tax, audit, and legal compliance (e.g. HMRC requirements)
• Internal analytics and service improvement
• Sending promotional emails (only with your consent)

Photo ID — Age and Identity Verification

Where a competition entrant is selected as a winner, we are required to verify that they are aged 18 years or over and are the named account holder. To fulfil this requirement:

• We will request a valid photographic ID document from the winner.
• The document will be reviewed solely for the purpose of confirming name, date of birth, and photograph.
• Photo ID will not be used for any other purpose, shared with any third party (except where legally required), or retained beyond the period necessary to complete verification.
• Once verification is complete, the document will be securely deleted.
• Failure to provide satisfactory Photo ID will result in forfeiture of the prize, as set out in our Terms and Conditions.

Winner Publicity, Photographs and Social Media

As part of ensuring fairness and transparency, Ruby Competitions Ltd may publish information relating to competition winners in order to demonstrate genuine prize fulfilment, announce competition results, maintain customer trust and promote the operation of our competitions.

This may include information already associated with a customer's win on the Ruby Competitions website, such as their public/display name, the competition entered, the prize or amount won, the date of the win and other non-sensitive information relating directly to that win.

Photographs, Videos and Testimonials Supplied by Winners

We may ask winners to provide photographs, video clips or testimonials for use on our website, social media channels, email newsletters or other promotional platforms.

Consent: Where we ask you to provide a photograph, video, testimonial or other material specifically for marketing purposes, we will obtain your consent before using that material.

Withdrawal of Consent: Where our processing is based on consent, you may withdraw that consent at any time by contacting us at [email protected]. Withdrawal of consent will not affect the lawfulness of any processing carried out before consent was withdrawn.

Publicly Available Social Media Profile Images

Where a customer has won a prize and maintains a publicly accessible Facebook or other social media profile, Ruby Competitions Ltd may, in limited circumstances, use the publicly accessible profile photograph associated with that customer when publishing a winner announcement.

This may occur where we can reasonably match the social media profile to the winner using information made publicly available by the customer and/or information associated with their Ruby Competitions account or publicly displayed win information.

We rely on our legitimate interests for this limited processing. Our legitimate interests are to publicly demonstrate genuine prize fulfilment, provide transparency regarding competition results, reduce concerns regarding fictitious winners and promote customer confidence in Ruby Competitions.

We will only use publicly available social media photographs where we consider the use to be necessary, proportionate and unlikely to cause an unjustified impact on the individual's privacy. A publicly accessible photograph will not be treated as consent for unrestricted marketing use.

Unless we obtain separate consent, publicly sourced profile photographs will be used only in connection with the relevant winner, prize or competition result and will not be used as a general endorsement, testimonial, paid advertising creative or unrelated promotional campaign.

We will not knowingly use a publicly available photograph where:

• we cannot reasonably establish that the social media profile belongs to the relevant winner;
• the photograph contains children or other identifiable individuals whose inclusion is not necessary;
• the photograph reveals or could reasonably reveal sensitive or special category personal information;
• the photograph is inappropriate for the intended winner announcement; or
• we are aware that the individual has objected to this type of processing.

Your Right to Object

You have the right to object to our use of your personal information where we rely on legitimate interests.

If you do not want Ruby Competitions Ltd to use a publicly available social media profile photograph in winner announcements, you may contact us at [email protected].

Where we receive an objection, we will consider it in accordance with applicable data protection law. Where appropriate, we will stop future use of the photograph and take reasonable steps to remove existing winner publicity containing the photograph from channels under our control.

Where personal information is being used for direct marketing purposes, you have an absolute right to object to that processing at any time.

4. Lawful Basis for Processing

We process your personal data under the following lawful bases:

• Contractual obligation – to fulfil competition entries
• Legal obligation – e.g. HMRC tax/audit requirements
• Legitimate interest – fraud prevention, age verification, site security
• Consent – for marketing or testimonials

Photo ID documents are processed on the basis of legitimate interest (age verification and fraud prevention) and legal obligation, in accordance with applicable competition legislation and our Terms and Conditions.

5. Data Sharing

We only share your data where necessary and with trusted third parties:

• Payment processors (e.g. Stripe or similar)
• Email marketing platforms (if subscribed)
• Delivery/courier services (for prizes)
• Legal or regulatory authorities (if required by law)
• Website analytics providers (e.g. Google Analytics, Facebook Pixel)

We do not sell your data.

6. Data Retention

We retain your personal data for up to 6 years from the date of your last interaction, in line with HMRC audit obligations. Data may be deleted sooner where appropriate, unless legally required to retain it.

7. Your Rights

You have the following rights under the UK GDPR:

• To access a copy of the data we hold about you
• To correct inaccurate or incomplete data
• To request deletion of your data (where legally permitted)
• To restrict or object to certain processing
• To data portability (in applicable cases)

To exercise any of these rights, contact [email protected]. We may request proof of identity.

8. Cookies and Tracking

We use cookies to enhance your browsing experience, manage sessions, and collect anonymised analytics. For full details, see our separate cookie policy: https://rubycompetitions.rafflex.uk/i/cookie-policy

9. Data Security

We apply technical and organisational measures to safeguard your data, including:

• Secure server hosting
• HTTPS encryption
• Access controls for staff
• Regular security audits

10. International Transfers

We do not routinely transfer your data outside of the UK. If we do, we ensure appropriate safeguards are in place, such as UK-approved Standard Contractual Clauses.

11. Complaints

If you have concerns about how your data is handled, contact us first at [email protected]. You also have the right to complain to the UK Information Commissioner's Office (ICO):

• Website: https://www.ico.org.uk
• Phone: 0303 123 1113

12. Updates to This Policy

We may update this policy from time to time. The latest version will always be available on our website with an updated Effective Date.

For any privacy-related enquiries, please contact: [email protected]