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📄 Legal

Privacy Policy

🗓️ Last updated: 3 March 2026 🇬🇧 UK Law Compliant 🔒 GDPR Compliant
📑 Contents

    Introduction

    Welcome to the X Comps privacy policy. We value your privacy and are dedicated to safeguarding your personal information. This policy explains how we handle your personal data when you use our website, regardless of your location. It also outlines your privacy rights and the legal protections available to you.

    Key Information and Our Identity

    What This Policy Covers

    This policy describes how X Comps gathers and processes your personal data through your interactions with our website. This includes any information you share when creating an account or participating in our competitions.

    Our website is designed for adults, and we do not intentionally gather data from children. We carry out age verification checks to comply with legal requirements, and entrants or winners may need to provide photo identification to confirm their identity, age, and address.

    Please read this policy alongside any other privacy notices we may issue on specific occasions. This document is supplementary and does not replace those notices.

    Data Controller

    X Comps acts as the controller responsible for your personal data (referred to as “we,” “us,” or “our” throughout this policy).

    We have designated a Data Protection Officer (DPO) to oversee matters related to this policy. For any questions — including requests to exercise your legal rights — please reach out to the DPO using the details below.

    How to Reach Us

    • Legal entity: X Comps Ltd
    • Email: team@xcomps.co
    • Post: Unit 7, 17 McFarlane Street, Paisley, PA3 1RY

    You may also lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk at any time. We would appreciate the opportunity to address your concerns directly before you contact the ICO.

    Policy Updates and Your Responsibilities

    We review this policy periodically. Please ensure the personal data you provide us remains accurate and up to date throughout our relationship.

    External Links

    Our website may contain links to third-party sites, plug-ins, and applications. We have no control over these external sites and bear no responsibility for their privacy practices. We recommend reading the privacy policy of every website you visit after leaving ours.


    Information We Collect

    Personal data means any information that can identify a living individual. It does not cover anonymised data. We may gather, use, store, and transfer the following categories of data:

    • Identity Data — first name, surname, date of birth, username, and title.
    • Contact Data — billing address, delivery address, and email address.
    • Financial Data — bank account and payment card information.
    • Transaction Data — payment history and details of competitions you have entered.
    • Technical Data — IP address, login credentials, browser type and version, time zone, location, browser plug-in details, operating system, and device information.
    • Profile Data — username, password, competition entries, interests, preferences, feedback, and survey responses.
    • Usage Data — information about how you navigate our website and interact with our competitions.
    • Marketing and Communications Data — your preferences for receiving marketing from us or third parties, and your communication settings.

    We may also compile Aggregated Data (such as statistical or demographic information) for analytical purposes. This data does not directly identify you and is not treated as personal data unless combined with other information that could reveal your identity.

    We do not collect Special Category Data (covering race, ethnicity, religion, sexual orientation, political views, trade union membership, health, or biometric information), nor do we gather data relating to criminal convictions.

    When You Do Not Provide Data

    If we are legally or contractually required to collect certain personal data and you do not supply it, we may be unable to fulfil our obligations — for instance, delivering goods or services. We will inform you if this situation arises.


    How We Gather Your Data

    We collect information through several methods:

    • Direct interactions — when you fill in forms or correspond with us by post, phone, email, or other means. This covers account creation, marketing sign-ups, competition entries, and any feedback you provide.
    • Automated technologies — as you browse our website, we automatically gather Technical Data about your device, browsing behaviour, and usage patterns via cookies and similar tools (see the Cookies section below).
    • Third-party and public sources — we receive data from external parties, including analytics providers (e.g., Google Analytics), advertising networks (e.g., Facebook), search information providers, and technical, payment, and delivery service providers.

    How We Use Your Data

    We process your personal data only where the law permits. The most common grounds include:

    • Fulfilling our obligations when you enter a competition.
    • Pursuing our legitimate interests (or those of a third party), provided your rights do not take precedence.
    • Complying with legal obligations.
    • Conducting identity verification for winners, including Know Your Customer (KYC) checks under Regulation 28 of the Money Laundering Regulations 2017.
    • Monitoring for fraud and filing Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) where required under Regulation 18 of the Money Laundering Regulations 2017.

    We generally do not rely on consent as our processing basis, except for third-party direct marketing sent via email or text. You may withdraw marketing consent at any time by contacting us.

    When you supply your contact details (including mobile number), we store this information to deliver email, SMS, and RCS communications covering service updates, competition notifications, and promotional messages in line with your consent preferences. You can opt out at any time by replying STOP or contacting us directly.

    Specific Processing Purposes

    Purpose Data Used Legal Basis
    Registering you as a customer Identity, Contact Contractual performance
    Processing competition entries and managing payments Identity, Contact, Financial, Transaction, Marketing & Communications Contractual performance; legitimate interest (debt recovery)
    Managing our relationship (e.g., notifying you of policy changes, requesting reviews) Identity, Contact, Profile, Marketing & Communications Contractual performance; legal obligation; legitimate interest (record-keeping, customer research)
    Enabling participation in competitions or surveys Identity, Contact, Profile, Usage, Marketing & Communications Contractual performance; legitimate interest (customer research, business growth)
    Administering and securing our business and website Identity, Contact, Technical Legitimate interest (IT services, network security, fraud prevention); legal obligation
    Delivering relevant content and advertising Identity, Contact, Profile, Usage, Marketing & Communications, Technical Legitimate interest (customer research, marketing strategy)
    Analysing data to improve our website and services Technical, Usage Legitimate interest (audience insight, business development)
    Recommending competitions of interest Identity, Contact, Technical, Usage, Profile, Marketing & Communications Legitimate interest (product development, business growth)

    Marketing

    Promotional Communications

    We may use your Identity, Contact, Technical, Usage, and Profile Data to identify competitions and services that may interest you. You will receive marketing if you have requested information or entered competitions and have not opted out.

    Third-Party Marketing

    We will obtain your explicit consent before sharing your data with any third party for their marketing purposes.

    How to Opt Out

    Contact us at any time to stop receiving marketing communications from us or from third parties.


    Cookies

    You can configure your browser to block all or selected cookies, or to notify you when cookies are set. Disabling cookies may affect the functionality of certain parts of our website.

    Cookies are small data files stored on your browser or device. We use them to distinguish you from other visitors, improve your browsing experience, and enhance our site. We employ the following types:

    • Strictly necessary cookies — essential for basic website operations such as logging in and using the shopping cart.
    • Analytical/performance cookies — help us understand visitor numbers and navigation patterns so we can improve site usability.
    • Functionality cookies — recognise returning visitors, enabling personalised content and remembered preferences.
    • Targeting cookies — track your browsing on our site to deliver more relevant advertising, potentially shared with third parties for the same purpose.

    Cookies in Use

    Cookie Name Purpose
    woocommerce_cart_hash Detects changes to cart contents
    woocommerce_items_in_cart Detects changes to cart contents
    wp_woocommerce_session_ Stores a unique code linking each customer to their cart data
    woocommerce_recently_viewed Supports the Recently Viewed Products feature
    store_notice[notice id] Lets customers dismiss the Store Notice
    wordpress_[hash] WordPress account management
    wordpress_logged_in_[hash] WordPress account management
    wordpress_test_cookie WordPress account management
    wp-settings-{time}-[UID] WordPress account management
    _ga Distinguishes users (Google Analytics, 2-year duration)
    _gid Distinguishes users (Google Analytics)
    _gat Manages request frequency (Google Analytics)
    AMP_TOKEN Retrieves Client IDs from the AMP Client ID service
    gac Stores campaign data; read by Google Ads conversion tags if Analytics and Ads accounts are linked
    Facebook Pixel Tracks Facebook ad conversions

    Cookie data is not shared with third parties. You can block cookies through your browser settings, though this may limit access to parts of our site. All non-essential cookies expire after 90 days.


    Change of Purpose

    We use your data only for the purposes for which it was originally collected, unless a new purpose is compatible with the original one. We will notify you and explain our legal basis if we need to process your data for an unrelated purpose. In certain cases, we may process data without your knowledge or consent where permitted or required by law.


    Sharing Your Data

    We may disclose your personal data to the following external parties:

    • Service providers (UK-based) who handle payment processing, IT, and system administration.
    • Professional advisers (UK-based), including lawyers, bankers, auditors, and insurers providing consultancy, legal, financial, and insurance services.
    • Regulatory authorities, including HMRC and other bodies that require reporting of processing activities in specific circumstances.

    All third parties are required to protect your data and process it solely in accordance with our instructions.


    International Transfers

    We do not transfer your personal data outside the United Kingdom. Contact us if you require further details on any data transfer mechanisms.


    Data Security

    We maintain appropriate security measures to guard against accidental loss, unauthorised access, alteration, or disclosure of your data. Access is restricted to employees, agents, contractors, and other parties with a legitimate business need, all of whom are bound by confidentiality obligations.

    We have procedures in place to handle suspected data breaches and will notify you and relevant regulators where legally required.


    Data Retention

    We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, tax, and reporting obligations. Retention periods are determined by considering the nature and sensitivity of the data, the risk of harm from unauthorised use, the processing purposes, and applicable legal requirements.

    We are legally required to keep basic customer information (Contact, Identity, Financial, and Transaction Data) for six years after the customer relationship ends, for tax purposes.

    In certain cases, you may request deletion of your data (see Your Rights below). We may also anonymise your data for research or statistical use, in which case it may be retained indefinitely.


    Your Legal Rights

    Under data protection law, you have the right to:

    • Access your personal data and receive a copy.
    • Correct inaccurate or incomplete data.
    • Erase your data where there is no valid reason for continued processing.
    • Object to processing based on legitimate interests or for direct marketing.
    • Restrict processing in specific circumstances (e.g., while data accuracy is verified).
    • Transfer your data in a structured, machine-readable format to yourself or a third party.
    • Withdraw consent at any time where consent is the basis for processing (without affecting prior lawful processing).

    To exercise any of these rights, please contact us.

    Fees

    Access to your data and exercise of your rights is normally free. We may charge a reasonable fee for requests that are clearly unfounded, repetitive, or excessive, or we may decline such requests.

    Identity Verification

    We may request information to confirm your identity before fulfilling a rights request. This is a security measure to prevent disclosure to unauthorised persons.

    Response Times

    We aim to respond to all valid requests within one month. Complex or multiple requests may take longer, and we will keep you informed of any delays.

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