World photography contest 2020-2022
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Privacy policy

Effective as of March 01, 2022

  1. About this Privacy Policy

    1. The website contest.alanhub.com (the “Website”) is operated by AlanHub Inc. (“we”, “us”, “our”, “AlanHub”), a company incorporated in the United States of America under company number 6380971. Our registered office is at 16192 Coastal Highway, Lewes, Sussex, 19958 Delaware, US.
    2. This Privacy Policy shall be governed by the law of England and courts of England and Wales will have exclusive jurisdiction in relation to this Policy.
    3. We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the “DPA 2018”), the United Kingdom General Data Protection Regulation (the “UK GDPR”) and any other applicable UK legislation (together, “Data Protection Law”).
    4. When you interact with us or use the Website, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
    5. We reserve the right to change this policy at any time by posting an updated version on the Website without any prior notice. You may wish to check it before using the Website as any changes will be effective immediately from the date that they are made.
  2. Policy Key Definitions

    • “We”, “us”, “our” or “ours” refers to AlanHub Inc.;
    • “You”, “yours”, “the participant” or “the applicant” refer to the person(s) using our Website and/or participating in the Contest;
    • PECR means Privacy & Electronic Communications Regulation;
    • ICO means Information Commissioner’s Office;
    • Cookies mean small files stored on a users’ computer or device; and
    • DPO means a data protection officer.
  3. Key Principles of the UK GDPR

    Our privacy policy embodies the following key principles:
    1. Lawfulness, fairness and transparency;
    2. Purpose limitation;
    3. Data minimisation;
    4. Accuracy;
    5. Storage limitation;
    6. Integrity and confidence; and
    7. Accountability.
  4. Contact Information

    1. If you have any concerns or would like further information about this policy in general, you can contact us at contest@alanhub.com.
  5. What information do we collect?

    1. We collect, store and use the types of below personal data set
    2. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    3. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
      1. Identity Data includes first name, last name, date of birth and gender;
      2. Contact Data includes the country of residence, residential address, billing address, delivery address, email address and telephone numbers;
      3. Payment Data includes first name, last name, billing address, billing details, payment account details; and
      4. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
      5. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
      6. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
  6. Purposes for which we will use your personal data

    Category of personal data Purpose of processing Lawful basis for processing
    Full name, country of residency and contact details

    1. Manage our relationship with you, including for public relations, advertising, and marketing purposes.

    2. The IP address you use to access our sites, and details of your internet browser’s capability so we understand when, where and how you have arrived at our Sites.

    3. For fraud prevention and detection.

    4. To contact you in case your Work is a winning entry.

    5. To contact you with information, newsletters and marketing materials.

    6. To publish your details affiliated with your Contest entry in case required.

    Consent.
    Date of birth

    1. For fraud prevention and detection.

    2. To ensure legal sale of age-restricted products and services.

    Consent.
    Payment information

    1. To process payment of the prize in case of the winning entry.

    2. For fraud prevention and detection.

    Consent.
    Technical data

    1. To conduct and store site usage analytics, statistical and trend analysis, market research and business improvement.

    Consent.
  7. If you fail to provide personal data

    1. Where we need to collect personal data by law, or under the terms we have with you, and you fail to provide that data when requested, we will not be able to consider your candidacy for the Contest and for the competition for prize and award respectively. In this case, your candidacy will be disqualified from the Contest.
  8. Sharing your personal data

    1. We may have to make your personal details, such as name, surname, age and country of residency, public.
    2. We may have to share your personal data with the parties set out below for the purposes set out in paragraph 6 above:
      • Internal Third Parties
      • External Third Parties
    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.
  9. How do we collect your personal data?

    1. We use different methods to collect data from and about you including through:
      1. Direct interactions. You may give us your personal data by filling in the form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
        • Submit your work to participate in the Contest;
        • Mistakenly submit your work to participate in the Contest;
        • Subscribe to our news and publications;
        • Request marketing to be sent to you;
        • Enter the Contest, promotion, or survey;
        • Share your personal and payment account details to receive the prize and/or award; or
        • Give us feedback or contact us.
      2. Automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
  10. How will we use your personal data?

    1. We will use your personal data for the purposes, including, but not limited to advertising, marketing and public relations; fraud detection and prevention; running the Contest; sending you the prize and/or award where applicable; for internal research and development; to improve our Website; to contact you with information, that might include the status of the competition or marketing materials.
    2. We are exempt from registration in the ICO Data Protection Register because we only process data for staff administration and for advertising, marketing and public relations.
      Under the UK GDPR we control and/or process any personal information about you electronically only when you consent for us to use your data for these purposes set out in the table at the end of this policy.
    3. We will continue to process your information under this basis until you withdraw consent, or it is determined your consent no longer exists.
    4. If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
  11. How do we share and disclose your personal data?

    1. When we share and disclose your personal data, we do so in accordance with Data Protection Law. We will share and disclose certain personal data when we publish the list of winning works, and/or when we notify the Contest winners and/or finalists.
    2. Personal information might be disclosed to third parties.
  12. Your rights

    1. We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
    2. Depending on the reason we have your personal data, you have a right to:
      1. Access the personal information we hold about you (commonly known as subject access): this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
      2. Request that we correct or complete personal information we hold about you that is inaccurate or incomplete: 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;
      3. Request that we erase your personal information in some 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;
      4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
      5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
        • If you want us to establish the data's accuracy;
        • Where our use of the data is unlawful but you do not want us to erase it;
        • 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; and
        • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
      6. Request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services: 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; and
      7. Where we have asked for your consent to process your data, to withdraw this consent: 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.
    3. These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
    4. If you wish to exercise any of these rights, please contact us using the details in paragraph 4 above.
  13. Data Retention

    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.
    2. Your data is safely stored and secured in encrypted locations around the world.
  14. Data Protection Principles

    1. We process your personal data in accordance with the following principles:
      1. we process your personal data lawfully, fairly and in a transparent way;
      2. we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which we collected it;
      3. we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
      4. we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
      5. we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing save for circumstances referred to in paragraph 12.1; and
      6. we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
  15. DATA SECURITY AND PROTECTION

    1. We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information around the world.