Privacy Policy

The business organizing the promotion is the data controller. For this deployment, that controller is GiftL. GiftL supplies the campaign software and processes participant data for the controller. The promotion rules may identify an additional or joint organizer, such as a campaign partner.

Questions or privacy requests can be sent to [email protected]. You may also contact the organizer using the details in the promotion rules or at the participating venue.

• Your phone number, normalized to an international format.
• Campaign activity: answers, score, wheel result, start and completion status, prize, promo/claim code, expiry, and redemption history.
• Any additional answers the organizer asks for in the campaign form, clearly shown before you submit them.
• Technical and security data: browser/user-agent, timestamps, truncated or cryptographically hashed network and device identifiers, risk signals, and reCAPTCHA assessment results where protection is enabled.
• For administrators: Google account email, name, profile image, organization role, sign-in and access records.

Please do not submit sensitive personal data unless the campaign specifically and lawfully asks for it. We do not intentionally collect payment-card details through campaign forms.

• To register your participation, run the quiz or wheel, calculate the result, issue a prize, and validate or redeem it.
• To enforce promotion rules, stock limits, expiry, and one-play-per-phone restrictions.
• To prevent fraud, automated submissions, repeated participation, and service abuse.
• To provide campaign reporting, lead management, customer support, and CSV exports to authorized organizer staff.
• To authenticate administrators and secure, operate, and troubleshoot the service.
• To send marketing messages only where the organizer has a separate lawful basis and gives you the notices and choices required by law. Entering a promotion does not by itself subscribe you to unrelated marketing.

Depending on your location and the campaign, processing is based on: taking steps at your request and performing the promotion terms; the organizer’s legitimate interests in operating a fair and secure campaign, preventing fraud, and measuring results; legal obligations; and consent where law requires it, including for optional marketing or non-essential storage.

Where consent is used, you can withdraw it at any time. Withdrawal does not affect processing already carried out lawfully. Some core data is necessary to enter and deliver the promotion; without it, participation or prize redemption may not be possible.

Quiz prizes are determined from your submitted answers and the campaign’s configured scoring tiers. Wheel results are selected by server-side weighted chance, subject to configured prize availability and campaign limits. These rules are used to deliver the promotion and do not evaluate personal characteristics.

Security controls may automatically flag or block a play using repeated-phone, device, network, rate, and reCAPTCHA signals. If you believe a result or restriction is wrong, contact the organizer for human review. These decisions are not intended to produce legal or similarly significant effects beyond participation in the promotion.

Data may be available to:

• Authorized staff of the organizer and disclosed campaign partners who need it to run the promotion or redeem prizes.
• GiftL and infrastructure providers acting under instructions, such as database, hosting, file-storage, and security providers.
• Google, when Google sign-in, Google Fonts, or reCAPTCHA is used. Google processes related device, network, and interaction data under its own privacy terms.
• Authorities, courts, advisers, or a successor business when disclosure is legally required or necessary to protect rights and security.

We do not sell participant personal data.

Some service providers may process data outside your country. Where applicable law requires it, the controller uses an approved transfer mechanism and appropriate safeguards, such as an adequacy decision or standard contractual clauses. Contact us for information about safeguards relevant to your campaign.

Campaign and prize records are kept for the period set by the organizer, taking account of prize fulfilment, campaign reporting, applicable limitation periods, tax/accounting obligations, disputes, and your rights. They are then deleted or irreversibly anonymized.

Hashed anti-abuse events and server-side device/network scopes expire after 30 days. The protection cookie expires after 31 days. A local device backup remains in your browser until you clear site data. Administrator records are retained while access is active and afterwards only as needed for security, audit, and legal obligations.

Subject to applicable law, you may ask to access, correct, delete, restrict, or receive a copy of your data; object to processing based on legitimate interests or direct marketing; withdraw consent; and request human review of an automated restriction. We may need to verify your identity and may retain limited data where law or a legitimate legal claim requires it.

You may complain to the Ukrainian Parliament Commissioner for Human Rights or to the data-protection authority where you live or work. If the GDPR applies, you also have the right to lodge a complaint in the EU/EEA Member State of your habitual residence, workplace, or the alleged infringement.

We use access controls, encryption in transit, signed claim and play tokens, hashing, limited staff roles, and other organizational and technical safeguards. No online system can be guaranteed completely secure.

Campaign eligibility, including minimum age, is stated in the promotion rules. The service is not directed to children who cannot lawfully provide their own data or enter the promotion. A parent or guardian who believes a child submitted data unlawfully should contact us.

We may update this policy when the service, providers, or law changes. The effective date above shows the latest revision. Material changes will be communicated where required. Contact [email protected] with questions or requests.