Privacy Policy

• Identity and eligibility information such as name, date of birth, address and verification documents.
• Contact information such as email address, telephone number and communication preferences.
• Account information including username, profile/avatar choices, login/security records and account restrictions.
• Orders, payments, refunds, chargebacks, entries, ticket numbers, game results, cash prizes, wallet activity and Site Credit.
• Reward activity including streaks, cashback, Daily Boost, Daily Spins, referrals, Power Plays and Proper Pass.
• Support messages, complaints, winner communications, marketing preferences and email engagement where lawfully collected.
• Device, IP/network, browser, cookie-consent, security, fraud and technical logs.
• Journey and behavioural events such as pages viewed, game/product interactions, cart/checkout events and feature engagement where collected lawfully.
• Competition/game performance information used by Proper360 and the Game Builder, including aggregated or customer-linked preferences where appropriate.

• To create and secure accounts, verify age/identity and provide customer support.
• To process payments, entries, ticket allocation, instant-win results, draws, rewards, refunds and prizes.
• To maintain separate cash, cash-prize and Site Credit records accurately.
• To prevent fraud, duplicate accounts, payment abuse, chargeback abuse and manipulation of entries or rewards.
• To administer responsible-play restrictions and suppress marketing where required.
• To understand site/game performance, improve products, diagnose faults and plan competitions.
• To personalise non-sensitive content and recommendations where lawful and appropriate.
• To send service communications and, where permitted, direct marketing.
• To meet tax, accounting, legal, regulatory and dispute-resolution obligations.

Depending on the activity, we rely on performance of a contract, compliance with legal obligations, legitimate interests or consent. We do not rely on consent where the processing is actually necessary to perform an order or legal obligation.

Where consent is required for electronic marketing, optional cookies or another activity, it can be withdrawn without affecting processing already carried out lawfully.

Proper360 may combine account, order, game, reward and journey information to understand preferences, identify service issues, improve recommendations, measure retention, forecast demand and help design future competitions.

• Site Credit is kept analytically separate from genuine external-cash performance.
• Profiling used for direct marketing is subject to marketing rights and objections.
• We do not intend to use sensitive personal information to target promotional gaming content.
• We do not make a solely automated decision with legal or similarly significant effect on a customer without applying the safeguards required by law.

Proper Wins may use AI-assisted tools to analyse aggregated business data, generate draft game concepts/artwork, identify operational trends, recommend marketing or support internal decision-making. AI output is not treated as automatically correct and may be reviewed before material action.

We aim to minimise personal data sent to AI/service providers and use appropriate contracts and security controls where a provider processes personal information for us.

Payment-card data is generally handled by the payment provider rather than stored in full by Proper Wins. We receive transaction identifiers, statuses and other information needed to administer orders, refunds, fraud checks and reconciliation.

We may share necessary information with hosting/security providers, payment processors, email/SMS providers, identity/fraud services, analytics/consent tools, accountants/advisers, prize suppliers/couriers, cloud/AI providers and authorities where required by law.

Providers are given only the information reasonably needed for their role and are subject to contractual or legal safeguards where required.

Some providers may process information outside the UK. Where UK data-protection law requires a transfer safeguard, we use an applicable adequacy mechanism, approved contractual safeguard or other lawful transfer mechanism.

Promotional email, SMS, direct message or similar electronic marketing is sent only where permitted by law. Customers can unsubscribe using the message link or by contacting support. We may keep a minimal suppression record so the opt-out remains effective.

Service emails such as order confirmations, ticket results, security messages, prize notices and material account communications are not treated as optional marketing merely because they are sent electronically.

Where permitted and technically enabled, we may record delivery, opens or clicks to measure communications, diagnose delivery issues and improve campaigns. Where tracking requires consent under applicable rules, it will be controlled accordingly.

Strictly necessary technologies support requested services such as login, basket, checkout, fraud prevention and consent storage. Optional analytics, advertising or personalisation technologies are controlled by the Cookie Policy and consent tool where consent is required.

Promotional rules may require enough winner information to demonstrate that a valid award took place. We will balance transparency with privacy, consider reasonable objections and avoid unnecessary publication.

Photos, video, interviews and testimonials are normally optional and used with an appropriate lawful basis.

Spend limits, cooling-off, self-exclusion, account restrictions and related records may be used to maintain the requested protection, prevent circumvention and demonstrate appropriate handling. Such data is not used to target promotional messages to restricted customers.

• Core order, payment, prize, tax, complaint and competition records may be retained for up to six years or longer where a legal claim or duty reasonably requires it.
• Identity documents are retained only for as long as reasonably necessary for verification, fraud prevention and legal obligations.
• Responsible-play restriction records may be retained beyond the active restriction where needed to maintain protection and evidence compliance.
• Marketing data is kept until consent/permission ends or it is no longer needed, with minimal suppression data retained to honour opt-outs.
• Technical, security and journey records use proportionate retention periods and may be aggregated or anonymised when detailed event data is no longer needed.

We use proportionate technical and organisational controls including access restrictions, secure service providers, logging, backups and monitoring. No online system can be guaranteed risk-free. Customers should protect account credentials and report suspicious access promptly.

Depending on the circumstances, you may have rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent. Some rights are limited where information must be retained for legal obligations, fraud prevention, prize integrity, self-exclusion or legal claims.

Email support@properwins.co.uk with the subject Data Rights Request. We may request proportionate identity verification. We normally respond within the legal time limit, ordinarily one month unless an allowed extension applies.

Proper Wins services are for adults aged 18 or over. If we reasonably believe an account belongs to a child, we may restrict it, investigate and delete information where appropriate while retaining any record genuinely required for safeguarding, fraud prevention or legal compliance.

Please contact us first so we can investigate. You also have the right to complain to the Information Commissioner’s Office using the ICO’s published contact routes.

We may update this policy when services, providers, data uses or legal requirements change. Material changes will be reflected in the updated date and brought to customers’ attention where appropriate.