Privacy Policy

This Privacy Policy explains how SnapWin ("we", "us", "our") collects, uses and protects your personal data when you use the SnapWin mobile application and any related websites or services (the "Service").

We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the General Data Protection Regulation ("GDPR") and relevant Irish legislation.

1. Data controller

The data controller responsible for your personal data in connection with SnapWin is the operator of the SnapWin platform. Contact details will be provided in-app and on the website for any privacy queries.

2. Information we collect

Depending on how you use the Service, we may collect:

• Account information (such as name, email address, phone number, county or region).
• Usage information (such as app interactions, device information, IP address and general location derived from your IP).
• Payment-related information (handled primarily by our payment provider; we receive limited information about transaction status and amounts).
• Support communications and any information you provide when you contact us with queries or issues.

3. How we use your information

We use your personal data for the following purposes:

• To create and manage your account.
• To process entries, payments and draws for raffles.
• To provide you with updates about your entries, results and account activity (for example, via in-app notifications or email).
• To improve and secure the Service, including analytics, fraud prevention and troubleshooting.
• To comply with legal and regulatory obligations, including age-verification, anti-money laundering checks where applicable and record-keeping requirements.

4. Legal bases for processing

We process your personal data on the following legal bases:

• Performance of a contract: to provide the Service, process your entries and manage your account.
• Legal obligation: to comply with applicable laws, regulatory requirements and licence conditions.
• Legitimate interests: to improve the Service, prevent abuse and protect our users, provided that these interests are not overridden by your rights.
• Consent: where required for specific optional features (for example, certain types of marketing communications).

5. Sharing your information

We may share your personal data with:

• Payment providers (such as Stripe) to process transactions.
• Cloud hosting, analytics and security service providers who help us operate and improve the Service.
• Regulators or law enforcement agencies where required by law or in response to a valid legal request.

We do not sell your personal data.

6. International transfers

Where we transfer your data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, such as standard contractual clauses or equivalent mechanisms that comply with data protection laws.

7. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, including any legal, accounting or reporting requirements. After this period, data may be anonymised or securely deleted.

8. Your rights

Under data protection law, you may have the following rights:

• the right to access your personal data;
• the right to rectify inaccurate or incomplete data;
• the right to request erasure of your data in certain circumstances;
• the right to restrict or object to processing in certain cases;
• the right to data portability in some situations;
• the right to withdraw consent where processing is based on consent.

You can exercise these rights by contacting us using the details provided in the app or on the website. You also have the right to lodge a complaint with the Irish Data Protection Commission if you are unhappy with how we handle your data.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or misuse. However, no system is completely secure, and we cannot guarantee absolute security of your information.

10. Changes to this policy

We may update this Privacy Policy from time to time. Where changes are material, we will take reasonable steps to inform you. Your continued use of the Service after any changes take effect will constitute your acceptance of the updated policy.