Privacy Policy

Last updated: 12th March 2026

Introduction

Winsmile Competitions respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we process and look after your personal data when you visit our website regardless of where you visit it from.

It also tells you about your privacy rights and how the law protects you.

1. Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how Winsmile Competitions collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase any products or services or take part in a prize draw or competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

WINSMILE LTD is the controller and responsible for your personal data (collectively referred to as "Winsmile Competitions", "we", "us" or "our" in this privacy policy).

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact us:

Email: info@winsmile.co.uk
Website: www.winsmile.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
Profile Data includes your purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our products or services;
Create an account on our website;
Subscribe to our service or publications;
Enter a competition, promotion or survey;
Request marketing to be sent to you;
Give us feedback or contact us.

Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources: We may receive personal data about you from various third parties including analytics providers, advertising networks, search information providers, and payment/delivery service providers.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

To register you as a new customer: Identity and Contact Data — Performance of a contract with you.
To process and deliver your order: Identity, Contact, Financial, Transaction and Marketing Data — Performance of a contract and legitimate interests.
To manage our relationship with you: Identity, Contact, Profile, Marketing and Communications Data — Performance of a contract, legal obligation, and legitimate interests.
To enable you to partake in a prize draw or competition: Identity, Contact, Profile, Usage, Marketing and Communications Data — Performance of a contract and legitimate interests.
To administer and protect our business and this website: Identity, Contact and Technical Data — Legitimate interests and legal obligation.
To deliver relevant website content and advertisements: Identity, Contact, Profile, Usage, Marketing, Technical Data — Legitimate interests.
To use data analytics to improve our website, products/services, marketing, customer relationships: Technical and Usage Data — Legitimate interests.

Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, entered a competition or prize draw and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out above:

Service providers who provide IT and system administration services;
Professional advisers including lawyers, bankers, auditors and insurers;
HM Revenue & Customs, regulators and other authorities such as the Advertising Standards Authority;
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International Transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

In some circumstances you can ask us to delete your data — see "Your legal rights" below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request");
Request correction of the personal data that we hold about you;
Request erasure of your personal data;
Object to processing of your personal data where we are relying on a legitimate interest;
Request restriction of processing of your personal data;
Request the transfer of your personal data to you or to a third party;
Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact us at info@winsmile.co.uk.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.