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Privacy Policy

Last updated: [DATE]

1. Data Controller

[PROMOTER NAME] ("we", "our", "us") is the data controller for the personal data collected through this product guarantee scheme. We are committed to protecting your privacy and processing your data in accordance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018.

2. What Data We Collect

We collect the following personal data when you register or make a claim:

  • Name and email address
  • Phone number (if provided)
  • Postal address (if provided during a claim)
  • Product details, purchase date, purchase price, and retailer
  • Proof of purchase (receipt)
  • Bank account details (encrypted, used for approved claim payments only)
  • Device fingerprint (used for fraud prevention only)
  • IP address (used for fraud prevention and rate limiting)

3. How We Use Your Data

We use your data to:

  • Process your product registration and maintain your protection record
  • Verify your identity and process claims
  • Transfer approved claim payments to your bank account
  • Send communications about your registration or claim
  • Prevent fraud and duplicate entries
  • Send marketing communications (only if you opted in)

4. Lawful Basis

We process your registration and claim data on the basis of contractual necessity (to perform the guarantee scheme) and legitimate interests (fraud prevention). Marketing communications are based on your explicit consent, which you may withdraw at any time.

5. Sharing Your Data

We share your data with TBK Agency Ltd, who operate this promotion on our behalf. We do not sell your data or share it with third parties for marketing purposes. Data may be shared with payment processors to process approved claim payments.

6. Data Retention

Registration and claim data is retained for [RETENTION PERIOD] after the promotion ends to comply with legal and financial record-keeping obligations. Device fingerprints and IP addresses used for fraud prevention are retained for [PERIOD] and then deleted.

7. Your Rights

Under UK GDPR you have the right to:

  • Access the personal data we hold about you
  • Correct inaccurate data
  • Request deletion of your data (subject to legal obligations)
  • Object to or restrict our processing
  • Withdraw consent for marketing at any time

To exercise these rights, contact us at [PRIVACY_EMAIL]. You also have the right to lodge a complaint with the ICO at ico.org.uk.

8. Cookies & Device Fingerprinting

This site uses essential cookies (e.g., to remember cookie consent) and device fingerprinting (via FingerprintJS) to prevent fraud and duplicate entries. No advertising or tracking cookies are used. Device fingerprints are pseudonymous identifiers derived from your browser and are not shared with third parties.