Legal

Privacy Policy

Last updated: 22 July 2026

1. Who We Are

Throwr ('we', 'us', 'our') operates the website at throwr.co.uk. We are the data controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For all data protection enquiries, including requests to exercise your rights, please contact us at [email protected] or via the Contact page on this website.

2. What Personal Data We Collect

We collect the following categories of personal data: (a) Identity data — your first name, last name and age verification; (b) Contact data — your email address and, where required for prize delivery, your postal address and phone number; (c) Transaction data — details of raffle tickets purchased and competitions entered; (d) Technical data — your IP address, browser type and version, time zone, browser plug-in types, operating system, and other technology on the devices you use to access our site; (e) Usage data — information about how you use our website; (f) Marketing and communications data — your preferences for receiving marketing from us. We do not collect any special category data (such as health, race or religion) and we do not collect data from children under 18.

3. How We Collect Your Data

We collect data through: (a) Direct interactions — when you register, purchase tickets, enter a competition or contact us; (b) Automated technologies — cookies, server logs and similar technologies as you interact with our site; (c) Third parties — Stripe (payment processing) may share transaction confirmation data with us. We do not purchase data from data brokers.

4. Legal Basis for Processing

Under UK GDPR, we rely on the following lawful bases to process your personal data: (a) Performance of a contract (Article 6(1)(b)) — to process your entry, handle payment and deliver prizes; (b) Legal obligation (Article 6(1)(c)) — to comply with financial, tax and regulatory requirements, including retaining transaction records; (c) Legitimate interests (Article 6(1)(f)) — to prevent fraud, maintain site security, improve our services and conduct winner announcements; our legitimate interests do not override your rights; (d) Consent (Article 6(1)(a)) — where you have opted in to receive marketing communications; you may withdraw consent at any time.

5. How We Use Your Data

We use your personal data to: process and manage your raffle and competition entries; process payments via Stripe; verify your eligibility (age and residency); contact you if you win a prize; publish winner announcements (first name and general location only); send you marketing communications where you have consented; detect and prevent fraud and abuse; comply with legal and regulatory obligations; and improve our website and services. We will never sell your personal data to third parties.

6. Cookies and Tracking

We use cookies and similar tracking technologies to distinguish you from other users and to improve your experience. Strictly necessary cookies are required for the site to function and cannot be disabled. Analytics cookies (including Google Analytics) help us understand how visitors use the site — these are only set with your consent. You can control or delete cookies at any time via your browser settings; disabling cookies may affect site functionality. A full list of cookies we use is available on request.

7. Third-Party Sharing

We share your personal data only where necessary with the following categories of third party: (a) Stripe Payments Europe Ltd — for secure payment processing; (b) Email service providers — to send transactional and marketing emails; (c) Hosting and infrastructure providers — to operate the website; (d) Law enforcement or regulatory authorities — where required by law or to protect our legal rights. All third-party processors are bound by data processing agreements and are required to keep your data secure. We do not share your data with third parties for their own marketing purposes.

8. International Data Transfers

Your personal data is primarily stored and processed in the United Kingdom. Where we transfer data to countries outside the UK (for example, where a service provider operates internationally), we ensure that appropriate safeguards are in place, such as the UK International Data Transfer Agreement (IDTA), Standard Contractual Clauses, or an adequacy decision by the UK Secretary of State. You may request details of the safeguards in place by contacting us at [email protected].

9. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this policy. Specifically: transaction and entry records are retained for 7 years to comply with HMRC and financial regulations; winner records may be retained indefinitely for audit and transparency purposes (first name and general location only in public-facing content); marketing data is retained until you unsubscribe or withdraw consent; technical and usage data is retained for up to 26 months. When data is no longer required, it is securely deleted or anonymised.

10. Your Rights Under UK GDPR

You have the following rights in relation to your personal data: (a) Right of access — to request a copy of the data we hold about you (Subject Access Request); (b) Right to rectification — to request correction of inaccurate or incomplete data; (c) Right to erasure — to request deletion of your data where there is no compelling reason for us to continue processing it; (d) Right to restrict processing — to request that we limit how we use your data; (e) Right to data portability — to receive your data in a structured, machine-readable format; (f) Right to object — to object to processing based on legitimate interests or for direct marketing; (g) Rights related to automated decision-making — we do not make solely automated decisions that have a legal or similarly significant effect on you. To exercise any of these rights, please contact us at [email protected]. We will respond within one calendar month. There is no charge for making a request. We may need to verify your identity before processing your request.

11. Right to Complain

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection. You can contact the ICO at ico.org.uk, by telephone on 0303 123 1113, or by post at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us first.

12. Data Security

We have implemented appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These include TLS/SSL encryption for data in transit, secure payment processing via Stripe (we never store card details), access controls limiting who can view personal data, and regular security reviews. While we take all reasonable steps to protect your data, no method of transmission over the internet is completely secure and we cannot guarantee absolute security.

13. Children's Privacy

Our services are strictly for individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected data from a minor, please contact us immediately at [email protected] and we will delete it without delay.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The date of the most recent revision appears at the top of this page. Where changes are material, we will notify you by email (if we hold your email address) or by a prominent notice on our website. Continued use of the site after changes are posted constitutes your acceptance of the revised policy.

15. Contact the Data Controller

The data controller for your personal data is Throwr, operating at throwr.co.uk. For all data protection enquiries — including Subject Access Requests, requests to exercise your rights, or concerns about how we handle your data — please contact us at [email protected] or via the Contact page on this website. We aim to respond to all requests within one calendar month.