Raffio
Raffio

Privacy Policy

Last updated: 08 October 2026

1. Introduction

1.1 This Privacy Policy gives you information about how Raffio Limited, a company registered in Scotland (Company Number SC879232) and having its registered office address at 9 Newton Place, Office 1, Glasgow, Scotland, G3 7PR (collectively referred to as "we", "us" or "our" in this privacy policy) collects and uses your personal data through your use of the Raffio platform (the “Platform”) including any data you may provide when you register with us and take part in a Draw.

1.2 This Platform is not intended for use by anyone under the age of 18, being the minimum age for participation under our Terms and Conditions, and we do not knowingly collect data relating to children. If we become aware that we have done so, we will delete the relevant data, save that we may retain a limited record (such as a declared date of birth and the fact of an attempted registration) for as long as reasonably necessary to enforce our under-18 restriction and to prevent repeat attempts to register.

1.3 By using our Platform, you acknowledge that you have read and understood this Privacy Policy.

1.4 This Privacy Policy should be read together with our Terms and Conditions, our Cookie Policy, our Refund Policy, our Shipping and Prize Fulfilment Policy, and our Complaints Policy. Capitalised terms used but not defined in this Privacy Policy have the same meaning given to them in our Terms and Conditions.

2. Who we are

2.1 We are the controller and responsible for your personal data.

3. The types of personal data we collect about you

3.1 Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • (a) Identity Data: includes full name, date of birth, gender, username, profile information and profile pictures;
  • (b) Contact Data: includes billing address, delivery address, email address and telephone numbers;
  • (c) Financial Data: includes payment amounts, payment status, payment history, bank account details for disbursements and payment card details (processed securely through our third-party payment provider and for the avoidance of doubt, we do not store raw card data);
  • (d) Transaction Data: includes details about payments to and from you and other details of Entries purchased and entered, completed transactions and Prizes won;
  • (e) Technical Data: includes 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, device ID and other technology on the devices you use to access this Platform;
  • (f) Profile Data: includes your username and password (we do not store your password), purchases or orders made by you, your interests, preferences and feedback. Where you are signed in as a Host Partner, this also includes your account identifier stored in your browser's local storage to prevent accidental duplicate listing submissions and to recover an unsaved listing draft;
  • (g) Usage Data: includes information about how you interact with and use our Platform, including your display theme and browse layout preferences, your recently viewed listings and category interactions, your recent search shortcuts, and your favourite listings, each of which is stored in your browser's local storage and used solely for that display or functionality purpose; and
  • (h) Marketing and Communication Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences including messages sent on the Platform and customer support enquiries and feedback.

3.2 We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Platform feature in order to analyse general trends in how users are interacting with our Platform to help improve the Platform and our service offering.

4. How is your personal data collected?

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

  • (a) Your interactions with us: you may give us your personal data by filling in online forms, by post (including where you submit a Free Postal Entry in accordance with our Terms and Conditions), or by corresponding with us by phone, email or otherwise. This includes (without limitation) personal data you provide when you:
  • (i) create an Account on our Platform;
  • (ii) request marketing to be sent to you;
  • (iii) enter a Draw; or
  • (iv) give us feedback or contact us.
  • (b) Automated technologies or interactions: as you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data using cookies, local storage, server logs and other similar technologies, including analytics and advertising technologies that only operate once you have given your consent through our cookie preference centre in the Platform’s footer. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • (c) Third parties or publicly available sources: we will receive personal data about you from various third parties including (without limitation) authentication providers, payment processors and age and verification providers (including for host-identity verification).
  • (d) The collection of Technical Data from advertising networks used by the Platform (currently Meta, but we may choose to use other similar networks in the future), as well as search information providers.
  • (e) The collection of Contact Data from providers of delivery services, including courier companies, for the delivery and fulfilment of Prizes.
  • (f) The collection of Technical Data by RANDOM.ORG, our independent third-party random draw service, for the purpose of conducting each Draw and posting limited data publicly to verify the Winner in accordance with clause 5.2.

5. How we use your personal data

5.1 The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • (a) Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • (b) Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • (c) Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • (d) Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

5.2 We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use

Type of data

Legal basis and retention period

To create and manage your Account

(a) Identity

(b) Contact

Performance of a contract with you: When you create an Account on the Platform, we process your name, email address, and other identity and contact details because this is necessary to set up and maintain your Account and to provide you with access to our services. Without this information, we would be unable to create your Account or fulfil our obligations to you as a participant on the Platform.

We will retain this data for a period of six years following the closure of your Account.

To process your Draw Entries, payments

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(h) Marketing and Communications

(a) Performance of a contract with you: When you purchase Entries into a Draw (including via the Free Postal Entry route), we process your identity, contact, and financial data because this is strictly necessary to complete the transaction, allocate your Entries, and, if you are a Winner, to arrange delivery of your Prize or payment of any cash prize. For example, we require your contact details to notify you if you win; and

(b) Necessary for our legitimate interests (to recover debts due to us): Where a payment is disputed, fails, or is subject to a chargeback, we may process your Transaction Data to pursue recovery of amounts lawfully owed to us. Our legitimate interest in protecting our revenue and the integrity of the Platform is proportionate and does not override your privacy right, as the processing relates solely to transactions you have initiated.

We will retain this data for a period of seven years following the relevant transaction.

To facilitate shipping and prize fulfilment

(a) Identity

(b) Contact

(d) Transaction

(a) Performance of a contract with you: Once you are confirmed as a Winner, we process your Identity, Contact and Transaction Data because this is necessary to verify your identity, age and eligibility, arrange delivery of your Prize with the relevant Host Partner or courier, and resolve any delivery issue (including a damaged, faulty, lost, or unclaimed Prize). For example, we share your delivery address and contact telephone number with the Host Partner or courier responsible for delivering your Prize, and we process this data to investigate a delivery dispute you raise with us; and

(b) Necessary for our legitimate interests (to prevent fraud and to resolve delivery disputes with our Host Partners and couriers): Where we share your data with a Host Partner or courier, or where we investigate a claim that a Prize was not delivered, was damaged, or does not match its description, we have a legitimate interest in coordinating with the relevant Host Partner or courier to verify what occurred and to protect the integrity of our Prize fulfilment process. Our interest in preventing fraudulent claims and resolving genuine delivery issues is proportionate and does not override your privacy rights, as the data shared is limited to what is necessary for delivery and dispute resolution.

We will retain this data for a period of 90 days after the Prize has been claimed, after which it will be anonymised or deleted, save where a longer retention period is required for legal purposes.

To manage our relationship with you, which will include:

(a) Notifying you about changes to our terms or privacy policy; and

(b) Dealing with your requests, complaints and queries.

(a) Identity

(b) Contact

(f) Profile

(h) Marketing and Communications

(a) Performance of a contract with you: Where we communicate with you about your Account, your Entries, or your Prize, this processing is necessary to fulfil our contractual obligations to you. For example, if you raise a refund request or query about a Draw result, we need to process your identity and contact data to respond;

(b) Necessary to comply with a legal obligation: We are required by law to notify you of material changes to our privacy policy under the UK GDPR. We may also be required to retain records of complaints and their outcomes under applicable consumer protection legislation and trading standards obligations; and

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you): We have a legitimate interest in maintaining accurate and up-to-date records about our users and in managing our relationship with them effectively. For example, where you inform us of a change of email address or contact details, we will update our records accordingly to ensure we can continue to communicate with you.

We will retain this data for the duration of your Account and for six years following the closure of your Account or the resolution of any complaint or query, whichever is the later.

To enable you to partake in a Draw or a Prize competition

(a) Identity

(b) Contact

(f) Profile

(g) Usage

(h) Marketing and Communications

(a) Performance of a contract with you: Processing your identity, contact, and profile data is necessary to validate your eligibility to enter a Draw, to allocate your Entries, to conduct the Draw fairly, and to notify and verify Winners. For example, we will use your date of birth to confirm you meet the minimum age requirement of 18 under our Terms and Conditions, and your contact details to notify you if you are selected as a Winner; and

(b) Necessary for our legitimate interests (to study how customers use our Platform to develop it and grow our business): We process Usage and Profile Data to understand how participants interact with our Draws and Platform features. For example, we may analyse which Draw formats generate the most engagement or which Prize categories attract the most Entries, in order to improve our Platform offering and grow our business. Our interest in improving and developing our services is proportionate and does not override your privacy rights, as the data is used to enhance the experience of all participants.

We will retain this data for the duration of your Account and for two years following the date of the relevant Draw, after which it will be anonymised or deleted, save where a longer retention period is required for legal purposes.

Where the user enters the Draw using the Free Postal Entry, we will retain this data for one year following the date of the relevant Draw, after which it will be anonymised or deleted, save where a longer retention period is required for legal purposes.

To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(e) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise): We process Technical and Identity Data to keep our Platform operational, secure, and reliable. For example, we use server log data and IP addresses to diagnose and resolve technical faults, to detect and prevent fraudulent or unauthorised access to the Platform, and to carry out routine maintenance and testing. We may also process this data in the event of a business reorganisation or restructuring where it is necessary to transfer operational data to a successor entity; and

(b) Necessary to comply with a legal obligation: We are required by law to implement appropriate technical and organisational security measures under Article 32 of the UK GDPR, and to report certain personal data breaches to the Information Commissioner's Office (ICO) within 72 hours. Processing Technical Data is necessary to enable us to meet these obligations.

We will retain this data for 13 months from the date of collection, after which it will be deleted or anonymised.

To deliver relevant Platform content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(e) Technical

(f) Profile

(g) Usage

(h) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our Platform, to develop them, to grow our business and to inform our marketing strategy): We process your Profile, Usage, and Technical Data to tailor the content and advertisements displayed to you on our Platform and, currently through Meta's advertising network (Meta Pixel), on third-party advertising networks. For example, we may use your browsing history on our Platform to display Draws that are relevant to your stated interests or previous Entry history, or to measure how many users clicked on a particular advertisement and subsequently purchased Entries. Our interest in delivering relevant and effective advertising is proportionate, and we implement safeguards such as pseudonymisation and data minimisation to reduce the privacy impact on you.

Where this processing involves the use of cookies, local storage or similar tracking technologies, it is carried out subject to your cookie preferences (currently a single combined analytics and advertising choice) as set out in our Cookie Policy. Where applicable law requires your consent for this processing (for example, under the Privacy and Electronic Communications Regulations 2003), we will only carry it out where you have provided your consent.

We will retain this data for 13 months from the date of collection, after which it will be deleted or anonymised.

To use data analytics to improve our Platform, Platform functionality and user experience, customer relationships and experiences, develop new features and services, and to measure the effectiveness of our communications and marketing

(e) Technical

(g) Usage

Necessary for our legitimate interests (to define types of customers for our Platform, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy): We use Technical and Usage Data, collected through consent-gated tools currently including PostHog (product analytics), Vercel Web Analytics (anonymous page-view analytics) and Sentry Session Replay (diagnostic session replay), to carry out analytics activities that help us understand how our Platform is used and where improvements can be made. For example, we may analyse page load times and navigation patterns to identify and resolve usability issues, or use aggregated data about Entry volumes and drop-off rates to inform the development of new Platform features. Where possible, we carry out this analytics processing using aggregated or anonymised data so that individual users are not identifiable. Where personal data is used, we apply appropriate safeguards including pseudonymisation.

We will retain this data for 13 months from the date of collection, after which it will be deleted or anonymised.

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data

(a) Identity

(b) Contact

(e) Technical

(g) Usage

(f) Profile

(h) Marketing and Communications

Necessary for our legitimate interests (to carry out direct marketing, develop our Platform and grow our business): Where we rely on legitimate interests for direct marketing, we process your Identity, Contact, and Profile Data to send you communications about our Draws that we consider relevant to you based on your history with us. For example, if you have previously entered Draws for a particular Prize category, we may contact you when a similar Draw is launched. We have assessed that our interest in promoting our services is not overridden by your privacy rights, as you have an existing relationship with us, the marketing relates to our own similar services, and you are provided with a clear and easy means to opt out at any time.

We will retain your marketing preferences and associated data for as long as you maintain an Account with us, or until you withdraw your consent or object to this processing, whichever is the earlier. Following opt-out, we will retain a record of your preference to ensure we do not contact you again.

To carry out market research through your voluntary participation in surveys and/or user feedback

Necessary for our legitimate interests (to study how customers use our Platform and to help us improve and develop our Platform): Where you voluntarily participate in surveys or feedback exercises, we process the responses you provide, together with limited Identity and Contact Data, to analyse user satisfaction and to identify areas for improvement in our Platform and services. For example, we may ask you to rate your experience of a particular Draw format or to suggest new Prize categories you would like to see. Participation in surveys is entirely voluntary, and you will not be disadvantaged in any way if you choose not to participate. Our interest in improving our services through customer feedback is proportionate and the processing involves only data that you have chosen to provide to us.

We will retain survey response data in identifiable form for a period of two years from the date of collection, after which it will be anonymised or deleted. Anonymised and aggregated survey data may be retained indefinitely for analytical and business development purposes.

To publish limited information about the Winner of a major Prize on the Platform's results pages, for competition transparency and integrity purposes

(a) Identity

(d) Transaction

Necessary for our legitimate interests (to demonstrate the integrity and transparency of our Draws, to comply with applicable advertising and promotions standards, and to provide assurance to participants that Prizes are genuinely awarded): We publish limited Identity Data (normally limited to the Winner's surname and county or region) together with the winning ticket number and Draw-verification evidence, once a Winner's claim has been confirmed. We do not publish a Winner's first name, address, email address, telephone number, Account identifiers, payment information, or the content of their Prize claim. We consider this processing proportionate because it is limited to the minimum information necessary to demonstrate a genuine Winner and Draw outcome, and because Winners are told about this processing at or before entry and may object to publication or request reduced disclosure at any time, as further described in clause 5.9 below and in our Terms and Conditions.

We will retain this data for two years, following the date of the relevant Draw, after which it will be anonymised or deleted, save where a longer retention period is required for legal purposes.

5.3 We will only send you direct marketing communications where we have a valid legal basis to do so, as set out in the table at clause 5.2.

5.4 We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which Draws may be of interest to you so that we can then send you relevant marketing communications.

5.5 We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

5.6 You can ask us to stop sending you marketing communications at any time by opting out in the Account settings on the Platform, by following the opt-out links within any marketing communication sent to you or by contacting us using the details in clause 11.

5.7 If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to transaction confirmations, details of Prizes that you have won, for updates to our Terms and Conditions and checking that your contact details are correct.

5.8 For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy here.

5.9 Where you are the Winner of a Draw, we will tell you at or before the time of entry that limited information about you may be published on the Platform's results pages in accordance with the table above. You may object to this publication, or ask us to publish less (for example, your county or region only, or your surname only), at any time, whether before entering, after entering, or after a result has been published, by contacting us using the details in clause 11. Exercising this choice does not affect your Entry, your chance of winning, your Prize, or your other rights under this Privacy Policy, and your objection or request is not itself made public. Further detail on how this operates is set out in our Terms and Conditions.

6. Disclosures of your personal data

6.1 We may share your personal data where necessary with the parties set out below for the purposes set out in the table set out in clause 5 including (without limitation):

  • (a) payment processors: to facilitate secure payments, process transactions and Prize disbursements;
  • (b) identification providers: to facilitate identification or age verification of users;
  • (c) IT and platform service providers: including cloud hosting, analytics, customer support, and communication with users;
  • (d) professional advisers: including lawyers, accountants, auditors and/or insurers;
  • (e) law enforcement and regulatory bodies: any body where required by law or we have a legitimate reason to disclose;
  • (f) postal handling: for processing Free Postal Entries and for distributing and fulfilling Prizes; and
  • (g) prospective purchasers: third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, subject to appropriate confidentiality provisions. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

6.2 To conduct each independent Draw, we send the competition ticket number list and Draw reference (pseudonymous identifiers that do not include your name, contact details, Account identifiers or payment information) to a third-party random draw service called RANDOM.ORG, which publishes a public record of the Draw and its result. This public record is created and retained by RANDOM.ORG independently of Raffio, is not held by us, and, in accordance with RANDOM.ORG's own retention practices, is retained by RANDOM.ORG for a minimum period once published and cannot subsequently be modified or deleted by Raffio.

6.3 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.4 For the avoidance of doubt, we do not sell your personal data to third parties.

7. International transfers

7.1 We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK.

7.2 Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

  • (a) we will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, any country that an adequacy regulation has been made by the UK Secretary of State; or
  • (b) we may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us using the details in clause 11.

8. Data security

8.1 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, including (without limitation):

  • (a) encryption of data in transit and at rest, including additional encryption of Winner delivery details;
  • (b) secure authentication and access controls; and
  • (c) regular security testing.

8.2 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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

8.3 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

9.1 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

9.2 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.

9.3 By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being users for tax purposes.

9.4 In some circumstances you can ask us to delete your data, see clause 10 below for further information.

9.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

10.1 You have a number of rights under data protection laws in relation to your personal data.

10.2 You have the right to:

  • (a) request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  • (b) request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  • (c) request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  • (d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object;
  • (e) you also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes;
  • (f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
  • (g) withdraw consent at any time where we are relying on consent to process your personal data (see the table in clause 5 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent;
  • (h) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • i. if you want us to establish the data's accuracy;
  • ii. where our use of the data is unlawful, but you do not want us to erase it;
  • iii. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • iv. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

10.3 If you wish to exercise any of the rights set out above, please contact us using the details in clause 11.

10.4 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.

10.5 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 may also contact you to ask you for further information in relation to your request to speed up our response.

10.6 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Contact details

11.1 If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • (a) Email address: privacy@raffio.co.uk
  • (b) Platform: through your Account settings or customer support
  • (c) Postal address: Raffio Limited, 9 Newton Place, Office 1, Glasgow, Scotland, G3 7PR

12. Complaints

12.1 You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

12.2 If you are dissatisfied with the handling of your data, you may raise a formal complaint by contacting us at support@raffio.co.uk and marking your correspondence "Formal Complaint."

12.3 Formal complaints are handled in accordance with our Complaints Policy, which can be found here.

12.4 Nothing in this clause affects your statutory rights or your right to bring proceedings before a court of competent jurisdiction.

13. Changes to the privacy policy and your duty to inform us of changes

13.1 We keep our privacy policy under regular review. Any changes will be published on the Platform with an updated "Last updated" date. Your continued use of the Platform following such an update constitutes your acceptance of the revised Policy.

13.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

14. Third-party links

This Platform 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. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.