Privacy Notice

PRIVACY NOTICE FOR 20Ten Creative

1. Introduction 

At 20Ten Creative we are committed to protecting your privacy. We will ensure that the information you submit to us throughout your participation in the Free Draw  (the “Free Draw ”) is only used for the purposes set out in this Privacy Notice. 

Please read this document carefully as it sets out what we do with your personal data and how we comply with our legal obligations to you in doing so. This Privacy Notice applies to all individuals who participate in our 20Ten Creative Free Draws. Your participation in the Free Draw and provision of personal data to us constitutes your acceptance of the terms of this Privacy Notice. 

For the purpose of this Privacy Notice and Applicable Data Protection Legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act 2018), the relevant data controller responsible for your data is 20Ten Creative Limited (“us” or "we"). 

If you need or want to get in touch with us, we have provided general contact details in the "How to Contact Us" section of this Privacy Notice. 

We may amend this Privacy Notice from time to time so please check it regularly on the bio of @vuse_worldwide 

If you are dissatisfied with any aspect of our Privacy Notice or how we have handled your personal data, you may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us. 

2. Information we collect about you

We collect information that you voluntarily provide to us, including when you enter the Free Draw, when you respond to our communications or requests for information via direct message on Instagram and when you communicate with us via email, phone or other social media channels. The information you provide may include: 

Instagram name; 
Name; 
Email address; 
Phone number; 
Home address or delivery address;
Country of residence; 
Date of birth; and 
Age.

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review. This Privacy Notice does not apply to, and 20Ten Creative is not responsible for, any third-party websites.

3. Why we collect your Personal data

We collect, use and disclose your personal data for a number of reasons, including: 

to arrange, facilitate and run the Free Draw; 
to verify the age of participants; 
to provide you with information about the Free Draw; 
to ensure that we can provide support and respond to any queries and contact you if you request us to do so; 
to contact the winner of the Free Draw; 
to make available the names of the winners in accordance with the UK Code of Non-broadcast Advertising, Sales Promotion and Direct Marketing (CAP Code); 
to facilitate our internal business operations, including to fulfil our legal or regulatory requirements and to detect or prevent fraud or illegal activities; or 
for other reasons with your consent.

We may not be able to do some or all of these things without your personal data. For example, this Free Draw is open to entrants aged 18 or over. The winner of the Free Draw will be contacted via direct message on Instagram, during which we will ask the winner to confirm that they are aged 18 or over. If you do not confirm to us that you are 18 or over, you will not be able to participate in the Free Draw and we reserve the right to withdraw the prize from you and pick a replacement winner.

In order to enable us to verify your age, we will require you to provide us with your date of birth. In some cases, we may need to ask for additional information in order to verify your age. If this is necessary, we will contact you to explain why. 

4. Legal basis for usage of your personal data 

Where we intend to use your personal data, we rely on the following legal grounds:  

Where using your data is in our legitimate interests: We are allowed to use your personal data where (a) it is non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own or third party’s legitimate interests to do so, and those interests are not outweighed by any potential prejudice to you. 

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to: 

to facilitate our organisation and running of the Free Draw; 
to direct market and advertise 20Ten Creative products and services; 
to the prevention of fraud and to help us establish, exercise and defend legal claims; and 
for our internal administrative purposes.

Performance of a Contract: Where using your personal data is necessary for us to carry out our obligations under our contract with you and in accordance with our terms and conditions. For example, we need to collect your contact details to enable us to contact you if you win the Free Draw. 

Compliance with a legal obligation: We may be required to process your personal information due to legal requirements and other regulatory provisions applicable to the Free Draw.

Consent: We are allowed to use your data where you have specifically consented in connection with certain services that we offer. Where we are reliant upon your consent, you may withdraw this at any time by contacting us, however, please note that we will no longer be able to provide you with the services that rely on having your consent.

We will seek your explicit consent, where we wish to use your name and image in our publicity materials. For example, we will ask for consent when featuring the winners of the Free Draw in any advertising for future Free Draws. If we require your consent for anything in the future, we will provide you with sufficient information so that you can decide whether or not you wish to consent. 

5. Sharing your personal data with third parties

We will share your information primarily to ensure that we administer the Free Draw in a fair, efficient and transparent manner, provided in all instances that such processing is consistent with Section 4 (Legal basis for usage of your personal data) above. We may share your information with the following contracted third-party service providers: 

Our agents implementing the Free Draw. We may share your personal data with our Free Draw fulfilment agent in order to fulfil our legal obligations and ensure that the Free Draw is run effectively. 
Tax, audit, or other authorities. We may share your information with tax, audit or other authorities when we believe that the law or other regulation requires us to do so (for example, because of a request by a tax authority or in connection with any anticipated litigation) or in order to help prevent fraud or to enforce or protect the rights and properties of 20Ten Creative or its subsidiaries; or protect the personal safety of 20Ten Creative employees, third party agents or members of the public. 
Third party service providers. We may share your information with third party service providers who perform functions on our behalf.

Professional advisors and auditors. We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us. 
If a 20Ten Creative entity merges with or is acquired by another business or company in the future, we may share your personal data with the new owners of the business or company. In addition, circumstances may arise where, whether for strategic or other business reasons, 20Ten Creative decides to sell, buy, merge or otherwise reorganise businesses in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from sellers. It is 20Ten Creative’s practice to seek appropriate protection for personal information in these types of transactions.

We do not send any personal information that we collect about you via the Free Draw to any social media sites that you link to your account, e.g. Facebook, nor do we share that information with such sites.

Any third parties that we may share your personal data with are obliged to keep your details securely, and to use them only to fulfil the service they provide us. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with Applicable Data Protection Legislation).

6. How we safeguard your personal data 

We care about protecting your information. That is why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. We are committed to taking all reasonable and appropriate steps to protect the personal data that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures, including encryption measures and disaster recovery plans. 

All employees, officers or contractors of 20Ten Creative and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we take reasonable steps to ensure the security of the Free Draw Website and we will continually strive to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet. 

7. International transfers 

Where you are submitting personal data from within the UK or European Economic Area (“EEA”), such information may be transferred to countries outside the EEA. By way of example, this may happen if one or more of our third-party service providers with whom we share personal data in accordance with section 5 (Sharing your personal data with third parties) are located, or have their servers located, outside your country or the country from which the data were provided.

If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

8. How long we store your personal data 

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.

9. Your rights 

Under Applicable Data Protection Legislation, we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate.

You have various rights in relation to the data which we hold about you. We have set these out below. You can request:

access to the personal data we hold about you
corrections or updates to your details;
the erasure of your personal data;
the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to object to, or request the restriction of, our use of your personal data.

Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. 

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. We shall respond to your request within one month, but this period may be extended by two further months where necessary. We may request proof of identification to verify your request. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reasons for doing so. 

If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us using the contact details set out at the end of this Privacy Notice. Please note that we may keep a record of your communications to help us resolve any issues which you raise. 

10. How to contact us

If you have any queries about this Privacy Notice, including your rights in relation to your personal information, or if you wish to contact us with any general queries or concerns, please contact our customer services team by Instagram direct message to @vuse_worldwide or email 20Ten Creative at [BAT@20ten.co.uk]. Right now, due to the current pandemic, we are not in our usual offices. To ensure that your message is seen and dealt with properly please use one of the communication methods above. 