Black Key Rewards
Privacy Policy
The short version
Black Key Rewards is not yet open for competitions. For now, you can visit our pre-launch page and, if you choose, create an account and ask to hear about our launch. This policy explains what we do with your information while that is the case. Creating an account does not sign you up to marketing; that is a separate, optional choice.
1. Who we are
Black Key Rewards is operated by Charlotte Rees, trading as Black Key Rewards, who is the data controller for the personal information described in this policy.
You can contact us about this policy or your information at support@blackkeyrewards.com.
2. What this policy covers
This policy covers the personal information we handle when you visit our pre-launch page, create an account, tell us whether you would like to receive updates, or contact us.
Our competitions are not yet open to the public, so this policy does not describe entries, ticket purchases, payments, draws or prizes. We will update this policy, and tell you where appropriate, before those features go live.
3. The information we collect
When you create an account, we ask you for:
- your first and last name;
- your email address, which you also use to log in;
- a UK mobile or telephone number;
- your date of birth;
- a password of your choice; and
- whether you would like to receive our marketing updates (optional).
If you tick the optional marketing box, we also keep a record of that choice: the date and time, the page it was made on, and the exact wording you were shown.
If you email us, we keep your message and our reply. Our hosting and security services may also process technical information such as your IP address and browser details when you visit or register, as described in section 8.
We collect this information directly from you, through the registration form on our pre-launch page or when you contact us.
4. How we use your information and why
The law requires us to have a valid reason, called a lawful basis, for each use of your personal information. These are ours:
| What we do | Information used | Lawful basis |
|---|---|---|
| Create and manage your account | Name, email, phone number, password | Taking steps at your request to set up an account with us (contract) |
| Check you meet our minimum age | Date of birth | Our legitimate interest in making sure accounts are only held by people who are old enough |
| Send you messages about your account and the service | Name, email | Contract, where the message is needed to provide the account you asked for; otherwise our legitimate interest in keeping you informed about your account |
| Protect the site and prevent spam or fake sign-ups | Email, IP address, browser details | Our legitimate interest in keeping our website and members secure |
| Respond to your enquiries | Name, email, your message | Our legitimate interest in answering you; or contract, if you are asking about your account |
| Send you optional marketing updates | Name, email, your marketing choice | Your consent |
| Keep a record of your marketing choice | Date and time, source and wording of your choice | Our legitimate interest, and our need to be able to show that you consented |
Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and expectations. You can ask us about this at any time.
We do not use your phone number for marketing, and we do not sell your personal information.
5. Your account and password
You create your account with your email address and a password. Your password is stored using WordPress's password hashing, which means it is held in a scrambled form rather than as readable text. We cannot see your password.
6. Date of birth and age
You must be 18 or over to create a Black Key Rewards account. We ask for your date of birth to confirm this when you register, and we keep it on your account record so that we can show you met the requirement. We do not use your date of birth for marketing.
7. Optional marketing
Creating an account does not mean you have agreed to marketing. If, and only if, you tick the optional box, we will use your name and email address to send you news about competition launches, winner announcements and Black Key Rewards updates.
We use Brevo, an email marketing platform, to manage these updates. When you opt in, we share only your email address, first name, last name and your opt-in status with Brevo. We do not send Brevo your date of birth, phone number or password.
You can withdraw your consent at any time, free of charge, by using the unsubscribe link that will be included in our marketing emails or by emailing support@blackkeyrewards.com. Withdrawing consent stops marketing but does not close your account, and it does not affect anything we did lawfully before you withdrew. We may keep a record that you opted out so that we respect your choice.
8. Who we share your information with
We do not sell your information. We use a small number of service providers who handle information for us, and only for the purposes described in this policy:
- WordPress.com and Automattic. Our website is hosted on WordPress.com infrastructure. Automattic services that help run and protect the site, including Jetpack and an anti-spam check on new sign-ups, may process account details and technical information such as your email address, IP address and browser details. Our website's email delivery also runs through this infrastructure.
- Brevo. Used only for people who have opted in to marketing, as explained in section 7.
We may also disclose information if we are legally required to do so, or where it is necessary to protect our rights or the safety of others.
Our pre-launch page contains a link to our Facebook page. If you follow it, you leave our website and Facebook's own privacy policy applies. We do not embed Facebook content or tracking on the pre-launch page.
9. Transfers outside the UK
Some of our service providers may process information outside the United Kingdom. Where that happens, we expect the transfer to be covered by a safeguard recognised under UK data protection law, such as an adequacy decision or approved contractual terms. You can contact us for more information.
10. Cookies and similar technologies
Our pre-launch page does not use analytics or advertising cookies, pixels or similar tracking technologies, and it does not load fonts or other content from third-party services. If we ever add cookies that are not strictly necessary, we will ask for your permission first.
Other pages of our website may use different technologies when the full site opens. We will provide appropriate information and choices at that time.
11. How long we keep your information
We keep personal information only for as long as is reasonably necessary for the purposes it was collected for, and where necessary to meet legal, regulatory, accounting, security or dispute-related requirements.
In practice, we normally keep account information while your account remains active, or for as long as is otherwise reasonably necessary. We may keep records of your marketing choices, including if you withdraw consent, for as long as we reasonably need them to show your preferences and that we have complied with the law.
12. Security
We use appropriate technical and organisational measures to protect your personal information, including storing passwords in hashed form and relying on reputable hosting and service providers. No online service can be guaranteed to be completely secure, so please choose a strong, unique password and keep it private.
13. Your rights
Under UK data protection law you have rights over your personal information. Depending on the circumstances, you may have the right to:
- be told how we use your information, and ask for a copy of it (access);
- ask us to correct information that is inaccurate or incomplete;
- ask us to delete your information (erasure);
- ask us to restrict how we use it;
- object to our use of it where we rely on legitimate interests;
- ask for the information you gave us in a portable format (data portability); and
- withdraw your consent at any time, where we rely on consent.
These rights are not absolute, and in some cases we may need to keep certain information or may be unable to act on a request, in which case we will explain why. To use any of them, email support@blackkeyrewards.com. We will normally respond within one month, and we may need to confirm your identity first.
14. Complaints
If you have a concern, please contact us first so we can try to put it right. You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk.
15. Changes to this policy
We may update this policy from time to time, in particular when our competitions open and we begin handling different information. The effective date at the top shows when it was last changed. Where a change is significant, we will tell you in an appropriate way.
16. Contact us
Black Key Rewards
Email: support@blackkeyrewards.com