OTP Consulting LLC · KONGRAVE
Privacy Notice
01 Who we are
OTP Consulting LLC (“we”, “us”) runs KONGRAVE and the FIVE giveaway. We are the data controller for the personal data described in this notice. You can reach us about anything in it at five@otp-consulting.org.
02 What we collect
- When you enter on the website: your name, email address, Instagram handle, the referral link you came through if any, your answers to the eligibility and consent boxes, your IP address, and the date and time of your entry and of your confirmation.
- When you enter by Instagram message: your Instagram account identifier and handle, the email address you give us, the referral link you came through if any, and the date and time of your entry.
- If you win: the information needed to check your eligibility and deliver your prize, such as your surname, first initial and county, state or province for publication, and, for Canadian winners, your answer to the skill-testing question.
- Cookies: the website uses no cookies unless you accept them. If you accept, the Meta Pixel sets a cookie that tells us which of our Instagram ads brought you to the site and whether you confirmed an entry.
03 Why we use it
| Purpose | Legal basis (UK GDPR) |
|---|---|
| Running the giveaway: recording and confirming entries, counting referrals, preventing fraud and duplicate entries, drawing and contacting winners, delivering prizes | Performance of the contract formed by the official rules |
| Publishing winners' surname, first initial and area, and keeping a record that shows the draw was fair | Legal obligation and legitimate interest |
| Sending you KONGRAVE marketing by email or Instagram message | Your consent, given with a separate box that is never ticked in advance |
| Measuring our ads with the Meta Pixel | Your consent, given in the cookie banner |
Without marketing consent, we only send you messages about your entry: the confirmation link, and a message if you win. Withdrawing consent does not affect your entry.
04 Who processes it for us
We use the following service providers, who process your data only on our instructions:
- Supabase, which hosts the entry database;
- Vercel, which hosts the website;
- Resend, which sends our emails;
- ManyChat, which runs our Instagram message conversations;
- Cloudflare, which provides our domain name service and forwards emails sent to us;
- Meta Platforms, for Instagram messaging and, only if you accept cookies, the Meta Pixel.
Some of these providers store data in the United States. Where UK data leaves the United Kingdom, the transfer relies on the safeguards those providers offer, such as the UK International Data Transfer Addendum or the UK Extension to the EU-US Data Privacy Framework.
We do not sell your personal data.
05 How long we keep it
We keep giveaway data for 24 months after the giveaway closes, unless you ask us to delete it sooner. We keep the draw record, which contains the anonymous ticket numbers and a fingerprint of the entry list, for as long as we may need to show that the draw was fair. Website entries that are never confirmed are deleted after 30 days.
06 Your rights
If you live in the United Kingdom, you have the right to access your data, to have it corrected or erased, to restrict or object to its use, to receive it in a portable format, and to withdraw consent at any time. You can also complain to the Information Commissioner's Office (ico.org.uk), although we would like the chance to deal with your concern first.
If you live in Canada, you can access and correct your personal information, and you can withdraw your consent to commercial electronic messages at any time under Canada's Anti-Spam Legislation. Residents of Québec may also read the full French version of the giveaway rules.
If you live in the United States, you can ask us what personal information we hold about you and ask us to delete it.
To use any of these rights, write to five@otp-consulting.org. We answer within one month.
07 Changes
If we change this notice, we will update the date at the top of this page.