INTRODUCTION

Possible Wins is an associated brand of, and operated by, ART OF THE POSSIBLE INFLUENCE LTD (registered in England & Wales, company number 14792504).

ART OF THE POSSIBLE INFLUENCE LTD respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website at https://possiblewins.co.uk, regardless of where you access it from. It also explains your privacy rights and how the law protects you.

CONTENTS

1. Important Information and Who We Are
2. The Data We Collect About You
3. How and Why We Use Your Personal Data
4. Cookies
5. Disclosures of Your Personal Data to Third Parties
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Complaints
11. Changes to This Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of This Privacy Policy

This Privacy Policy aims to give you information on how ART OF THE POSSIBLE INFLUENCE LTD collects and processes your personal data when you use our website, including data you may provide when:

• creating an account
• entering a Prize Draw
• signing up for newsletters or marketing
• communicating with us
• redeeming or claiming a Prize

The Site is not intended for children, and we do not knowingly collect data relating to anyone under 18.

This Privacy Policy supplements other notices or fair processing information we may provide at specific times and is not intended to override them.

Controller

ART OF THE POSSIBLE INFLUENCE LTD (“we”, “us”, “our”) is the data controller responsible for your personal data.

We have appointed a Data Protection Officer (DPO) who manages questions relating to this Privacy Policy.

Contact Details

Data Protection Officer
ART OF THE POSSIBLE INFLUENCE LTD
Building 7, Floor 5
566 Chiswick High Rd.
Chiswick
London
W4 5YG

Email: hello@aotp.london

If you have any questions about this Privacy Policy or wish to exercise your legal rights, please contact our DPO.

Your Right to Complain

You may lodge a complaint at any time with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

However, we would appreciate the opportunity to resolve your concerns before you approach the ICO—please contact us first.

Your Duty to Inform Us of Changes

It is essential that the personal data we hold about you is accurate and current. Please update your Account or notify us if your personal data changes during your relationship with us.

Third-Party Links

Our website may include links to third-party websites, plug-ins, or applications. Clicking on those links may allow third parties to collect or share your personal data.

We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the Privacy Policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data means any information that can identify an individual.

We may collect, use, store and transfer the following categories of personal data:

Personal & Contact Information

• Full name
• Email address
• Phone number
• Postal address
• Date of birth
• Account details

Communications & Support Interactions

• Emails, messages or chats with our customer support team
• Voice recordings from telephone support
• Social media interactions
• Feedback and support queries

Identity Verification Information

Required when legally necessary or when claiming Prizes:

• Copy of passport
• Driving licence
• Other identity or age-verification documents

Transaction & Prize Draw Data

• Prize Draws you have entered
• Payment information (processed securely by third-party providers)
• Prize outcomes and prize fulfilment information
• Subscription details
  We do not store your full payment card details.

Media, Marketing & Consent-Based Data

• Images, footage, audio or statements you consent to provide
• Data used in advertising or winner content (with consent)

Technical Data

• Internet protocol (IP) address
• Device ID
• Browser type and version
• Time zone settings
• Operating system
• Login data
• Website usage patterns

Website Interaction Data

• Pages viewed
• Referring website
• On-site behaviour
• Cookies and tracking technologies

Data From Third Parties

Including:

• Social media (if you interact with us)
• Advertising platforms
• Identity and verification providers
• Payment processors

We Do NOT Collect Special Category Data

We do not intentionally collect data relating to:

• race or ethnicity
• religious or philosophical beliefs
• political opinions
• sexual life or orientation
• health information
• genetic/biometric data
• criminal convictions

If You Fail to Provide Personal Data

If we must collect personal data by law or under a contract and you fail to provide it, we may not be able to provide services or fulfil Prize Draw obligations. We will notify you if this is the case.

3. HOW AND WHY WE USE YOUR PERSONAL DATA

We only process your personal data when legally permitted to do so.

We rely on the following lawful grounds:

• Performance of a contract
• Compliance with legal obligations
• Legitimate interests
• Consent (only for specific uses like marketing or publicity)

Below is a clear explanation of what we use your data for and why:

1. To register you as a new customer

Legal basis: Performance of a contract

1. To determine Prize Draw eligibility (age, UK residence)

May include automated checks and ID verification.
Legal basis: Legal obligation

1. To verify your identity when required by law

Legal basis: Legal obligation

1. To provide our Prize Draw services

Including processing Entries, subscriptions and payments.
Legal basis: Performance of a contract

1. To contact winners and fulfil Prizes

Legal basis: Performance of a contract

1. To manage our relationship with you

Including support interactions.
Legal basis:

• Contract performance
• Legal obligation
• Legitimate interests

1. To conduct surveys or request feedback

Legal basis: Legitimate interests

1. To show you relevant content or marketing

Across our website, email, and social media.
Legal basis:

• Legitimate interests
• Consent (for electronic marketing)

1. To measure marketing effectiveness

Legal basis: Legitimate interests

1. To prevent fraud or misuse

Legal basis:

• Legal obligation
• Legitimate interests

1. To respond to complaints or customer service requests

Legal basis:

• Legal obligation
• Legitimate interests

1. To use aggregated data for analysis and reporting

Aggregated data is not personal unless combined with identifiable information.
Legal basis: Legitimate interests

Marketing Communications

You may choose whether to receive marketing messages when signing up or entering a Prize Draw.

Winner Announcements

If you win, we may publish your:

• first name
• first initial of surname
• county

This is for transparency and legitimacy.

You may object at any time by contacting hello@aotp.london – this will not affect your eligibility or the Prize.

Opting Out

You may stop marketing communications at any time by:

• clicking “unsubscribe” in marketing emails
• updating your Account preferences
• contacting us at hello@aotp.london

Marketing Partners and Social Platforms

We may share limited data with:

• advertising partners (e.g. Meta, Google, Snapchat)
• email marketing platforms
• affiliate platforms
• social media custom audience tools

This allows us to:

• show you relevant ads
• exclude you from irrelevant ads
• measure advertising effectiveness

A full list of partners is available by contacting hello@aotp.london.

Change of Purpose

We will only use your personal data for the purposes described in this policy unless we reasonably consider another purpose compatible.

If we must use your data for something unrelated, we will notify you and explain the legal basis.

4. COOKIES

We use cookies and similar technologies to improve user experience, secure our platform, and deliver relevant advertising.

You may block cookies via your browser settings, but some functionality may not work.

We use:

Strictly Necessary Cookies

Essential for account access and site security.

Performance Cookies

To analyse user behaviour and improve performance.

Functionality Cookies

To remember preferences, login state, page variants, etc.

Advertising Cookies and Pixels

Used by partners to:

• deliver relevant ads
• cap ad frequency
• measure campaign performance
• build custom audiences

Typical Partners Include:

• Google Analytics / Tag Manager
• Google Ads
• Facebook
• Snapchat
• Email automation platforms
• Hotjar
• Trustpilot
• Affiliate networks (Awin, Affiliate Future)

A full cookie list can be provided on request.

5. DISCLOSURES OF YOUR PERSONAL DATA TO THIRD PARTIES

We share personal data only when necessary. Examples include:

Operational & Service Providers

• Prize fulfilment partners
• Banks & payment processors
• IT and software providers
• Customer service tools
• Hosting services

Marketing & Advertising

• Email service providers
• Marketing agencies
• Digital analytics platforms
• Social media platforms for targeted advertising

Professional Services

• Lawyers
• Auditors
• Insurers
• Consultants

Regulatory & Compliance

• Police and law enforcement
• Regulatory bodies
• Fraud prevention agencies
• Dispute resolution bodies

All third party providers must:

• protect your data
• act only on our instructions
• comply with the law

6. INTERNATIONAL TRANSFERS

We do not intentionally transfer your personal data outside the UK or EEA.

If this changes, we will update this Privacy Policy and ensure appropriate safeguards (e.g., UK Standard Contractual Clauses).

7. DATA SECURITY

We have implemented appropriate technical and organisational security measures to:

• prevent unauthorised access
• protect against accidental loss
• secure data transmission
• manage internal access

We notify you and the ICO of any legally notifiable breach.

8. DATA RETENTION

We retain your personal data only as long as reasonably necessary to:

• fulfil the purposes for which it was collected
• comply with legal, tax and regulatory obligations
• resolve disputes
• enforce our terms

Retention periods vary depending on the data type and purpose.

Verification When Exercising Rights

We may request proof of identity before fulfilling access or deletion requests to protect your data.

9. YOUR LEGAL RIGHTS

You have rights under data protection laws, including to:

✔ Request access

To your personal data.

✔ Request correction

Of inaccurate or incomplete data.

✔ Request erasure

Where no lawful reason remains for processing.

✔ Object to processing

Where we rely on legitimate interests or for direct marketing.

✔ Request restriction

In certain circumstances.

✔ Request transfer

Of your data in machine-readable format.

✔ Withdraw consent

Where processing is based on consent.

10. COMPLAINTS

You may contact the ICO:
https://ico.org.uk

However, please contact us first at hello@aotp.london and we will do our best to resolve your concern quickly.

11. CHANGES TO THIS PRIVACY POLICY

We review this Privacy Policy regularly. Updates will be posted on https://possiblewins.co.uk, and significant changes may be notified via email or on your next login.