PRIVACY AND COOKIE NOTICE

    A.F. Blakemore and Son Limited (we, us or our) respect your privacy and are committed to protecting your personal data. This privacy and cookie notice will provide you information about how we look after your personal data when you enter the “Easter Spinner Winner” competition (the Competition) and/or use the website “www.sparspinwin.co.uk” (the Website), and how cookies are used on the Website. We also tell you about your privacy rights and how the law protects you.

    About this privacy notice

    This privacy notice (together with the applicable terms and conditions of the Competition) applies to your entry into and participation in the Competition and your use of the Website.

    This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

    The Competition and the Website are not intended for children and we do not knowingly collect data relating to children.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements those other notices and is not intended to override them.

    Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

    About us

    For the purpose of data protection laws in the UK, A.F. Blakemore and Son Limited is the controller and is responsible for your personal data. The Competition is a national competition run in conjunction with SPAR (UK) Limited (SPAR).

    If you have any questions, including any requests to exercise your legal rights, please contact us using the details set out below:

    Company Name: A.F. Blakemore and Son Limited

    Address: Longacres Industrial Estate, Rose Hill, Willenhall, West Midlands, WV13 2JP

    Email: [email protected]

    The personal data we collect about you

    Personal data means any information about an individual from which that person can be identified. Personal data does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data: includes your full name and date of birth, and, if required, evidence that verifies your identity and age.
    • Contact Data: includes your email address, mobile telephone number, and postcode.
    • Usage Data: includes details of your use of our Website and participation in the Competition including, but not limited to, how many games you have participated in and the number of prize draw entries submitted.
    • Technical Data: includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties, your communication preferences and where relevant your consent to receive marketing.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the participation in different elements of the Competition. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    We do not collect any ‘special categories’ of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

    Please note that where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you access to the Competition and/or award you a prize as part of the Competition). In this case, we may have to cancel your entry into the Competition but we will notify you if this is the case at the time.

    Please also note that the Website does use cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Section 15 below covers the specific cookies used on the Website and all other information relevant to our use of cookies. If you have any questions about our use of cookies on the Website please contact us.

    How is your personal data collected?

    We will collect and process the following data about you:

    • Information you give us. This is information (including Identity, Contact and Marketing and Communications Data) you give us by filling in forms on the Website as part of the Competition, or by corresponding with us (for example, by email or chat). It includes information you provide when you enter the Competition on the Website. If you contact us, we will keep a record of that correspondence.
    • Information we collect about your use of the Website. Each time you use the Website we will automatically (subject to your acceptance of cookies) collect personal data including Usage Data and Technical Data so that we can manage the Competition and the Website.

    How we use your personal data

    We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

    • Where you have consented before processing.
    • Where we need to perform a contract we are about to enter or have entered with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement.
    • Where we need to comply with a legal or regulatory obligation, including the prevention of crime.

    Specifically, we will use your personal data for the following activities:

    • We will use your Identity Data, Contact Data and Usage Data to administer and make the Competition available to you via the Website. This is necessary for the performance of a contract between you and us, or is otherwise necessary for our legitimate interests in providing the Competition (via the Website) to you. Where Usage Data is collected via cookies, this is used for the same purposes but with your consent.
    • We will use your Identity Data, Contact Data and Marketing and Communications Data to manage our relationship with you including notifying you of changes to the Competition or communicating with you about the Competition. This may be done in our performance of our contract with you, or otherwise in accordance with our legitimate interests in managing the Competition and our relationship with you. Where Usage Data is collected via cookies, this is used for the same purposes but with your consent.
    • We will use your Identity Data, Contact Data and Usage Data to enable you to participate in the Competition. If you win a prize, your Identity Data and Contact Data will be used to validate your entry and notify you that you have won. This may be done in our performance of our contract with you, where no contract is formed it will be used as necessary for our legitimate interests in running the Competition to develop and grow our business. Prize draws will be operated in accordance with our prize draw terms and conditions at www.sparspinwin.co.uk. Where Usage Data is collected via cookies, this is used for the same purposes but with your consent.
    • We will use your Identity Data, Contact Data, Usage Data and Technical Data to administer and protect our business and the Website (including troubleshooting, data analysis and system testing and support). This is necessary for our legitimate interest in running our business and the Website, the provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation, sale or group restructuring exercise, and for compliance with our legal obligations. Where Usage Data and/or Technical Data is collected via cookies, this is used for the same purposes but with your consent.
    • We will use your Identity Data, Contact Data, Usage Data, Technical Data and Marketing and Communications Data to form a view on what we think you as a user may want or need, or what may be of interest to you and in doing so we will only send information that is deemed relevant to you and to deliver content and advertisements to you that are relevant. Generally, this will be necessary for our legitimate interests in developing and growing our business. However, we will rely on your consent for sending you electronic marketing or providing your personal data to a third party to market relevant products or services to you (further details of this data sharing are set out below). You can ask us or any third party to stop sending marketing communications at any time by contacting us or them (depending on who you wish to stop sending the communications).
    • If you contact us, we will use your Identity and Contact Data to respond to you.
    • Where we process personal data on the basis of consent, this means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
    • Where we process personal data on the basis of a legitimate interest, as set out in this privacy notice, legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise we are required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    • We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
    • Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

    Location Data

    The Website features a store locator which will allow you to enter any postcode to see how close any SPAR stores that are participating in the Competition are to that postcode.

    The Website does not collect any location data directly from your device.

    Disclosures of your personal data

    Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected.

    Your personal data will not be disclosed to any other individuals or other entities except in the following circumstances:

    • Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
    • Where we are under a legal duty to do so in order to comply with any legal obligation.
    • Where you have given consent for us to do so, we will share your personal data with SPAR so that they can market relevant goods and services to you. As set out above, you can change your preferences or opt out of receiving such communications from SPAR at any time by contacting them directly or using any preference management tool they offer.
    • On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, such as competition service providers, providers of web development and support, and IT/website/system administration support. Currently such entities include PayPoint and Stormnet Media.
    • In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with our professional advisers, and with other companies and organisations for the purposes of, for example, fraud prevention.
    • If we or substantially all of our business or our assets are acquired by or merged with a third party, in which case personal data that we hold will be one of the transferred assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties that process personal data on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    WeWe may also be required to provide limited details about you to third parties who request confirmation of a valid award in the Competition (namely the grand prize draw) unless you specifically request that we do not do this (which you can do by emailing us with the details above). The information we provide will only be an abbreviated version of your name such that it is unlikely to constitute personal data when provided to the requestor (unless your name is particularly unique). We may have to provide this information (and potentially more detailed information), whether you consent or not, to the Advertising Standards Authority in compliance with our legal obligations in operating the Competition.

    International transfers

    We do not transfer your personal data outside of the UK.

    Should we do so in the future, for example where we engage a third party service provider based outside of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • Where the country your personal data is transferred to has been deemed to provide an adequate level of protection for personal data.
    • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

    Please contact us if you would like an update and/or confirmation on any international transfers of your personal data, and/or if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.

    Security

    All information you provide to us is stored on secure servers. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

    We will collect and store personal data on your device using data caches so that you do not play the same game or activity twice.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

    Data retention

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    We intend to delete all personal data after the Competition has ended save where we have your consent to use it for marketing in the future. We will retain all personal data for a short while after the Competition in case we need provide evidence of compliance with legal obligations.

    In some circumstances you can ask us to delete your data: see section 14 below for further information.

    In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

    Your legal rights

    Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

    • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new personal data that you provide to us.
    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
    • Withdraw consent at any time where we are relying on consent to process your personal data. To be clear, we do not currently rely on consent as a basis of process, however should that change (and we will update this privacy notice if it does) you can as above withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can ask us (or any third party) to stop sending you marketing messages at any time by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us (or them) at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any transaction between us.

    If you wish to exercise any of your above rights, please send a written request to us at the postal or email address listed in section 2 above.

    You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

    Cookies

    We use the following cookies:

    • Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to access secure areas of our website, operate the relevant elements of the Website necessary for the fair and lawful operation of the Competition.
    • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily.
    • Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you and ensure fair operation, and compliance with the terms, of the Competition.

    You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

    Cookie name Purpose Duration
    SpinnerWinner Functionality: Essential to operation of system, used to store your name, postcode, email for use with the application forms to help speed up data entry 1 Year
    SpinnerWinnerConsent Strictly Necessary: Essential to track whether or not you have given consent to the use of cookies on the Website. 1 Year
    SpinnerWinnerFirst Strictly Necessary: Essential to track whether or not you have entered your date of birth and mobile number in the home page, and then clicked continue. 1 Year
    _fbp Analytical: Tracking / analytics token 3 months
    _AntiXsrtToken Strictly Necessary: Essential to operation of system for the user’s session management Expires on Browser close
    _ga Analytical: Google Analytics / tracking token 2 years

    Save as detailed above in section 10 (which covers your personal data including any personal data collected by cookies), we do not share the information collected by the cookies with any third parties except with Google as part of our use of Google Analytics (although to be clear this does not include personal data, only analytical information collected by the above cookies).

    You may block cookies by activating settings on your browser which allow you to refuse the setting of some or all cookies. If you do so choose to block all cookies (including essential cookies) you may not be able to access all or some parts of the Website.

    Changes to this privacy notice and your duty to inform us of changes

    We keep our privacy notice under regular review. This version was last updated on 9th November. It may change and if it does, these changes will be available for review by their inclusion on the Website.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

TERMS PRIVACY POLICY