This Privacy and Cookie Notice (“Notice”) describes how EverUp LTD (also referred to as “EverUp”, “we”, or “us”) will make use of your personal data when you are using our Services. This Notice comprises the following sections:
Privacy & Cookie Policy
Contents
1. What does this Privacy Notice cover?
2. Who we are?
3. What information do we collect?
4. How do we use this information, and what is the legal basis for this use?
5. Cookies
6. Storing your personal information
7. Sharing your personal information
8. Your data protection rights
9. Updates to this Notice
10. Contact Us
Overview
1. What does this Privacy Notice cover?
This Notice describes how EverUp LTD (also referred to as “EverUp”, “we”, or “us”) will make use of your personal data when you are using our Services.
It explains the types of information we collect, the purposes for which we are using personal information and the legal grounds on which we rely. The Notice sets out how we share personal information with third parties, for how long we store personal information and how we use cookies.
It also describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your data protection rights” section.
When we use capitalized terms in this Notice, these terms have the meaning explained in our Terms of Service or Competition Rules.
2. Who we are?
We are EverUp LTD, a company incorporated in England and Wales with company registration number 12462608 and registered address at Arquen House 4-6 Spicer Street, St. Albans, England, AL3 4PQ. We control the information we collect about you when you use our Services and we are the data controller for the purposes of data protection law.
3. What information do we collect?
When we refer to “personal data” or “personal information” in this Notice, we mean information that relates to you. We collect and process your personal data when you interact with us through our website and our app and when you use our Services. This includes:
- Identity and contact information, including your name, title, date of birth, your postal address, email address and phone number, identification documents (such as copies of your passport or driving licence or other documents you provide for identification purposes) and any other information you provide to prove you are eligible to use our Services;
- Account information, including username, password and other registration information, your use of our Services and your participation in our Competitions, your Coin Balance, transactions you effect through our app, any prizes you win and transactions we carry out to provide you with your cash prizes, your privacy and marketing preferences;
- Financial information, including bank account details (such as account number, sort code and IBAN) of the bank account you have linked to your Profile and of your Electronic Money Account you create with the Partner Institution, and relevant information provided by fraud prevention agencies;
- Communications information, including records of your communications with us and our customer service team (such as records of emails, chat and in-app communications and voice recordings);
- Social network information, including your interactions with us (such as messages) or our content (such as your likes) on social media (such as Facebook, Instagram or Twitter), your use of social media features integrated in our website and app, your social media username when you select to access our Services using your social media account, and any other account information or activity that you permit a third party social media network to share with us;
- Technical information, including device identifiers, IP address, and where you have enabled location services, your GPS location, as well as information on how you use our website and app. This information is mainly collected through cookies and includes: your visits to our platform, the links you click on, through and from our site (including date and time), the services you view or search for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page; technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device identifier, number, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use; information stored on your device, including if you give us access to contact information from your address book, photos, videos or other digital content, check-ins.
We collect this information from you, when you provide it to us directly or when we collect it through our website or app using technical means, such as cookies. Sometimes, we also collect information about you from third parties, in particular:
- Banks and payment institutions: we will collect information from your bank when you link your bank account to your Profile, from the Partner Institution with which you open your Electronic Money Account, and from providers issuing and managing the distribution of e-money to you. This is required for us to provide our Services.
- Fraud prevention agencies and third parties carrying out identification checks: these parties provide or confirm information to us to allow us to verify your identity, confirm that you are eligible to use our Services and prevent fraudulent activity through our Services.
- Social media platforms (such as Facebook, Twitter, Instagram): these parties provide information to us when you use your social media account to connect to our app and use our Services, when you interact with us or our content on those platforms, when you interact with social media features (e.g. “Like” buttons) integrated on our website and app.
4. How do we use this information, and what is the legal basis for this use?
Purpose |
To allow you to create a Profile with us, set up an Electronic Money Account with our Partner Institution, use our Services and enter any of our Competitions, claim any prizes and have such prizes awarded to you. |
Legal grounds |
Contractual necessity, to the extent the information we collect for these purposes is necessary to fulfil our contract with you;
Our and our Partner Institution’s legitimate interests, to the extent the information is necessary to allow our Partner Institution to fulfil its contract with you and ensure the Partner Institution Terms are complied with. |
Purpose |
To communicate with you about your Profile and your use of our Services, such as your entry in Competitions and to effectively manage your Profile (e.g. send you an account activation email, process any changes you make to your Profile, keep track of your Coin Balance and use of Coins). |
Legal grounds |
Contractual necessity, to the extent the information is necessary to fulfil our contract with you (for example, to inform you about how you can claim your prize);
Our legitimate interests, to the extent the information is necessary to process queries you make in relation to your Profile and account and to effectively manage our relationship with you as our user and your Profile to effectively manage your Profile, your Coin Balance, Coin expiry and cancellation. |
Purpose |
If you communicate with us (for example, if you email or call us), we will use your information for dealing with your queries, training and customer service purposes. |
Legal grounds |
Contractual necessity: where you provide information that is necessary for us to fulfil our contract with you and provide our Services.
Our legitimate interests to handle your queries and provide you with requested information, to ensure high customer service quality and to train staff in responding to such requests. |
Purpose |
To carry out identity and credit reference checks, to verify the bank account information you provide to us and to establish your eligibility to use our Services, in accordance with our Terms of Service and Competition Terms. |
Legal grounds |
Our legitimate interests to protect the integrity of our Services and business operations and to ensure that our users are able to comply with our terms and do not misuse our Services.
Legal requirements, to the extent we are required by law to verify any of your information in order to provide our Services to you. |
Purpose |
To administer and effectively manage our Competitions, including selecting winners and disqualifying entries. |
Legal grounds |
Our legitimate interests to ensure the effective management of our operations and the integrity of our Services. |
Purpose |
To publish your information on our “winners” page of our website and app, when you win in any of our Competitions. This information includes your name, home city and photograph. |
Legal grounds |
We rely on our legitimate interests to publish this information. You can object to publishing your information at any time by emailing us at: |
Purpose |
To send you marketing communications about our Services (and the products or services of third parties that we make available through our Services), or to send you our newsletter when you sign up to receive this and to monitor whether you open our emails and/or click on URLs in our emails. |
Legal grounds |
We rely on your consent, where this is required by law.
Otherwise, we rely on our legitimate interest to keep you informed of products and services on our platforms, when we are allowed by law to do so. |
Purpose |
To carry out market research and create marketing profiles about our users and understand their preferences in relation to our Services (including the products and services available through these). |
Legal grounds |
Our legitimate interests to carry out marketing activities. |
Purpose |
To display our advertisements to you on other platforms, such as social media platforms or to display on our website and app advertisement which we think you might like. |
Legal grounds |
Your consent, where we obtain this information by using cookies or where otherwise required by law.
Otherwise we rely on our and third parties’ legitimate interests to carry out marketing activities and inform you of products and services we think you might like. |
Purpose |
To compile statistics and analysis about the use of our Services and use such statistics to enable us to provide a better service, features and functionality to you and other users. |
Legal grounds |
Your consent, where we obtain this information by using cookies.
Our legitimate interests (where consent is not required by law) so as to ensure the smooth and effective functioning of our Services, to make sound business decisions about our products and services and to design, inform and deploy our business strategies. |
Purpose |
To protect the security of our Services, information systems and assets, to monitor compliance with our Terms of Service and Competition Terms, to prevent fraud and other prohibited or illegal activities in relation to our Services. |
Legal grounds |
Our legitimate interests to protect our business assets against fraud, misuse, and illegal activities or security threats. |
Purpose |
To respond to legitimate requests for the disclosure of information, made by public authorities, law enforcement or governmental bodies or under a court order. |
Legal grounds |
Legal requirement, to the extent we are obliged under law to process such requests.
Our legitimate interests to assist legitimate investigations carried out by official authorities. |
Purpose |
To respond to complaints, to protect our legal rights and to establish, exercise or defend legal claims relating to our platforms and/or our products and services. |
Legal grounds |
Our legitimate interests to protect our legal rights. |
Purpose |
For tax, accounting, record keeping and audit purposes. |
Legal grounds |
Legal requirements, to the extent the law requires that we use your information (for example, to comply with our tax obligations).
Our legitimate interest to effectively manage our business, audit our business processes and make informed business decisions. |
Purpose | Legal grounds |
To allow you to create a Profile with us, set up an Electronic Money Account with our Partner Institution, use our Services and enter any of our Competitions, claim any prizes and have such prizes awarded to you. | Contractual necessity, to the extent the information we collect for these purposes is necessary to fulfil our contract with you;
Our and our Partner Institution’s legitimate interests, to the extent the information is necessary to allow our Partner Institution to fulfil its contract with you and ensure the Partner Institution Terms are complied with. |
To communicate with you about your Profile and your use of our Services, such as your entry in Competitions and to effectively manage your Profile (e.g. send you an account activation email, process any changes you make to your Profile, keep track of your Coin Balance and use of Coins). | Contractual necessity, to the extent the information is necessary to fulfil our contract with you (for example, to inform you about how you can claim your prize);
Our legitimate interests, to the extent the information is necessary to process queries you make in relation to your Profile and account and to effectively manage our relationship with you as our user and your Profile to effectively manage your Profile, your Coin Balance, Coin expiry and cancellation. |
If you communicate with us (for example, if you email or call us), we will use your information for dealing with your queries, training and customer service purposes. | Contractual necessity: where you provide information that is necessary for us to fulfil our contract with you and provide our Services.
Our legitimate interests to handle your queries and provide you with requested information, to ensure high customer service quality and to train staff in responding to such requests. |
To carry out identity and credit reference checks, to verify the bank account information you provide to us and to establish your eligibility to use our Services, in accordance with our Terms of Service and Competition Terms. | Our legitimate interests to protect the integrity of our Services and business operations and to ensure that our users are able to comply with our terms and do not misuse our Services.
Legal requirements, to the extent we are required by law to verify any of your information in order to provide our Services to you. |
To administer and effectively manage our Competitions, including selecting winners and disqualifying entries. | Our legitimate interests to ensure the effective management of our operations and the integrity of our Services. |
To publish your information on our “winners” page of our website and app, when you win in any of our Competitions. This information includes your name, home city and photograph. | We rely on our legitimate interests to publish this information. You can object to publishing your information at any time by emailing us at: |
To send you marketing communications about our Services (and the products or services of third parties that we make available through our Services), or to send you our newsletter when you sign up to receive this and to monitor whether you open our emails and/or click on URLs in our emails. | We rely on your consent, where this is required by law.
Otherwise, we rely on our legitimate interest to keep you informed of products and services on our platforms, when we are allowed by law to do so. |
To carry out market research and create marketing profiles about our users and understand their preferences in relation to our Services (including the products and services available through these). | Our legitimate interests to carry out marketing activities. |
To display our advertisements to you on other platforms, such as social media platforms or to display on our website and app advertisement which we think you might like. | Your consent, where we obtain this information by using cookies or where otherwise required by law.
Otherwise we rely on our and third parties’ legitimate interests to carry out marketing activities and inform you of products and services we think you might like. |
To compile statistics and analysis about the use of our Services and use such statistics to enable us to provide a better service, features and functionality to you and other users. | Your consent, where we obtain this information by using cookies.
Our legitimate interests (where consent is not required by law) so as to ensure the smooth and effective functioning of our Services, to make sound business decisions about our products and services and to design, inform and deploy our business strategies. |
To protect the security of our Services, information systems and assets, to monitor compliance with our Terms of Service and Competition Terms, to prevent fraud and other prohibited or illegal activities in relation to our Services. | Our legitimate interests to protect our business assets against fraud, misuse, and illegal activities or security threats. |
To respond to legitimate requests for the disclosure of information, made by public authorities, law enforcement or governmental bodies or under a court order. | Legal requirement, to the extent we are obliged under law to process such requests.
Our legitimate interests to assist legitimate investigations carried out by official authorities. |
To respond to complaints, to protect our legal rights and to establish, exercise or defend legal claims relating to our platforms and/or our products and services. | Our legitimate interests to protect our legal rights. |
For tax, accounting, record keeping and audit purposes. | Legal requirements, to the extent the law requires that we use your information (for example, to comply with our tax obligations).
Our legitimate interest to effectively manage our business, audit our business processes and make informed business decisions. |
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out in the “Contact Us” section below.
Wherever we rely on consent, you will always be able to withdraw that consent at any time, although we may have other legal grounds for processing your data for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing purposes, at any time. You can do this by (i) clicking on the unsubscribe link in the relevant marketing communication, (ii) changing your marketing preferences through your Profile, or (iii) emailing us using the contact details under the “Contact Us” section below.
We do not use your personal information to take automated decisions about you which have a legal or similarly significant effect on you.
6. Storing your personal information
We will store your personal information for as long as it is required for us to fulfil the purposes for which we have collected it, as described in this Notice, and for such further period that is necessary to comply with our legal and regulatory obligations, to exercise our legal rights and to protect our business from legal claims.
8. Your data protection rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions upon which we rely when responding to any request you make.
To exercise any of these rights you can get in touch with us using the details set out in the “Contact us” section below. If you have unresolved concerns, you have the right to complain to the data protection authority, which in the UK is the Information Commissioner’s Office.
9. Updates to this Notice
We may from time to time update this Notice if there is a change to the way we use personal data or if this is required by a legal or regulatory change. Any new version of this Notice will be published on our website.
10. Contact us
If you have questions in relation to this Notice or on how we use your personal data at EverUp or if you would like to exercise your data protection rights, you can get in touch with us by writing to:
EverUp LTD
1 Arquen House, 4-6 Spicer Street
St Albans, England
AL3 4PQ
Or emailing us at