These Terms and Conditions prevail in the event of any conflict or inconsistency with any other communications, including advertising or promotional materials. Entry/claim instructions are deemed to form part of the terms and conditions and by participating all claimants will be deemed to have accepted and be bound by the terms and conditions. Please retain a copy for your information.

1. The Promoter: Trigg Digital, C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London, W1T 6QW, United Kingdom
2. The Supplier: Please see each individual promotion for details of the prize supplier.
3. Eligibility: This prize promotion is open to UK residents (England, Scotland, Wales and Northern Ireland) aged 18 years or over, excluding employees and their immediate families (spouse, parent, child, sibling, grandparent and/or “step” family), of The Promoter.
4. Promotional Period: Please see each individual promotion for its prize pool.
5. Entry Instructions: Please see the individual prize promotion for entry details.
6. Only one entry per person per prize promotion unless otherwise stated in the individual promotion. All additional entries will be disqualified.
7. Any entries that the Promoter considers (in our absolute discretion) to be dangerous, vulgar, offensive, indecent, illegal racist, copied, offensive, cruel or fraudulent, or infringe on the rights or copyright of others will be immediately disqualified.
8. No third party or bulk entries. If it becomes apparent that either a participant or household is using any means to circumvent this condition such as, and without limitation, multiple email accounts, multiple reproduced or computer-generated entries, using multiple identities, fraudulently falsifying data, acting fraudulently or dishonestly in the opinion of the promoter or otherwise acting in violation of these terms, these participants will be disqualified, and any prize entitlement will be void. Incomplete, illegible, misdirected or late entries will not be accepted. Proof of sending will not be accepted as proof of delivery or receipt. No responsibility can be accepted for entries that are incomplete, lost due to technical reasons, corrupted, delayed, wrongly delivered, or not received for whatsoever reason.
9. Prize Fund: Please see each individual promotion for its prize pool.
10. Winner Selection: Prize draw winner (s)will be randomly selected by a computerised random generator from all entries. Skills based entries shall be judged based on the judging criteria, set out in the promotion, by a panel which shall include one judge independent to the Promoter.
11. Winner Notification: The winners will be notified by email or phone via the account provided at point of entry within 14 days of the closing date and will have 14 days from notification to claim their prize. If a winner does not claim their prize within this timeframe the promoter reserves the right to withdraw prize entitlement and will award the prize to a reserve drawn at the same time as the original.
12. It is the responsibility of the entrant to provide correct, up-to-date details when entering the prize promotion and acceptance of the prize. The Promoter cannot be held responsible for winners failing to supply accurate information which affects prize acceptance or delivery of their prize.
13. General: Promoter’s decision is final and binding. No correspondence will be entered into. Entry implies acceptance of these terms and conditions.
14. Prizes must be accepted as offered by the named winner. There is no cash or alternative prizes, in whole or part. The prizes are not transferable and cannot be resold.
15. The Promoter reserves the right to substitute a prize of equal or greater value should circumstances outside its control make this necessary.
16. The Promoter reserves the right to verify winners and ask for proof of identity, age and address and to withdraw prize entitlement where there are reasonable grounds to believe there has been a breach of these terms and conditions.
17. You agree that if you are a winner, you will take part in and co-operate fully with reasonable publicity and to the use of your name, photograph and any comments in such publicity without any fee being payable.
18. By entering the Promotion, each entrant grants the Promoter a world-wide, perpetual, irrevocable, non-exclusive, transferable, royalty free and sub-licensable right and licence to use reproduce, modify, adapt, publish or display (in whole or in part) any intellectual property contained in the content of their entry, without royalty, payment or other compensation. Each Entrant agrees not to assert any moral rights in relation to such use and warrants that they have full authority to grant such rights.
19. The Promoter reserves the right, at its sole discretion, to eliminate or disqualify any entries or entrants that it regards as being in breach of these terms and conditions or the spirit of the Promotion. Those who try to circumvent the entry process and/or entry instructions by any method, will be disqualified and any prize award will be void.
20. Entry into the Promotion is at the entrant’s sole risk. To the extent permitted by law, neither the Promoter nor Supplier accept any responsibility for any damage, loss, liabilities, injury, costs, expenses or claims (whether in contract, tort or otherwise) suffered by entrants or any third parties arising out of or in connection with the Promotion and/or accepting a prize. The Promoter and Supplier further disclaim liability for any injury or damage to entrants or any other person relating to or resulting from participation with this Promotion save that nothing in these terms and conditions shall act to limit or exclude the Promoter and Supplier’s liability resulting from its negligence or fraud.
21. If for any reason, the Promotion is not capable of running as planned for reasons (including but not limited to tampering, unauthorized intervention, fraud, technical failures or any other causes beyond the control of the Promoter which corrupt or affect the administration, security, fairness, integrity or proper conduct of this Promotion), the Promoter reserves the right (subject to any written directions given under applicable law) to disqualify any individual who tampers with the entry process and to cancel, terminate, modify or suspend the Promotion.
22. If an act, omission, event or circumstance occurs which are beyond the reasonable control of the Promoter and which prevents the Promoter from complying with these terms and conditions the Promoter will not be liable for any failure to perform or delay in performing its obligation.
23. The Promoter accepts no responsibility for system errors or other issues that may result in disruption to, lost, delayed or not received entries, winner notifications or prizes. The Promoter, the Supplier or its agencies will not be responsible for the non-inclusion of entries as a result of technical failures or otherwise, including any such failure which is within the control of The Promoter or its agencies.
24. Where a prize is provided by a Supplier, the Promoter accepts no responsibility for inaccuracy of any prize description, and The Supplier is responsible for prize fulfilment.
25. If any of these clauses should be determined to be illegal, invalid or otherwise unenforceable then it shall be severed and deleted from these Terms and Conditions and the remaining clauses shall survive and remain in full force and effect.
26. The Promoter and the Supplier reserve the right to cancel, amend, withdraw, terminate or temporarily suspend this promotion in the event of any unforeseen circumstances or technical reason outside its reasonable control, with no liability to any entrants or third parties but will use all reasonable endeavours to avoid consumer disappointment.
27. The decisions of the Promoter are final and binding in all matters relating to the Promotion and no correspondence will be entered into.
28. The Promotion and these terms and conditions, and any disputes arising therefrom, shall be subject to English law and the exclusive jurisdiction of the English and Welsh Courts.
29. Data Protection: Any personal information that entrants share with the Promoter will be kept secure and only used in line with these terms and conditions unless the entrant has opted in to future marketing from the Promoter and/or the Supplier. By entering the promotion, entrants agree that their information may be used by the Promoter to administer the promotion and winners consent to give their name and county for the winners’ list.
30. Promoter’s Privacy Policy https://www.triggdigital.com/privacy-policy/

C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London, W1T 6QW, United Kingdom 

1 INTRODUCTION

1.1 Important information and who we are 

Welcome to Trigg Digital Ltd’s Privacy and Data Protection Policy (“Privacy Policy”). 

At Trigg Digital Ltd (“we”, “us”, or “our”), a company incorporated in England and Wales with company number 12095839, whose registered office is C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London W1T 6QW, we are committed to protecting and respecting your  privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and  regulations of the United Kingdom. 

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy  Policy will tell you about your privacy rights, how the law protects you, and inform our  employees and staff members of all their obligations and protocols when processing data. 

The individuals from which we may gather and use data can include: 

• Customers 
• Suppliers 
• Business contacts 
• Employees/Staff Members 
• Third parties connected to your customers 
• and any other people that the organisation has a relationship with or may need to contact. 

This Privacy Policy applies to all our employees and staff members and all Personal Data  processed at any time by us.

1.2 Who is Your Data Controller 

Trigg Digital Ltd is your Data Controller and responsible for your Personal Data. We are not  obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed  one at this time. Therefore, any inquiries about your data should either be sent to us on email at privacy@triggdigital.com or sent in a letter to Trigg Digital C/O Arthur G Mead Ltd, 4th Floor, Fitzrovia House, 153-157 Cleveland Street, London W1T 6QW, United Kingdom

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. 

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you 

In discharging our responsibilities as a Data Controller we have employees who will deal with  your data on our behalf (known as “Processors”). Therefore, the responsibilities described  below may be assigned to an individual, or may be taken to apply to the organisation as a  whole. The Data Controller and our Processors have the following responsibilities: 

Ensure that all processing of Personal Data is governed by one of the legal bases laid  out in the GDPR (see 2.2 below for more information on those bases); 

Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of  confidentiality; 

Implement appropriate technical and organisational measures to ensure a level of  security appropriate to the risk associated with the processing of Personal Data; 

Obtain the prior specific or general authorisation of the Controller before engaging  another Processor; 

Assist the Controller in the fulfilment of the Controller’s obligation to respond to  requests for exercising the data subject’s rights; 

Make available to the Controller all information necessary to demonstrate compliance  with the obligations laid down in the GDPR and allow for and contribute to audits,  including inspections, conducted by the Controller or another auditor mandated by the  Controller; 

Maintain a record of all categories of processing activities carried out on behalf of a  Controller; 

Cooperate, on request, with the supervisory authority in the performance of its tasks; 

Ensure that any person acting under the authority of the Processor who has access to  Personal Data does not process Personal Data except on instructions from the Controller; and 

Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 LEGAL BASIS FOR DATA COLLECTION 

2.1 Types of Data / Privacy Policy Scope 

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from  you: 

Profile/Identity Data: This is data relating to your first name, last name, gender, date of  birth. 

Contact Data: This is data relating to your phone number, addresses, email addresses,  phone numbers. 

Marketing and Communications Data: This is your preferences in receiving marketing  information and other information from us. 

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. 

2.2 The Legal Basis for Collecting That Data 

There are a number of justifiable reasons under the GDPR that allow collection and processing  of Personal Data. The main avenues we rely on are: 

“Consent”: Certain situations allow us to collect your Personal Data, such as when you  tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’  to a service. 

“Contractual Obligations”: We may require certain information from you in order to  fulfil our contractual obligations and provide you with the promised service. 

“Legal Compliance”: We’re required by law to collect and process certain types of data,  such as fraudulent activity or other illegal actions. 

“Legitimate Interest”: We might need to collect certain information from you to be  able to meet our legitimate interests – this covers aspects that can be reasonably  

expected as part of running our business, that will not have a material impact on your  rights, freedom or interests. Examples could be your address, so that we know where to  deliver something to, or your name, so that we have a record of who to contact moving  forwards.

3 HOW WE USE YOUR PERSONAL DATA 

3.1 Our Uses 

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful basis listed in the  table below. 

Examples provided in the table below are indicative in nature and the purposes for which we  use your data may be broader than described but we will never process your data without a  legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

3.2 Change of Purpose 

We will only use your Personal Data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason and that reason is compatible  with the original purpose. If you wish to get an explanation as to how the processing for the  new purpose is compatible with the original purpose, please contact us. 

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will  explain the legal basis which allows us to do so. 

Please note that we may process your Personal Data without your knowledge or consent, in  compliance with the above rules, where this is required or permitted by law. 

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 How Does Trigg Digital Ltd Protect Customers’ Personal Data? 

We are concerned with keeping your data secure and protecting it from inappropriate  disclosure. Any Personal Data collected by us is only accessible by a limited number of  employees who have special access rights to such systems and are bound by obligations of  confidentiality. If and when we use subcontractors to store your data, we will not relinquish  control of your Personal Data or expose it to security risks that would not have arisen had the  data remained in our possession. However, unfortunately no transmission of data over the  internet is guaranteed to be completely secure. It may be possible for third parties not under  the control of Trigg Digital Ltd to intercept or access transmissions or private communications  unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the  security of any Personal Data you transmit to us. Any such transmission is done at your own  risk. If you believe that your interaction with us is no longer secure, please contact us. 

4.2 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other  rights). However, if your request is clearly unfounded, we could refuse to comply with your  request. 

We may need to request specific information from you to help us confirm your identity and  ensure you have the right to access your Personal Data (or to exercise any of your other  rights). This is a security measure to ensure that Personal Data is not disclosed to any person  who has no right to receive it. We may also contact you to ask you for further information in  relation to your request to speed up our response. 

4.3 Correcting, updating, accessing or deleting your information

Trigg Digital may retain your information for a period of time consistent with the original purpose of collection and during the time needed to pursue our legitimate business interests, conduct audits or comply with our legal obligations.

By emailing privacy@triggdigital.com, you may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s website and services.  Requests to access, change or delete your information will be addressed within a reasonable timeframe.

5 YOUR DATA AND THIRD PARTIES 

5.1 Will We Share Your Data With Third Parties? 

We may also share Personal Data with interested parties in the event that Trigg Digital Ltd  anticipates a change in control or the acquisition of all or part of our business or assets or with  interested parties in connection with the licensing of our technology. 

If Trigg Digital Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer,  sell or assign your Personal Data to a third party as part of or in connection with that  transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the  further use of your Personal Data. In all other situations your data will still remain protected in  accordance with this Privacy Policy (as amended from time to time). 

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy. 

5.2 Cookies and other technologies we use

We use the following types of cookies:

• Essential cookies: These cookies are essential to enable you to view the site.
• Google Analytics: We use Google Analytics to measure the number of visitors to our site. The cookies that Google Analytics uses store information about when a visit occurred, which pages were visited and for how long. None of the information provided by Google Analytics is personally identifiable. It is provided to us as anonymous data.
• Social Media: Social Media share buttons are used throughout the site to enable you to share our content through multiple social media channels. We also cookies to track behaviour on our website for Linkedin and Facebook. This data is not personally identifiable. 

6 HOW LONG WILL WE RETAIN YOUR DATA FOR? 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we  collected it for. We may retain your Personal Data for a longer period than usual in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you.

7 INTERNATIONAL TRANSFER OF DATA 

Your information may be stored and processed in the US or other countries or jurisdictions outside  the US where Trigg Digital Ltd has facilities. We are currently storing data in the EU and so, by using  Trigg Digital Ltd, you are permitting and consenting to the transfer of information, including Personal  Data, outside of the US.

8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY 

We keep our Privacy Policy under review and will place any updates on this webpage. This version is  dated 12 October 2021. By using Trigg Digital Ltd, you consent to the collection and use of data by us  as set out in this Privacy Policy. Continued access or use of Trigg Digital Ltd will constitute your  express acceptance of any modifications to this Privacy Policy. 

9 INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples  are not intended to in any way limit the term which they serve to illustrate. Any email addresses set  out in this policy may be used solely for the purpose for which they are stated to be provided, and  any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the  right to not respond to emails, even if they relate to a legitimate subject matter for which we have  provided an email address. As a matter of common sense, you are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with or  answer your concern or question (e.g. FAQs, other areas of our website etc.). 

Our staff are not authorised to contract on behalf of Trigg Digital Ltd, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a Trigg  Digital Ltd address contradicts anything in this policy, our terms or any official public announcement  on our website, or is inconsistent with or amounts to a waiver of any Trigg Digital Ltd rights, the  email content will be read down to grant precedence to the latter. The only exception to this is  genuine correspondence expressed to be from the Trigg Digital Ltd legal department.