PRIVACY POLICY

1. Introduction
2. We are committed to safeguarding the privacy of our Website visitors and users (“user/s” – including entrants and voters). In this policy we explain how we will treat your personal information.
3. By using our Website and agreeing to its Polices and Rules, you understand and consent to our processing of your personal information and cookies in accordance with the provisions below, as well as with our other Policies and Rules which might explain further terminology or conditions.
4. Please ensure that you read all the provisions below, and our other Rules and Policies to understand your, and our, rights and duties.
5. Collecting personal information
6. Strictly for the purposes of providing the services and use of the Website to users and for our legitimate business purposes, we may collect, store and use the following kinds of personal information which a user might be required to disclose to us when using the Website, or voting, or entering a Competition (“personal information”):
   i. information about your computer and about your visits to and use of this Website (including, but not limited to, your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths);
   ii. information that you provide to us when registering with our Website (including, but not limited to, information about the user that is personally identifiable like the user’s name, photographs, address, age, gender, e-mail address, phone number(s) and other unique information such as user IDs and passwords, banking/accounting information, product and service preferences and contact preferences that are not otherwise publicly available);
   iii. information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
   iv. information that you provide to us when using the services on our Website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
   v. information contained in or relating to any communications that you send to us or send through our Website; and
   vi. any other personal information that you voluntarily choose to send to us.
7. Using your personal information
8. We will only process your personal information strictly for the purposes of providing the services and use of the Website, and for our legitimate business purposes, as specified in this policy or on the relevant pages of the Website.
9. We may use your personal information to:
   i. administer our Website and business;
   ii. personalise our Website for you;
   iii. enable your use of the services available on our Website;
   iv. supply to you services purchased through our Website;
   v. send statements, invoices and payment reminders to you, and collect payments from you;
   vi. send you non-marketing commercial communications;
   vii. send you email notifications that you have specifically requested;
   viii. send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter, in same communications);
   ix. send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email, SMS or similar technology (you can inform us at any time if you no longer require marketing communications, in same communications or by contacting info@r39.co.uk
   x. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
   xi. deal with enquiries and complaints made by or about you relating to our Website;
   xii. keep our Website secure and prevent fraud; and
   xiii. verify compliance with the terms and conditions governing the use of our Website, and adherence to any applicable laws or lawful authorities’ instructions.
10. If you submit personal information for publication on our Website, we will publish and otherwise use that information in accordance with the rights you grant to us.
11. Disclosing personal information
12. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
13. We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
14. We may disclose your personal information:
    i. to the extent that we are required to do so by law;
    ii. in connection with any ongoing or prospective legal proceedings;
    iii. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
    iv. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
    v. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
15. Except as provided in this policy, we will not provide your personal information to third parties.
16. Should we disclose your personal information to a third party, we will ensure that their standards for processing your personal information are equal to, or better, than those used by us.
17. International data transfers
18. Information that we collect may be stored and processed in, and transferred between, any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
19. We ensure that all foreign processing laws applicable to the processing of your personal information in a foreign country, are applied properly as and when necessary, by our authorised/delegated third party.
20. Retaining personal information
21. Personal information that we process for any purpose(s) shall not be kept for longer than is necessary for that purpose, or those purposes.
22. Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data for the protection and furtherance of the Website’s and our legitimate business needs, as well as:
    i. to the extent that we are required to do so by law or in compliance with lawful instructions provided to us by a legitimate authority;
    ii. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    iii. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of crime prevention and reducing credit risk).
23. Security of your personal information
24. We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
25. We will store all the personal information you provide on our secure (password- and firewall protected) servers.
26. You acknowledge that the transmission of information over the internet is inherently insecure by its nature, and, beyond implementing the reasonable precautions discussed, we cannot guarantee the security of data sent over the internet.
27. You are responsible for keeping the information and password you use for accessing our Website confidential.
28. Amendments
29. We may update this policy, or our other Policies or Rules, from time to time by publishing a new version on our Website.
30. It is your responsibility to periodically check for any changes, and read and understand this policy and the Website’s other Policies and Rules to ensure you are always compliant with them. To this end, we are not responsible for ensuring that you are aware of any applicable changes.
31. Your rights
32. You may instruct us to provide you with any personal information we hold about you, where the provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your South African ID book plus an original copy of a utility bill showing your current address).
33. We may withhold personal information that you request, but only to the extent permitted by law.
34. You may instruct us at any time not to process your personal information for particular marketing purposes. To this end, please contact info@r39.co.uk for further information on this right. Further, you understand that the deletion of certain personal information of yours might result in the Website or services and features related thereto, not functioning properly or at all.
35. Notwithstanding the protections afforded herein, should you desire to be excluded from any marketing or correspondence from us, you may do so by utilising the “opt-out” feature provided in same correspondence or marketing, or by contacting us directly at info@r39.co.uk
36. Third party websites
37. Our Website includes hyperlinks to, and details of, third party websites.
38. We have no control over, and are not responsible for, the privacy policies and practices of these third parties.
39. Whilst we will do all things reasonably necessary to protect your rights of privacy, we cannot guarantee or accept any liability whatsoever for unauthorised or unlawful disclosures of your personal information, whilst in our possession or made by third parties who are not subject to our control, unless such disclosure is as a result of our gross negligence.
40. If you disclose your personal information to a third party, such as an entity which operates a website linked to this Website and is therefore not subject to these provisions, we shall not be liable for any loss or damage, howsoever arising, suffered by you as a result of the disclosure of such information to the third party. This is because we do not regulate or control how that third party uses your personal information. You should always ensure that you read the privacy policy of any third party who is not operating under the protections offered by us.
41. Updating and Correctness of Information
42. Please let us know if the personal information that we hold about you needs to be corrected or updated. We are under no obligation to ensure the correctness of the information you provide us, nor to follow-up with you regarding any required amendments or notices sent to you in this regard.
43. You warrant that the personal information disclosed to us or the Website is directly from you as the user on the Website or in connection to the Competition, and all such personal information is lawfully yours to provide. You may choose to provide additional personal information to us, in which event you agree to provide accurate and current information, and, generally, not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
44. Cookies
45. Our Website uses cookies.
46. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
47. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
48. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
49. Blocking all cookies will have a negative impact upon the usability of the Website. If you block cookies, you understand and accept that you will not be able to use all the features on our Website.
50. Our details
51. This Website is owned and operated by Route 39 Digital Media Ltd.

Updated: 25 June 2020