1. Who is responsible for your data
[Snaffle Legal Entity Ltd] is the data controller for personal information you give us. Our registered office is [address] and our contact for privacy questions is privacy@snaffle.win. We are registered with the UK Information Commissioner's Office (ICO), registration number [•].
2. What we collect
- Account details: name, email, date of birth, postal address, phone (optional).
- Identity checks: information used to verify your age, identity and address (e.g. results from our ID verification provider).
- Payment details: card and billing information — collected and stored by our payment provider [Payment provider], not by Snaffle.
- Entry and prize history: which Draws you entered, how many entries you had, whether you won.
- Communications: emails, in-app messages and support requests you send us.
- Technical data: IP address, device and browser information, and cookie identifiers when you use the site.
3. Why we use it and the legal basis
| Purpose | Legal basis (UK GDPR) |
|---|---|
| Running your account and entering you into Draws | Performance of a contract with you |
| Age, identity and anti-fraud checks; complying with gambling and AML law | Legal obligation; legitimate interest in preventing fraud |
| Notifying and paying winners | Performance of a contract; legal obligation |
| Service emails (billing, entry confirmations, security) | Performance of a contract |
| Marketing emails about future Draws | Consent — you can unsubscribe at any time |
| Analytics and improving the site | Legitimate interest, balanced against your privacy |
4. Who we share it with
We share personal information only with providers who help us run Snaffle, under contracts that require them to protect your data:
- Our hosting and backend provider ([Cloud/Supabase]).
- Our payment provider ([Payment provider]).
- Our ID and age verification provider ([ID provider]).
- Our email delivery provider ([Email provider]).
- Our independent scrutineer ([Scrutineer]).
- Regulators, law enforcement or courts where we are legally required to.
We do not sell your personal information and we do not share it for anyone else's marketing.
5. International transfers
Some of our providers process data outside the UK. Where that happens, we rely on UK adequacy regulations or on the ICO's International Data Transfer Agreement / EU Standard Contractual Clauses to protect your information.
6. How long we keep it
- Account and Draw records: for as long as your account is open and for [6] years after closure, to meet gambling, tax and audit obligations.
- Marketing preferences: until you opt out.
- Support emails: [24] months.
- Server logs and analytics: up to [13] months.
7. Your rights
Under UK GDPR you can ask us to:
- give you a copy of the personal information we hold about you;
- correct information that is wrong;
- delete your information, where the law allows;
- restrict or object to how we use it;
- port your information to another provider; and
- withdraw consent for marketing at any time.
Email privacy@snaffle.win to exercise any of these rights. We will respond within one month.
8. Cookies
We use strictly necessary cookies to keep you signed in, remember your preferences and keep the site secure. With your consent we also use analytics cookies to understand how the site is used. You can change your cookie choices at any time in the cookie banner.
9. Complaints
If you're not happy with how we handle your data, please email us first at privacy@snaffle.win. You can also complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
10. Changes to this notice
We may update this notice. Material changes will be emailed to registered users. Please check back periodically for the latest version.
See also: Terms of Use, Subscription Terms, Official Rules.
Last updated: 7 July 2026. Version 0.1 (draft).