For the purposes of the Data Protection Act 2018 (the “Act”) and the General Data Protection Regulation 2016/679 (the “GDPR”), the data controller is Dream Globally. Dream Globally is responsible for your personal data protection. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below. 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.

• Dream Globally may process your data with your consent (for example, when you accept that Dream Globally may place cookies on your device or process or share information that you input into our website)
• Dream Globally may process your data when we need to do this to fulfil a contract with you (for example, if you win a prize in a competition that Dream Globally promoted or where we are required to do this by law, e.g. to comply with record keeping obligations)
• Dream Globally also processes your data when it is in Dream Globally’s legitimate interests to do this, and when these interests are not overridden by your data protection rights (including, for example, when Dream Globally shares data with our affiliates)

If you want to contact Dream Globally or to use certain facilities we provide on the Website, you will need to provide us with some additional personal information so that we can liaise with you and deal with your request, query or application. If you do choose to provide Dream Globally with your personal information, Dream Globally will collect that information for our own use and for the purposes described in this Policy.

Where you choose to provide personal details to Dream Globally, we may collect, store and process the following personal information from you:

if you create an account – your password, e-mail address, your full name and telephone

the reason for your contact, which may be an enquiry, a request or enquiry on behalf of someone else, providing a comment, or details in relation to a possible or existing competition

your contact and marketing preferences

if you take a survey or interact with us in various other ways – demographics information and information about subjects that may interest you

standard internet and website log information and details of patterns about how visitors behave on our Website and App. The information we may collect includes information about your Internet service provider, your operating system, browser type, domain name, the Internet Protocol (IP) address of your computer (or other electronic Internet-enabled device), your access times, the website that referred you to us, the Web pages you request and the date and time of those requests

where you “like” us or make posts on our pages on social networking websites

This information will be collected primarily from you as information voluntarily provided to us, but we may also collect it where lawful to do so from (and combine it with information from) public sources, third party service providers, individuals whom you have indicated have agreed for you to provide their personal information, government, tax or law enforcement agencies, and other third parties. We may also collect personal information about you from your use of other company services.

Dream Globally may use information about you for purposes described in this Policy or disclosed to you on our Website and App or with our services. For example, we may use information about you for the following purposes, all of which we believe to be in our legitimate business interests:

• to operate our competitions
• to respond to and/or deal with any request or enquiry you may raise
• to improve our products and services
• to present our content in the most effective manner for you and for your device
• to administer the Website and App
• for internal record keeping
• to contact you either by Dream Globally or through a relevant partner or agent by e-mail or phone for the above reasons
• subject to your consent where required under applicable laws, to carry out direct marketing, targeting through paid marketing, and/or e-mail marketing that you have requested
• to perform any contract Dream Globally has with you
• for compliance with legal, regulatory and other good governance obligations and
• subject to your consent when entering a raffle, to share your personal data via secure transfer to any specified third party organisations

Importantly, we do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent.

Your personal information will be made available for the purposes mentioned above and on a ‘need-to-know’ basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other Dream Globally staff who properly need to know these details for their functions within Dream Globally. Please note that certain individuals who will see your personal information may not be based at Dream Globally or in your country of residence (please see below).

We may share personal information within Dream Globally as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by Dream Globally for the other purposes described in this Policy.

Your personal information may also be made available to third parties (within or outside Dream Globally) providing relevant services under contract to Dream Globally (see below for further details), such as credit and debit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. Subject to your consent when entering a raffle, Dream Globally may also share your personal data via secure transfer to any specified third party organisations. Those organisations will process that data for their own respective purposes, and will become the controller of that personal data. Dream Globally has put in place various security and data privacy measures, inclusive in scope of such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA that work for us or for one of our providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Dream Globally, our employees, agents, customers, and others, as well as to parties to whom you authorise Dream Globally to release your personal information.

We will not sell your personal information to any third party other than as part of any restructuring of Dream Globally or sale of the business.

Importantly, we do not pass your personal data onto any third parties for them to market their products/services to you. If in the future we decide that we want to, we will only do so if we have your consent.

Your personal information will be made available for the purposes mentioned above and on a ‘need-to-know’ basis and only to responsible management, human resources, accounting, legal, audit, compliance, information technology and other Dream Globally staff who properly need to know these details for their functions within Dream Globally. Please note that certain individuals who will see your personal information may not be based at Dream Globally or in your country of residence (please see below).

We may share personal information within Dream Globally as needed for reasonable management, analysis, planning and decision making, including in relation to taking decisions regarding the expansion and promotion of our service offering and for use by Dream Globally for the other purposes described in this Policy.

Your personal information may also be made available to third parties (within or outside Dream Globally) providing relevant services under contract to Dream Globally (see below for further details), such as credit and debit card processors, auditors and compliance managers, provider or call centres and IT hosting and IT maintenance providers. These companies may use information about you to perform their functions on our behalf. Subject to your consent when entering a raffle, Dream Globally may also share your personal data via secure transfer to any specified third party organisations. Those organisations will process that data for their own respective purposes, and will become the controller of that personal data. Dream Globally has put in place various security and data privacy measures, inclusive in scope of such third parties, in order to protect personal information and shall seek to comply with applicable legal requirements.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA that work for us or for one of our providers. This may include staff engaged in, among other things, the fulfilment of any contract with you, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

We may disclose specific information upon lawful request by government authorities, law enforcement and regulatory authorities where required or permitted by law and for tax or other purposes. Personal information may also be released to external parties in response to legal process, and when required to comply with laws, or to enforce our agreements, corporate policies, and terms of use, or to protect the rights, property or safety of Dream Globally, our employees, agents, customers, and others, as well as to parties to whom you authorise Dream Globally to release your personal information.

We will not sell your personal information to any third party other than as part of any restructuring of Dream Globally or sale of the business.

Dream Globally may wish to provide you with information about new products, services, promotions and offers which may be of interest to you, and may invite you to take part in market research or request feedback on our products and services. This communication may occur by e-mail, telephone, post, social media or SMS. We will obtain your consent and advise you of how to opt-out of receiving such communications where we are required to do so in accordance with applicable law.

Dream Globally takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of personal information. While we take these reasonable efforts to safeguard your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of dealing online and will not hold us responsible for any breach of security unless such breach has been caused by the specific negligence of Dream Globally.

You have the right to review and access your personal information held by Dream Globally.

You also have the right to ask us to rectify, block, complete and delete your personal information, to restrict its use, and to ‘port’ your personal information (that is, to ask us to provide it to you in a structured, commonly used and machine readable format and to transmit it directly to another organisation).

In addition, you have the right to request further information about the handling of your personal information.

If you wish to do so, or to notify Dream Globally of a change in your details, please contact contact@dreamglobally.com or post to Dream Globally Limited, 28 Dundee Close, Cambridge, Cambridgeshire, CB4 1SH

There are exceptions to these rights, however. For example, access to personal information may be denied in some circumstances if making the information available would reveal personal information about another person, or if we are legally prevented from disclosing such information. In addition, we may be able to retain data even if you withdraw your consent, where we can demonstrate that we have a legal requirement to process and store your data.

If you have a question about the use of your personal information, or wish to file a complaint about it, please contact us using the contact details set out above.

Finally, if you have unresolved concerns, you also have the right to complain to the data protection authorities.

We will keep your data for as long as you hold a Dream Globally account and/or where you are still happy to hear from us about our latest news, products and services. Once you no longer wish to be engaged with Dream Globally we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax purposes where you have made purchases to play in our competitions or where we need to resolve any disputes with you).

The Competitions are not intended for children and Dream Globally do not knowingly collect data relating to children. The terms of our competitions prohibit users aged under 18 years from accessing our competitions without consent of their parent or guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at contact@dreamglobally.com. We will delete such information within a reasonable time.

We use cookies for certain areas of the Website and App. Cookies are small data files stored on your hard drive by a website. Cookies help us improve the Website and App, and your experience of them. We use cookies to see which areas and features are popular and to count visits to our websites, to recognise you as a returning visitor and to tailor your experience of the Website and/or App according to your preferences. Overall, cookies help us provide you with a better Website and App, by enabling us to monitor which pages you find useful and which you do not. We may also use cookies for targeting and/or advertising purposes. We may use Web beacons on our Website and App, or in our e-mails. Web beacons are electronic images that may be used to deliver cookies, count visits, understand usage of group websites and to tell if an e-mail has been opened and acted upon. Further details about cookie purposes and types are below. To delete or block cookies through your browser settings at any time, and for more general information about cookies including the difference between session and persistent cookies, visit www.allaboutcookies.org.

We also use Google Analytics on the Website and App to collect information about your online activity on the Site, such as the Web pages you visit and the links you click on the Website and App. We use the information to compile reports and to help us improve the Website and App. The cookies collect information in an anonymous form, including the number of visitors to the Website and App, where visitors have come to the Website and App from and the pages they visited.

For more information about the information gathered using Google Analytics please visit http://www.google.com/intl/en/analytics/privacyoverview.html. You can prevent these cookies by selecting the appropriate settings on your browser. If you do this, you may not be able to use the full functionality of this site. You may download and install the Google Analytics Opt-out Browser Add-on available here: http://tools.google.com/dlpage/gaoptout.

We only use category D cookies as defined in the international chamber of Commerce United Kingdom Cookie Guide:

“Targeting or advertising” cookies used to deliver adverts relevant to an identified machine or other device (not a named or otherwise identifiable person) which are tailored to interests associated with the website activity tied to that machine or device. For example, if a cookie on a third party website recognises that a particular product was purchased from a particular device, that cookie may “talk to” marketing cookies on the Website or App to ensure advertisements about similar products displayed on the Website or App are accessed from that device. These cookies are also used to limit the number of times a user sees an advertisement, as well as to help them measure the effectiveness of an advertising campaign. They may also remember that the Website or App has been visited from a device and share that information with marketing organisations. The marketing cookies on the Website and App are operated by third parties with our permission. Marketing cookies are used to monitor from which advertising source a user was directed towards the Website/App, so that we know whether it is worth us investing in that particular advertising source.

We will ask for your consent to the use of cookies set out in this Policy when you first access the Website or App, and if we introduce any new cookies to the Website/App. When you first visit the Website and App, a box/banner will appear asking you to agree to the cookies that we set on the Website/App.

You can usually choose to set your browser to warn you when a cookie is being sent or to remove or reject cookies. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you choose to remove or reject cookies, it will affect many features or services on our Website and App.

If you agree to cookies from our Website or App by clicking on the “I agree” button, we will set cookies from category D on your device. If you wish to delete the cookies we have set on your device, please refer to your browser Help menu.

If you do nothing to indicate your cookie preference for our Website or App (i.e. if you do not click on “I agree”), category D cookies will not be set on your device. To modify your cookie settings, please refer to the Help menu of your browser.

If you say no to cookies on our Website or App, we will not set category D cookies on your device. Please note that if you do this you may not be able to use the full functionality of our Site.

We keep this Policy under regular review. We may change this Policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. The date at the top of this Policy will be updated accordingly.

We encourage you to check the date of this Policy when you visit the Website or App for any updates or changes. We will notify you of any modified versions of this Policy that might materially affect the way we use or disclose your personal information.

If you have any questions about this Policy, please contact us by e-mail at contact@dreamglobally.com, or by mail at: Dream Globally Limited, 28 Dundee Close, Cambridge, Cambridgeshire, CB4 1SH