1. Introduction

Project TEETIME (“TEETIME”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

For the purposes of UK data protection law, the data controller is Project TEETIME.

This Privacy Policy explains how we collect, use, store and share your personal data when you:

• visit our Website
• enter our weekly prize draw (including via the free entry route)
• create an account or subscribe
• make an optional voluntary contribution to junior golf
• contribute prizes or partner support
• contact or correspond with us

TEETIME is not intended for children and we do not knowingly collect personal data relating to individuals under the age of 18.

2. Definitions of Providers (Macro Terms)

For clarity and consistency, the following terms are used throughout this policy:

• Payment Provider – third-party payment processing provider
• CRM Provider – email marketing and customer relationship management system
• Website Provider – website hosting and content management platform
• Analytics Provider – website analytics service
• Advertising Provider – advertising or tracking platforms used (if applicable)
• Fulfilment Partner – third parties used to deliver prizes

These providers act as data processors or independent data controllers depending on their role. Where they act as processors, they process data on our instructions and under contractual safeguards.

3. Contact and Complaints

If you have any questions about this policy or how your data is handled, contact:

Email: hello@teetimedraw.co.uk

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection matters. We encourage you to contact us first so we can attempt to resolve your concern.

4. Personal Data We Collect

We may collect the following categories of personal data:

Identity Data

Name, title (optional), confirmation of age eligibility, account or entry identifiers.

Contact Data

Email address, telephone number, postal address.

Entry and Transaction Data

Entries made (paid or free), subscription status, optional voluntary contributions, prize claims and fulfilment status.

Verification Data

Information required for identity verification, fraud prevention or compliance checks where necessary.

Partner / Contribution Data

Details provided by individuals or organisations offering prize contributions or voluntary support.

Technical Data

IP address, browser type, device type, operating system, time zone and related technical identifiers.

Usage Data

Information about how you interact with our Website.

Marketing and Communications Data

Preferences, consent records and correspondence history.

Payment Data

We do not store full payment card details. Payments are processed securely by our Payment Provider.

We do not intentionally collect special category personal data.

5. How We Collect Your Data

We collect personal data through:

• Direct interactions (account creation, entry forms, communications)
• Automated technologies (cookies and analytics tools)
• Third-party providers (such as Payment Providers and CRM systems)
• Optional voluntary contribution processes
• Prize or partner contribution communications

We use cookies and similar technologies for essential functionality, analytics and (where applicable) advertising. You can manage your preferences via our cookie banner. Further details are provided in our Cookie Policy.

6. How We Use Your Data and Lawful Bases

We process personal data only where we have a valid lawful basis under UK GDPR.

Administering paid entries and subscriptions
Lawful basis: Contract

Operating the free entry route
Lawful basis: Legitimate interests

Managing accounts and entries
Lawful basis: Contract

Winner selection, verification and contact
Lawful basis: Contract

Prize fulfilment
Lawful basis: Contract

Managing voluntary contributions
Lawful basis: Legitimate interests and/or Consent

Managing prize or partner contributions
Lawful basis: Legitimate interests

Customer service and complaints
Lawful basis: Contract and Legitimate interests

Fraud prevention and compliance checks
Lawful basis: Legitimate interests and/or Legal obligation

Website operation and security
Lawful basis: Legitimate interests

Marketing communications
Lawful basis: Consent (and in limited cases, legitimate interests where permitted by law)

Legal, regulatory and audit compliance
Lawful basis: Legal obligation and Legitimate interests

7. Marketing Communications

You may receive marketing communications if:

• you have provided consent; or
• you have engaged with TEETIME and have not opted out, where permitted by law

You can opt out at any time via your account settings or by using the unsubscribe link in communications.

We retain a minimal suppression record to ensure your opt-out preferences are respected.

Service communications (such as entry confirmations, draw results or prize notifications) will still be sent where necessary.

8. Sharing Your Personal Data

We share personal data only where necessary with:

• Payment Providers
• CRM Providers
• Website Providers
• Analytics Providers
• Advertising Providers (where applicable)
• Fulfilment Partners
• Professional advisers (legal, accounting, compliance)
• Regulators or authorities where legally required

We do not sell or rent personal data.

9. International Transfers

Where personal data is transferred outside the UK, appropriate safeguards are applied, including:

• UK adequacy regulations
• International Data Transfer Agreements (IDTAs)
• Standard contractual clauses or equivalent mechanisms

10. Data Security

We implement appropriate technical and organisational measures, including:

• Access controls and restricted permissions
• Secure systems and hosting environments
• Supplier due diligence and contractual safeguards
• Internal governance and policies

We maintain breach response procedures and will notify regulators and affected individuals where legally required.

11. Data Retention

We retain personal data only for as long as necessary for the purposes described:

• Entry, draw and prize records – up to 6 years
• Complaints and disputes – up to 6 years after resolution
• Contribution and partner records – up to 6 years
• Marketing records – until opt-out plus a minimal suppression record
• Technical logs – typically 12 to 24 months

Retention periods may be extended where required to comply with legal, regulatory or accounting obligations.

Where data is no longer required, it is securely deleted or anonymised.

12. Automated Decision-Making

We do not carry out automated decision-making that produces legal or similarly significant effects without human involvement.

Random selection of winners is conducted independently of profiling or behavioural analysis.

13. Your Legal Rights

You have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request erasure of your data
• Object to processing
• Request restriction of processing
• Request data portability
• Withdraw consent where applicable

We may require verification of identity before fulfilling requests.

To exercise your rights, contact: hello@teetimedraw.co.uk

14. Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for their privacy practices or content.

15. Optional Contributions and Fairness Statement

Optional voluntary contributions and prize donations:

• are entirely optional
• do not affect entries, odds or outcomes
• are handled separately from prize participation
• are recorded only for administration, reporting and transparency

No contributor receives preferential treatment in any Draw.

16. Changes to This Policy

We keep this Privacy Policy under review.

The latest version published on the Website will apply.

Where changes are material, we may take reasonable steps to bring them to your attention.