This policy explains what personal data Accumulate collects, why, and what you can do about it. It applies to accumulate.lol and to entering our competitions.

Who is responsible for your data

The data controller is WinWink Ltd, company number 12711240, registered in England and Wales at WinWink, 11 Laura Place, Bath, England, BA2 4BL, United Kingdom, trading as Accumulate. For anything to do with your data, email info@accumulate.lol.

What we collect

• Account details - your name, email address, and any phone number or address you give us.
• Entry and order history - which competitions you entered, how many entries, when, and what you paid.
• Payment data - handled by our payment provider. We receive confirmation that a payment succeeded and a reference for it. We never see or store your full card details.
• Winner verification data - if you win, we collect what we need to confirm your identity and age, and the bank details to pay you. We ask for this only from winners.
• Postal entries - the name, address, and account email written on any free entry you post to us.
• Technical and security data - IP address, device and browser information, and a device fingerprint used to detect duplicate accounts and fraudulent entries. Protecting the integrity of a draw is the reason this exists.
• Communications - emails and messages you send us, and our replies.

Why we use it, and on what basis

• To run competitions and your account - entering you into draws, allocating entry numbers, notifying and paying winners, and providing support. Basis: performance of our contract with you.
• To prevent fraud and keep draws fair - detecting duplicate accounts, automated entry, and payment fraud, and enforcing exclusions. Basis: our legitimate interests in a competition that is not rigged and a business that is not defrauded.
• To meet legal obligations - tax and accounting records, and responding to lawful requests. Basis: legal obligation.
• To send you marketing - updates on new draws and results. Basis: your consent, which you can withdraw at any time from the link in every email or in your account settings.
• To measure and improve the site - understanding which pages and campaigns work. Basis: your consent, through the cookie banner, for anything non-essential.

Who we share it with

We do not sell your personal data, and we do not share it for anyone else's marketing. We share only what is needed with:

• our payment provider, to take payment and process refunds;
• Basecomp, the platform this site runs on, as our hosting and processing provider;
• our email delivery provider, to send account and competition emails;
• analytics and fraud-prevention providers, where you have consented or where the processing is necessary for security;
• professional advisers, and authorities where we are legally required to disclose.

Where a provider is outside the UK or EEA, we rely on approved safeguards such as the UK International Data Transfer Addendum or an adequacy decision.

Publishing winners

We publish the winning entry number and the draw's verification data for every competition. Where we name a winner, we use a first name and a county or country only, unless they have agreed to more. Your full contact details are never published.

How long we keep it

• Account and entry records - for as long as your account is open, then up to 7 years, because they are financial records.
• Winner verification records - up to 7 years, for tax and audit.
• Self-exclusion records - kept indefinitely, so that an exclusion cannot be undone by deleting an account.
• Marketing consent records - until you withdraw consent, then a minimal record that you did.

Your rights

Under UK data protection law you can ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, or transfer it elsewhere. You can withdraw consent for marketing or non-essential cookies at any time.

To exercise any of these, email info@accumulate.lol. We respond within one month. Some data we must keep despite a deletion request, such as financial records and self-exclusion records - we will tell you if that applies.

If you are unhappy with how we have handled your data you can complain to the Information Commissioner's Office at ico.org.uk, though we would rather you told us first so we can put it right.

Security

The site runs over HTTPS, passwords are stored hashed, and access to personal data is limited to those who need it. No system is perfectly secure, but we take this seriously and will tell you and the ICO if a breach ever puts you at risk.

Under 18s

Accumulate is for adults. We do not knowingly collect data from anyone under 18. If we find that we have, we delete it and close the account.

Cookies

See our Cookie Policy for what we set, why, and how to change your choices.

Changes

If we change this policy we will update this page, and tell you directly if the change materially affects you.