Privacy Policy

We are LuxWinAsia Ltd, a company registered in England and Wales under company number 17038462, with its registered office at 128 City Road, London, EC1V 2NX, United Kingdom. We are the data controller for the personal data we collect through this Site and are registered with the UK Information Commissioner's Office (ICO).

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a concern, you can contact our Data Protection point of contact at contact@luxwinasia.com.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you visit our website www.luxwinasia.com (the "Site") or use our services, including entering competitions.

By using our Site or services, you agree to the collection and use of your personal data as described in this policy. This Privacy Policy should be read alongside our Terms & Conditions, Game Rules, and Responsible Gaming Policy, which together govern your use of the Site and participation in our competitions.

This policy applies only to data collected through the Site. If you provide personal data to third-party services (such as payment providers), please refer to their respective privacy policies.

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically. Continued use of the Site constitutes acceptance of the updated policy.

4.1 Information You Provide to Us

When you create an account, enter a competition, or contact us, we may collect:

• Full name
• Email address
• Phone number
• Date of birth (for age verification)
• Postal address (for winner correspondence and prize delivery)
• Passport or ID information (upon winning, for identity verification and prize fulfilment)
• Payment information (processed securely through third-party payment providers: we do not store full card details)
• Communications you send to us (emails, support requests)
• Referral information (if you use a "Refer a Friend" feature)

4.2 Information Collected Automatically

When you visit the Site, we may automatically collect:

• IP address
• Browser type and version
• Device type, operating system, and unique device identifiers
• Pages visited, time spent on pages, and navigation patterns
• The website from which you arrived at our Site (referral URL)
• Date and time stamps of your visits
• A unique reference number linked to your session or account activity

4.3 Information from Third Parties

We may receive limited information from third parties, including:

• Billing verification information from our payment provider (e.g., name, email address, and billing address)
• Fraud prevention data from specialist service providers

We use your personal data for the following purposes:

• Contract performance: To process your competition entries, verify eligibility, manage your account, administer prize draws, and arrange prize fulfilment for winners.
• Legitimate interests: To manage and improve the Site, track usage patterns, detect and prevent fraud or abuse, and ensure the security of our platform.
• Consent: To send you marketing communications, newsletters, or promotional materials where you have opted in. You can withdraw consent at any time (see Section 10).
• Legal obligations: To comply with applicable laws, regulations, and legal processes, including anti-money laundering, age verification, and tax reporting requirements.
• Referrals: If you provide us with another person's email address through a referral feature, we will send them a single referral message. We will not use their email for other purposes unless they independently consent.

Under the UK General Data Protection Regulation (UK GDPR), we process your personal data on the following legal bases:

• Performance of a contract: Where processing is necessary to fulfil our contractual obligations to you (e.g., processing entries, awarding prizes).
• Legitimate interests: Where processing is necessary for our legitimate business interests and those interests are not overridden by your rights (e.g., fraud prevention, site improvement).
• Consent: Where you have given us specific, informed consent (e.g., marketing emails).
• Legal obligation: Where processing is required to comply with applicable law.

7.1 We Do Not Sell Your Data

LuxWinAsia does not sell, rent, or trade your personal data to third parties for their marketing purposes.

7.2 Service Providers

We may share your personal data with trusted third-party service providers who help us operate our business, including:

• Payment processors and PCI-DSS compliant payment service providers for secure payment handling
• Cloud hosting and IT infrastructure providers for data storage and site operation
• Email service providers for transactional and marketing communications
• Analytics providers (e.g., Google Analytics) for site usage analysis
• Fulfilment partners (airlines, hotels, couriers, manufacturers, and other suppliers) for prize delivery or travel arrangement: only the information necessary for fulfilment will be shared, and only after the winner's explicit confirmation

7.3 Legal and Regulatory Authorities

We may disclose your personal data to law enforcement authorities, regulators, or other government bodies where required by law, court order, or legal process.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity as part of the transaction.

7.5 Professional Advisers

We may share data with our insurers, auditors, and legal advisers in connection with insurance coverage, regulatory compliance, or legal claims.

Your personal data is primarily stored within the United Kingdom and the European Economic Area (EEA). However, some of our service providers may process data outside the UK/EEA. Where data is transferred internationally, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner's Office (ICO), the UK International Data Transfer Agreement (IDTA) where applicable, or transfer to countries recognised as providing adequate data protection.

• Account data: For the duration your account is active, and for 24 months following your last activity.
• Transaction and competition records: For 7 years, in compliance with UK financial and tax regulations.
• Marketing preferences: Until you withdraw consent or unsubscribe.
• Winner identity verification data: For 12 months following prize fulfilment, then securely deleted.
• Communication records: For 12 months from the date of the communication.

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data, subject to our legal obligations.
• Right to Restrict Processing: Request that we limit the processing of your data.
• Right to Data Portability: Request your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw at any time without affecting prior processing.

To exercise any of these rights, please contact us at contact@luxwinasia.com. We will respond within 30 days.

Essential Cookies: Required for the Site to function (session management, authentication).

Analytics Cookies: Help us understand how visitors use the Site (Google Analytics).

Advertising Cookies: Personalise advertisements and measure effectiveness.

Payment Provider Cookies: Placed by our payment providers for secure transactions.

You can manage or delete cookies through your browser settings. Disabling certain cookies may affect Site functionality.

Our services are strictly for individuals aged 18 or older. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will delete it promptly.

We implement appropriate technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption for data in transit
• Encrypted data storage with access controls
• Regular security audits and vulnerability assessments
• Staff training on data protection obligations
• Restricted access on a need-to-know basis

The Site may contain links to third-party websites. We are not responsible for the privacy practices of these external sites.

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk or 0303 123 1113.

We encourage you to contact us first at contact@luxwinasia.com.