The ZB Lucky Draw Platform collects Personal Data from its
Users.
Owner and Data Controller
ZB LUCKY DRAW
For all DPO enquiries, contact our customer service centre on: info@onlinedraws.com
Legal information
This
privacy statement has been prepared based on provisions of multiple
legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data
Protection Regulation).
This
Privacy Policy relates solely to the ZB Lucky Draw Platform, if not stated
otherwise within this document.
Latest update: 4th October 2023
Definitions and Interpretation
In this
Privacy Policy:
- All capitalised words and
expressions used shall have the following meanings; and
- Unless the context otherwise
requires, words in the singular shall include the plural and, in the
plural, shall include the singular.
Cookies / Identifiers |
Portions of code
are placed on a User’s device in order to identify them. |
Cookie Policy |
The ZB Lucky Draw
Cookie Policy, a copy of which can be found on either the ZB Lucky Draw
Website or Mobile App. |
Data Controller (or Owner) |
The natural or
legal person, public authority, agency or other body which, alone or jointly
with others, determines the purposes and means of the Processing of Personal
Data, including the security measures concerning the operation and use of
this Platform. The Data Controller, unless otherwise specified, is the Owner
of this Platform. |
Data Processing / Processing |
The methods used to
collect and Process a User’s Personal Data on the Platform and the processes
used which govern the integrity of the Data Processing. |
Data Processor (or Data Supervisor) |
The natural or
legal person, public authority, agency or other body which processes Personal
Data on behalf of the Controller, as described in this Privacy Policy. |
Data Subject |
The natural or
legal person to whom the Personal Data belongs to. |
European Union (or EU) |
Unless otherwise
specified, all references made within this document to the European Union
include all current member states to the European Union and the European
Economic Area. |
Owner |
ZB Lucky Draw LLC,
a Limited Liability Company incorporated in the UAE. |
Personal Data (or Data) |
Any information
that directly, indirectly, or in connection with other information, such as a
username or password that allows the identification or identifiability of a
natural person. |
Platform or Mobile App |
The ZB Lucky Draw
Website and Mobile App and its associated content which collects and
processes a User’s Personal Data. |
Privacy Policy |
This document which
outlines how the Platform collects, processes and retains a User’s Personal
Data. |
Service |
The Service
provided by the Platform as described in the Terms which can be found on
either the ZB Lucky Draw Website or Mobile App. |
Usage Data |
Information
collected automatically through this Platform (or third party services
employed by this Platform), which can include: the IP addresses or
domain names of the computers utilised by the Users who use this Platform; · the URI (Uniform
Resource Identifier) addresses, the time of the request; · the method
utilised to submit the request to the server, the size of the file received
in response; · the numerical
code indicating the status of the server’s answer (successful outcome, error,
etc.); · the country of
origin, the features of the browser and the operating system utilised by the
User; · the various time
details per visit (e.g., the time spent on each page within the Application); · the details about
the path followed within the Application with special reference to the
sequence of pages visited; other parameters
about the device operating system and/or the User’s IT environment. |
User (You or Your) |
The individual
using this Platform who, unless otherwise specified, is considered the Data
Subject. |
Website |
ZB Lucky Draw’s
internet Website www.emiratesdraw.com (or such other address as may be
advised from time to time). |
Types of Data collected
Among the
types of Personal Data that this Platform collects, by itself or through third
parties, this can be broadly categorised as email address, Usage Data, first
name, last name, telephone number, Cookies, unique device identifiers for
advertising (Google Advertiser ID or IDFA, for example) and geographic
position.
Complete
details on each type of Personal Data collected are provided in the dedicated
sections of this Privacy Policy or by specific explanation texts displayed
prior to the Data collection.
Personal
Data may be freely provided by the User, or, in case of Usage Data, collected
automatically when using the Platform. Unless specified otherwise, all Data
requested by the Platform is mandatory. Failure to provide this Data may make
it impossible for the Platform to provide its Services. In cases where the
Platform specifically states that some Data is not mandatory, Users are free
not to communicate this Data without consequences to the availability or the
functioning of the Service. Users who are uncertain about which Personal Data
is mandatory are welcome to contact the Owner.
Any use of
Cookies, or of any other tracking tools, by this Platform or by the owners of
third-party services used by this Platform, serves the purpose of providing the
Service required by the User, in addition to any other purposes described in
the present document and in the Cookie Policy.
Users are
responsible for any third-party Personal Data obtained, published, or shared
through this Platform and confirm that they have the third party’s consent to
provide the Data to the Owner.
Data Processing
Methods of Processing
The Owner
takes appropriate security measures to prevent unauthorised access, disclosure,
modification, or unauthorised destruction of the Data. Data Processing is
carried out using computers and/or IT-enabled tools, following organisational
procedures and modes strictly related to the purposes indicated. In addition to
the Owner, in some cases, the Data may be accessible to certain persons
involved with the operation of the Platform (such as but not limited to:
administration, sales, marketing, legal, and system administration) or external
parties (such as but not limited to: third party technical service providers,
mail carriers, hosting providers, IT companies and communications agencies)
appointed, if necessary, as Data Processors by the Owner. An updated list of
these parties may be requested from the Owner at any time.
Legal Basis of Data Processing
The Owner
may process Personal Data relating to Users if any one of the following
applies:
- Users have given their consent
for one or more specific purposes. Note: Under some legislations, the
Owner may be allowed to process Personal Data until the User objects to
such Data Processing (“opt-out”), without having to rely on consent or any
other of the following legal bases. This, however, does not apply,
whenever the processing of Personal Data is subject to European data
protection law;
- provision of Data is necessary
for the performance of an agreement with the User and/or for any
pre-contractual obligations thereof;
- Processing is necessary for
compliance with a legal obligation to which the Owner is subject;
- Processing is related to a
task that is carried out in the public interest or in the exercise of
official authority vested in the Owner;
- Processing is necessary for
the purposes of the legitimate interests pursued by the Owner or by a
third party.
In any
case, the Owner will help to clarify the specific legal basis that applies to
the Data Processing, and in particular whether the provision of Personal Data
is a statutory or contractual requirement, or a requirement necessary to enter
into a contract.
Place
Data
Processing is carried out at the Owner’s operating offices and in any other
places where the parties involved in the Data Processing are located.
Depending
on the User’s location, data transfers may involve transferring the User’s Data
to a country other than their own. To find out more about the place of
processing of such transferred Data, Users can refer to the section “Detailed
information on the Processing of Personal Data”.
Users are
also entitled to learn about the legal basis of Data transfers to a country
outside of the European Union, or to any international organisation governed by
public international law or set up by two or more countries (such as the UN),
and about the security measures taken by the Owner to safeguard their Personal
Data.
If any
such transfer takes place, Users can find out more by checking the relevant
sections of this Privacy Policy or inquire with the Owner using the information
provided in the contact section.
Retention time
Personal
Data shall be processed and stored for as long as required by the purpose/s it
has been collected for. Therefore:
- Personal Data collected for
purposes related to the performance of a contract between the Owner and
the User and shall be retained until such contract has been fully
executed.
- Personal Data collected for
the purposes of the Owner’s legitimate interests shall be retained as long
as needed to fulfill such purposes. Users may find specific information
regarding the legitimate interests pursued by the Owner within the
relevant sections of this Privacy Policy or by contacting the Owner.
The Owner
may be allowed to retain Personal Data for a longer period whenever the User
has given consent to such Data Processing, as long as such consent is not
withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a
longer period whenever required to do so for the performance of a legal
obligation or upon order of an authority.
Once the
retention period expires, Personal Data shall be deleted. Therefore, the right
to access, the right to erasure, the right to rectification, and the right to
data portability cannot be enforced after the expiration of the retention
period.
The purposes of Processing
Personal
Data belonging to the User is collected to allow the Owner to provide its
Service, comply with its legal obligations, respond to enforcement requests,
protect its rights and interests (or those of its Users or third parties) or to
detect any malicious or fraudulent activity. In addition, Personal Data may be
used for the following, but not limited to, purposes: advertising, analytics,
contacting the user, displaying content from external platforms, handling
payments, location-based interactions, managing contacts and sending messages,
platform services and hosting, backend infrastructure, User database
management, SPAM protection, and tag management.
For
specific information about how the Personal Data is used for each purpose, the
User may refer to the below section “Detailed information on the Processing of
Personal Data”.
Detailed information on the processing of Personal Data
Personal
Data is collected for the following purposes and using the following Services:
Advertising
This
service allows User Data to be utilised for advertising communication purposes.
These communications are displayed in the form of banners and other advertisements
on the Platform, possibly based on User interests. This does not mean that all
Personal Data is used for this purpose. Information and conditions of use are
shown below. Some of the services listed below may use Cookies or other
Identifiers to identify Users or they may use the behavioural retargeting
technique, i.e. displaying ads tailored to the User’s interests and behaviour,
including those detected outside of the Platform. For more information, please
check the privacy policies of the relevant services.
In
addition to any opt-out feature offered by any of the services below, Users may
opt-out by visiting the Network Advertising Initiative opt-out page.
Users may
also opt out of certain advertising features through applicable device
settings, such as the device advertising settings for mobile phones or ad
settings in general.
Crimtan (Crimtan Holdings Limited)
- Crimtan is an advertising
service provided by Crimtan Holdings Limited.
- Personal Data processed:
Cookies; Usage Data.
- Place of Processing: United
Kingdom – Privacy Policy – Opt-out.
- Category of personal data
collected: Internet information.
Analytics
The
services contained in this section enable the Owner to monitor and analyse web
traffic and can be used to keep track of User behaviour.
Google Analytics (Google LLC)
Google
Analytics is a web analysis service provided by Google LLC (“Google”). Google
analyses the Data collected to track and examine the use of this Platform, to
prepare reports on its activities and share them with the Owner and other
Google services. Google may use the Data collected to contextualise and
personalise the ads of its own advertising network.
- Personal Data processed:
Cookies; Usage Data.
- Place of Processing: United
States – Privacy Policy – Opt-Out. Privacy Shield participant.
- Category of personal data
collected: Internet information.
Google Analytics Advertising Reporting Features
Google
Analytics has Advertising Reporting Features activated on this Platform, which
collects additional information from the DoubleClick cookie (web activity) and
from device advertising IDs (app activity). It allows the Owner to analyse
specific behaviour and interests Data (traffic Data and Users’ ads interaction
Data) and, if enabled, demographic Data (information about age and gender of
Users).
Users can
opt out of Google’s use of Cookies by visiting Google’s Ads Settings.
Personal
Data processed: Cookies; unique device Identifiers for advertising (Google
Advertiser ID or IDFA, for example); various types of Data as specified in the
privacy policy of the service.
Place of
Processing: United States – Privacy Policy – Opt-Out. Privacy Shield
participant.
Category
of personal data collected: Internet information and Identifiers.
Telephone contact
Users that
provided their telephone number might be contacted for commercial or
promotional purposes related to this Platform, as well as for fulfilling
support requests.
- Personal Data processed:
Telephone number.
- Category of personal data
collected: Identifiers.
Displaying content from external platforms
This
service allows Users to view content hosted on external platforms directly from
the pages of this Platform and to interact with them. This type of service
might still collect web traffic data for the pages where the service is
installed, even when Users do not use it.
Google Fonts
Google
Fonts is a typeface visualisation service provided by Google LLC that allows
this Platform to incorporate content of this kind on its pages.
- Personal Data processed: Usage
Data; various types of Data as specified in the privacy policy of the
service.
- Place of Processing: United
States – Privacy Policy. Privacy Shield participant.
- Category of personal data
collected: Internet information.
YouTube
YouTube is
a video content visualisation service provided by Google LLC whose widget
allows this Platform to incorporate video content on its pages.
- Personal Data processed:
Cookies and Usage Data.
- Place of Processing: United
States – Privacy Policy. Privacy Shield participant.
- Category of personal data
collected: Internet information.
Handling payments
Unless
otherwise specified, this Platform processes any payments by debit or credit
card, bank transfer or other means via external payment made to Authorised ZB
Lucky Draw Retailers and other appropriate service providers. In general and
unless where otherwise stated, Users are requested to provide their payment
details and personal information directly to such payment service providers.
This Platform is not involved in the collection and processing of such
information: instead, it will only receive a notification by the relevant
payment service provider as to whether payment has been successfully completed
or not.
CC Avenues Payment Solutions
- Personal Data processed:
Cookies, and Credit Card information
- Place of Processing: United
Arab Emirates
Location-based interactions
Non-continuous geolocation
This
Platform may collect, use and share geographic location Data in order to
provide the User with location-based services. Most browsers and devices
provide tools to opt-out from this feature by default. If explicit
authorisation has been provided, the User’s location data may be tracked by
this Platform.
The
geographic location of the User is determined in a manner that is not
continuous, either at the specific request of the User or when the User does
not point out its current location in the appropriate field and allows the
application to detect the position automatically.
- Personal Data processed:
Geographic position.
- Category of personal data
collected: Geolocation data.
Managing contacts and sending messages
This
service makes it possible to manage a database of email contacts, telephone
contacts or any other contact information to communicate with the User.
These
services may also collect Data concerning the date and time when the message
was viewed by the User, as well as when the User interacted with it, such as by
clicking on links included in the message.
MoEngage
- Personal Data processed: Email
Address, Gender and Purchase information
- Category of personal data
collected: Personal marketing information
SPAM protection
This
service analyses the traffic of the Platform, potentially containing Users’
Personal Data, with the purpose of filtering it from parts of traffic, messages
and content that are recognised as SPAM.
Tag Management
This
service helps the Owner to manage the tags or scripts needed on this Platform
in a centralised manner. This results in the User’s Data being passed through
these services, potentially resulting in the retention of the User’s Data.
User database management
This
service allows the Owner to build user profiles by starting from an email
address, a personal name, or other information that the User provides to this
Platform, as well as to track User activities through analytics features. This
Personal Data may also be matched with publicly available information about the
User (such as social network profiles) and used to build private profiles that
the Owner can display and use for improving the Platform.
Some of
these services may also enable the sending of timed messages to the User, such
as emails based on specific actions performed on this Platform.
Further information about Personal Data
Push notifications
This
Platform may send push notifications to the User to achieve the purposes
outlined in this Privacy Policy.
Users may
in most cases opt-out of receiving push notifications by visiting their device
settings, such as the notification settings for mobile phones, and then
changing the settings for this Platform, or all of the apps on the particular
device.
Users must
be aware that disabling push notifications may negatively affect the utility of
the Platform.
Selling goods and services online
Personal
Data collected is used to provide the User with Services or to sell goods,
including payment and possible delivery.
Personal
Data which is collected to complete the payment may include the debit or credit
card, the bank account used for the transfer, or any other means of payment
envisaged. The kind of Data collected by this Platform depends on the payment
method or system used.
The rights of Users
Users may
exercise certain rights regarding their Data being processed by the Owner.
In
particular, Users have the right to do the following:
- Withdraw
their consent at any time. Users have the right to withdraw consent where
they have previously given their consent to the Processing of their
Personal Data.
- Object
to Processing of their Data. Users have the right to object to the Processing
of their Data if the Processing is carried out on a legal basis other than
consent. Further details are provided in the dedicated section “User’s
rights to object to Processing”
- Access
their Data. Users
have the right to learn if their Data is being processed by the Owner,
obtain disclosure regarding certain aspects of the Data Processing and
obtain a copy of the Data undergoing Processing.
- Verify
and seek rectification. Users have the right to verify the accuracy of
their Data and ask for it to be updated or corrected.
- Restrict
the Processing of User Data. Users have the right, under certain
circumstances, to restrict the Processing of their Data. In this case, the
Owner will not process their Data for any purpose other than storing it.
- Have
their Personal Data deleted or otherwise removed. Users have the right, under
certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive
their Data and have it transferred to another Data Controller. Users have the right to receive
their Data in a structured, commonly used and machine-readable format and,
if technically feasible, to have it transmitted to another Data Controller
without any hindrance. This provision is applicable provided that the Data
is processed by automated means and that the Processing is based on the
User’s consent, on a contract which the User is part of, or on
pre-contractual obligations thereof.
- Lodge
a complaint. Users
have the right to bring a claim before their competent data protection
authority.
Users rights to object to Processing
Where
Personal Data is processed for a public interest, in the exercise of an
official authority vested in the Owner, or for the purposes of the legitimate
interests pursued by the Owner, Users may object to such Processing by
providing a ground related to their particular situation to justify the
objection.
Users must
know that, however, should their Personal Data be processed for direct
marketing purposes, they can object to that Processing at any time without
providing any justification. To learn, whether the Owner is Processing Personal
Data for direct marketing purposes, Users may refer to the relevant sections of
this document.
How to exercise these rights
Any
requests to exercise User rights can be directed to the Owner through the
contact details provided at the beginning of this document. These requests can
be exercised free of charge and will be addressed by the Owner as early as
possible and always within one month.
Cookie Policy
This
Platform uses Cookies and other Identifiers. To learn more, the User may
consult the Cookie Policy, a copy of which can be found on either the ZB Lucky
Draw Website or Mobile App.
Legal action
The User’s
Personal Data may be used for legal purposes by the Owner in Court or in the
stages leading to possible legal action arising from improper use of this
Platform or the related Services.
The User
declares to be aware that the Owner may be required to reveal Personal Data
upon request of public authorities.
Additional information about User’s Personal Data
In
addition to the information contained in this Privacy Policy, this Platform may
provide the User with additional and contextual information concerning
particular Services or the collection and Processing of Personal Data upon
request.
System logs and maintenance
For
operation and maintenance purposes, this Platform and any third-party services
may collect files that record interaction with this Platform (System logs) use
other Personal Data (such as the IP Address) for these purposes.
Information not contained in this Privacy Policy
More
details concerning the collection or Processing of Personal Data may be
requested from the Owner at any time. Please refer to the contact details
provided at the beginning of this document.
How “Do Not Track” requests are handled
This
Platform does not support “Do Not Track” requests.
To
determine whether any of the third party services the Platform uses honour the
“Do Not Track” requests, please read their relevant privacy policies.
Changes to this Privacy Policy
The Owner
reserves the right to make changes to this Privacy Policy at any time by
notifying its Users on this page and possibly within this Platform and/or (as
far as technically and legally feasible) sending a notice to Users via any
contact information available to the Owner. It is strongly recommended to check
this page often, referring to the date of the last modification stated at the
beginning of this document.
Should the
changes affect Processing activities performed on the basis of the User’s
consent, the Owner shall collect new consent from the User, where required.
Categories of personal information collected, disclosed or sold
In this
section We summarise the categories of personal information that We have
collected, disclosed or sold and the purposes thereof. You
can read about these activities in detail in the section titled “Detailed
information on the Processing of Personal Data” within this document.
Information We collect: the categories of personal information
We collect
We have
collected the following categories of personal information about You:
Identifiers, internet information and geolocation data.
We will
not collect additional categories of personal information without notifying
You.
How We collect information: what are the sources of the personal
information We collect?
We collect
the above mentioned categories of personal information, either directly or
indirectly, from You when You use this Platform.
For
example, You directly provide Your personal information when You submit
requests via any forms on this Platform. You also provide personal information
indirectly when You navigate this Platform, as personal information about You
is automatically observed and collected. Finally, We may collect Your personal
information from third parties that work with Us in connection with the Service
or with the functioning of this Platform and features thereof.
How We use the information We collect: sharing and disclosing of
Your personal information with third parties for a business purpose
We may
disclose the personal information We collect about You to a third party for
business purposes. In this case, We enter a written agreement with such third
party that requires the recipient to both keep the personal information
confidential and not use it for any purpose(s) other than those necessary for
the performance of the agreement.
We may
also disclose Your personal information to third parties when You explicitly
ask or authorise Us to do so, in order to provide You with Our Service.
To find
out more about the purposes of Processing, please refer to the relevant
sections of this Privacy Policy.
Sale of Your personal information
For Our
purposes, the word “sale” means any “selling, renting, releasing, disclosing,
disseminating, making available, transferring or otherwise communicating
orally, in writing or by electronic means, a consumer’s personal information by
the business to another business or a third party,
for monetary or other valuable consideration”.
This means
that, for example, a sale can happen whenever an application runs ads, or makes
statistical analyses on the traffic or views, or simply because it uses tools
such as social network plug-ins and the like.
Your right to opt out of the sale of personal information
You have
the right to opt out of the sale of Your personal information. This means that
whenever You request Us to stop selling Your data, We will abide by Your
request.
Such
requests can be made freely and at any time, without submitting any verifiable
request, simply by following the instructions below.
Instructions to opt-out of the sale of personal information
If You
would like to know more, or exercise Your right to opt out in regard to all the
sales carried out by this Platform, both online and offline, You can contact Us
for further information using the contact details provided at the beginning of
this document.
What are the purposes for which We use Your personal
information?
We may use
Your personal information to allow the operational functioning of this Platform
and features thereof (“business purposes”). In such cases, Your personal
information will be processed in a manner necessary and proportionate to the
business purpose for which it was collected, and strictly within the limits of
compatible operational purposes.
We may
also use Your personal information for other reasons such as for commercial
purposes (as indicated within the section “Detailed information on the
Processing of Personal Data” within this document), as well as for complying
with the law and defending Our rights before the competent authorities where
Our rights and interests are threatened, or We suffer an actual damage.
We will
not use Your personal information for different, unrelated or incompatible
purposes without notifying You.
Your privacy rights and how to exercise them
The right to know and to portability
You have
the right to request that We disclose to You:
- the categories and sources of
the personal information that We collect about You, the purposes for which
We use Your information and with whom such information is shared;
- in case of sale of personal
information or disclosure for a business purpose, two separate lists where
We disclose:
- for sales, the personal
information categories purchased by each category of recipient; and
- for disclosures for a
business purpose, the personal information categories obtained by each
category of recipient.
The
disclosure described above will be limited to the personal information
collected or used over the past 12 months.
If We
deliver our response electronically, the information enclosed will be
“portable”, i.e. delivered in an easily usable format to enable You
to transmit the information to another entity without hindrance, provided that
this is technically feasible.
The right to request the deletion of Your personal information
You have
the right to request that We delete any of Your personal information, subject
to exceptions set forth by the law (such as, including but not limited to,
where the information is used to identify and repair errors on this Platform,
to detect security incidents and protect against fraudulent or illegal
activities, to exercise certain rights etc.).
If no
legal exception applies, as a result of exercising Your right, We will delete
your personal information and direct any of Our service providers to do so.
How to exercise Your rights
To
exercise the rights described above, You need to submit Your verifiable request
to Us by contacting Us via the contact details provided at the beginning of
this document.
For Us to
respond to Your request, it is necessary that We know who You are. Therefore,
You can only exercise the above rights by making a verifiable request which
must:
- provide sufficient information
that allows Us to reasonably verify You are the person about whom We
collected personal information or an authorised representative;
- describe Your request with
sufficient detail that allows Us to properly understand, evaluate, and
respond to it.
We will
not respond to any request if We are unable to verify Your identity and
therefore confirm the personal information in Our possession actually relates
to You.
If You are
an adult, You can make a verifiable request on behalf of a minor under Your
parental authority.
You can
submit a maximum number of 2 requests over a period of 12 months.
How and when We are expected to handle Your request
We will
confirm receipt of Your verifiable request within 10 days and provide
information about how We will process Your request.
We will
respond to Your request within 45 days of its receipt. Should We need more
time, We will explain to You the reasons why, and how much more time We need.
In this regard, please note that We may take up to 90 days to fulfil Your
request.
Our
disclosure(s) will cover the preceding 12 month period.
Should We
deny Your request, We will explain to You the reasons behind Our denial.
We do not
charge a fee to process or respond to Your verifiable request unless such
request is manifestly unfounded or excessive. In such cases, We may charge a
reasonable fee, or refuse to act on the request. In either case, We will
communicate Our choices and explain the reasons behind it.