Privacy Policy

1. Introduction

Celtic Luck Ltd (trading as FRC Competitions) ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we look after your personal data when you visit our website and tells you about your privacy rights and how the law protects you.

We are registered with the Information Commissioner's Office (ICO) as a data controller.

2. Who We Are

Data Controller: Celtic Luck Ltd (trading as FRC Competitions) Company Number: 16321487 Registered Office: Celtic Luck Ltd, Castle House, Castle Street, Guildford, Surrey, GU1 3UW Email: support@celticluck.com

3. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data — first name, last name, username or similar identifier
• Contact Data — postal address, email address, telephone number
• Financial Data — payment card details (processed securely by our payment provider; we do not store full card numbers)
• Transaction Data — details about payments to us and other details of products and services you have purchased from us, including competition entries
• Technical Data — internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website
• Profile Data — your username and password, competition entries made by you, your preferences, feedback and survey responses
• Usage Data — information about how you use our website and services
• Marketing and Communications Data — your preferences in receiving marketing from us and your communication preferences

4. How We Collect Your Personal Data

We use different methods to collect data from and about you, including:

• Direct interactions — you may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create an account, enter a competition, make a payment, request marketing communications, or give us feedback.
• Automated technologies — as you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties — we may receive personal data about you from analytics providers, payment processors, and from social media platforms if you choose to engage with us through those channels.

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract — where we need to perform the contract we are about to enter into or have entered into with you (including processing your competition entries and notifying winners).
• Legitimate interests — where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal obligation — where we need to comply with a legal obligation.
• Consent — where you have given us explicit consent to process your data for a specific purpose (such as sending you marketing emails). You may withdraw consent at any time by contacting us or using the unsubscribe link in any marketing email.

Purposes for which we use your data include:

• Registering you as a new customer / member
• Processing and delivering competition entries, including managing payments and collecting prize fulfilment details
• Managing our relationship with you, including notifying you about changes to our terms or privacy policy
• Administering and protecting our business and website
• Delivering relevant website content to you and measuring the effectiveness of our services
• Making suggestions and recommendations to you about competitions or services that may be of interest to you (only where you have opted in to marketing communications)

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below:

• Service providers acting as processors who provide IT, payment processing, and system administration services
• Professional advisers including lawyers, bankers, auditors and insurers
• Regulators and other authorities such as the ICO or the Advertising Standards Authority, where required by law or where we are legally obliged to report certain activities
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

7. International Transfers

Some of our external third parties are based outside the UK. Where we transfer your personal data outside the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: use of Standard Contractual Clauses approved for use in the UK, or transfer to countries that have been deemed to provide an adequate level of protection for personal data.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data — see your legal rights below.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (commonly known as a "data subject access request")
• Request correction of the personal data that we hold about you
• Request erasure of your personal data
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party)
• Request restriction of processing of your personal data
• Request transfer of your personal data to you or to a third party
• Withdraw consent at any time where we are relying on consent to process your personal data

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your 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 try to respond to all legitimate requests within one month.

11. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies — required for the operation of our website, including enabling you to log in to secure areas
• Analytical/performance cookies — allow us to recognise and count the number of visitors and to see how visitors move around our website
• Functionality cookies — used to recognise you when you return to our website

12. Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

13. How to Contact Us and Make a Complaint

To exercise any of your rights, or if you have any questions about this privacy policy, please contact us:

Email: support@celticluck.com Post: Celtic Luck Ltd, Castle House, Castle Street, Guildford, Surrey, GU1 3UW

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

14. Changes to This Privacy Policy

We keep our privacy policy under regular review. This version was last updated on 23 February 2026. Historic versions can be obtained by contacting us.

Version dated: 23 February 2026.