Top Dog Raffle Website Privacy Policy

 

Introduction

 

Top Dog Raffle (‘we,’ ‘our,’ or ‘us’) respects your privacy and is committed to protecting your personal data in compliance with the Data Protection Act No. 1 of 2023 of Grenada (‘GDPA’), which governs the collection, processing, storage, and protection of personal information to safeguard the privacy rights of individuals. This Privacy Policy outlines how we collect, use, disclose, and protect your information when you access and interact with our website www.topdograffle.com (‘Website’), including the use of third-party services such as WooCommerce for ticket sales, PayPal for payments, Google Analytics, Facebook Pixel, and our social media integrations with Facebook, X (formerly Twitter), Instagram, YouTube, and TikTok.

 

By using our Website and services, you accept and consent to the practices described in this policy. If you do not agree with any part of this policy, you should refrain from using our Website. Please review this Privacy Policy periodically as it may be updated from time to time to reflect changes in our practices or legal requirements.

 

Definitions

 

The following definitions apply throughout this Privacy Policy:

 

• Top Dog Raffle: Refers to the trading name of Grenada Consulting Inc., which is the entity responsible for managing the website, offering products and services, including ticket sales, and ensuring compliance with applicable laws and regulations in Grenada.
• Website: Refers to our online platform accessible via www.topdograffle.com, through which users can access services, purchase tickets, participate in prize draws, and engage with our content and other users.
• Third Parties: Entities or individuals other than Grenada Consulting Inc. (Top Dog Raffle) who may receive or have access to personal data collected via our Website. This includes service providers like WooCommerce and PayPal, communication tools (e.g., WhatsApp), email marketing services (e.g., MailChimp), as well as social media platforms (Facebook, X, Instagram, YouTube, TikTok) and analytics services (Google Analytics, Facebook Pixel)..
• Service Providers: Organizations or third parties engaged by Grenada Consulting Inc. (Top Dog Raffle) to perform services on our behalf, such as payment processing (PayPal), ticket sales (WooCommerce), communication tools (e.g., WhatsApp), email marketing services (e.g., MailChimp), marketing analytics (Google Analytics and Facebook Pixel), and other operational support, including social media platforms (Facebook, X, Instagram, YouTube, TikTok) for engagement and outreach.
• Personal Data: Any information relating to an identified or identifiable individual. This may include, but is not limited to, names, addresses, email addresses, phone numbers, payment details, and other identifiers collected through our Website.
• Data Subject or You: Refers to any individual who interacts with our Website, including those who purchase tickets, participate in prize draws, engage with our social media channels, or access any of our services.
• Prize Draw: Refers to the competition organized by Top Dog Raffle, where participants who purchase tickets are entered into a draw for a chance to win prizes, and the events may be broadcast live via platforms such as YouTube, Facebook, or TikTok.
• Cookies: Small text files stored on a user’s device when visiting our Website, used to identify user preferences, track activity, and enhance the user experience. This includes essential, analytics, and marketing cookies.
• Data Controller: The entity (Top Dog Raffle) that determines the purposes and means of processing personal data in accordance with the GDPA.
• Processing: Any operation or set of operations performed on personal data, such as collection, recording, organization, storage, alteration, retrieval, use, disclosure, or deletion, as regulated by the GDPA.
• Consent: The freely given, specific, informed, and unambiguous indication of the data subject’s agreement to the processing of their personal data, in compliance with the GDPA.
• Legal Obligation: Refers to the requirement to process and retain personal data to comply with statutory, regulatory, or legal obligations under Grenadian law, including tax reporting, anti-fraud measures, or judicial processes.
• Legitimate Interests: The business interests of Top Dog Raffle in operating, managing, and improving the services offered, provided these interests are balanced against the rights and freedoms of the data subject.
• Data Breach: A security incident resulting in unauthorized access, alteration, loss, or disclosure of personal data. Under the GDPA, this necessitates notification to affected individuals and authorities within specific timeframes.
• Retention Period: The duration for which Top Dog Raffle retains personal data to fulfill the purposes for which it was collected, as well as to comply with legal, accounting, and regulatory requirements as defined by Grenadian law.
• Data Protection Authority: The regulatory body in Grenada responsible for overseeing compliance with data protection laws, investigating complaints, and ensuring the rights of data subjects are upheld under the GDPA.

 

LAWS:

 

• GDPA: Stands for the Data Protection Act No. 1 of 2023 of Grenada, which sets forth the rules and guidelines governing the collection, processing, storage, and protection of personal data in Grenada.
• Consumer Protection Act: Refers to the Consumer Protection Act No. 2 of 2018, which regulates the rights of consumers and obligations of businesses operating in Grenada, ensuring fair business practices and compliance with legal standards in transactions.
• Civil Liability Act: The statute that governs liability matters, including data protection, electronic transactions, and the protection of consumer rights under Grenadian law. It replaces references to the broader “Civil Code of Grenada” when addressing liability and data-related issues.
• Contracts Act: The legislation governing the obligations, rights, and liabilities related to contractual agreements within Grenada, ensuring that both businesses and consumers comply with fair and legal practices. It replaces references to the “Civil Code of Grenada” when discussing contracts and business obligations.

These definitions provide clarity on terms used throughout this Privacy Policy and form the basis for interpreting our obligations and your rights in the context of your interactions with our Website and services.

 

1. Information We Collect

We collect various types of information in compliance with the Civil Liability Act and the GDPA:

 

• Personal Identification Information: When you purchase raffle tickets or interact with our Website, we may collect your full name, email address, phone number, shipping address, and payment information. This data is necessary to fulfill our contractual obligations and ensure compliance with the Consumer Protection Act No. 2 of 2018
• Technical and Usage Information: We automatically collect data about your device, browsing actions, and patterns. This may include IP addresses, browser type, operating system, referral sources, and time zone settings. We collect this information through cookies and similar technologies to comply with electronic communications regulations and optimize your experience.
• Payment Information: Payments are processed securely through PayPal, and we do not store your payment information. PayPal’s Privacy Policy governs all data handling during payment processing. This is consistent with Cap 72B of Grenada’s Civil Liability Act, which covers liability in electronic transactions (verify that this section specifically addresses electronic transactions; if not, replace or remove the section number accordingly).
• Social Media Information: We may collect publicly available information from your social media profiles when you engage with our accounts on platforms such as Facebook, X, Instagram, and YouTube.
• Analytics Data: Google Analytics and Facebook Pixel are employed to gather information about your interactions with our Website. This includes tracking page visits, time spent on pages, and other user behaviors. This data helps us to enhance the user experience and measure the effectiveness of our marketing strategies, in compliance with the GDPA’s regulations on data transparency and lawful processing.

 

2. How We Use Your Information

The information collected is used for the following purposes in accordance with the legal framework of Grenada:

 

• To Process Transactions: We use your data to fulfill ticket sales, manage payments, and ensure the proper delivery of services. This is done in compliance with the provisions of the Consumer Protection Act No. 2 of 2018, which promotes fair and ethical business practices and protects consumer rights. (If a specific section directly covers transactions, reference it; otherwise, refer to the act in general terms.)
• To Communicate with You: We send confirmations, notifications, and updates related to your orders, ticket status, and prize draws. These communications are conducted in accordance with the Electronic Communications Act of Grenada, ensuring that digital communications are lawful and secure.
• To Enhance Our Website: Information collected through Google Analytics and Facebook Pixel is used to analyze how you interact with our Website and services. This is done in compliance with the GDPA to ensure data minimization and protection of user rights.
• To Conduct Prize Draws: We use personal data to verify participant eligibility, notify winners, and conduct live draw events on platforms like YouTube or Facebook. This process complies with the Gaming, Betting, and Lotteries Act (verify the specific section covering prize draws; otherwise, reference the act generally to maintain accuracy).
• For Legal Compliance: We process your data to comply with applicable legal obligations, such as tax reporting and anti-fraud measures, as outlined in the Fraud Prevention Act of Grenada. We also ensure regulatory compliance in accordance with Grenada’s Civil Liability Act, which governs liability and data protection regulations..

 

3. Legal Basis for Processing Your Data

We process your personal data based on several legal grounds:

 

• Contractual Obligation: We collect and process your personal data to perform and fulfill our contract with you when you purchase a ticket or participate in the prize draw.
• Legitimate Interests: We have a legitimate interest in processing your data to operate, manage, and improve our services, including marketing efforts and analysis. This is done in accordance with the Civil Liability Act of Grenada, which covers matters related to liability and commercial transactions, ensuring that our practices are lawful and balanced against your rights.
• Consent: We seek your explicit consent for marketing communications and the use of certain cookies when required by the GDPA. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
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4. Sharing of Your Information

We may disclose your personal information to third parties only as outlined below and in compliance with Grenadian law:

 

• Service Providers: We share data with WooCommerce for ticket sales, PayPal for secure payment processing, and Google Analytics and Facebook Pixel for marketing and analytics purposes, ensuring that all processors comply with the GDPA and relevant regulations.
• Social Media Platforms: When you engage with our social media accounts, those platforms may collect information under their own privacy policies. Please review their respective policies for more details.
• Legal and Regulatory Authorities: We may disclose your information where legally required to comply with regulations or to protect the rights and safety of Top Dog Raffle, our users, or others, in accordance with Grenadian consumer protection and electronic communications laws.

 

5. Use of Cookies and Tracking Technologies

Our Website uses cookies and other tracking technologies in compliance with the Electronic Communications Act of Grenada, Section 6, to improve your browsing experience. The types of cookies we use include:

 

• Essential Cookies: Required for the functioning of the Website, such as those used by WooCommerce to remember your shopping cart.
• Analytics Cookies: Google Analytics cookies help us track and analyze your interaction with our Website. This complies with data protection standards for lawful data processing.
• Marketing Cookies: Facebook Pixel cookies allow us to provide personalized advertising and measure marketing effectiveness.

You have the option to manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website.

 

6. Data Retention

In accordance with the GDPA, and the principles of Grenada’s Civil Liability Act, we retain your personal data only for the duration necessary to achieve the purposes for which it was initially collected. This includes fulfilling our contractual obligations, such as processing ticket sales, managing prize distributions, providing customer support, and ensuring the effective operation of our services. Additionally, we retain certain data to comply with statutory and regulatory obligations, such as accounting and tax requirements under Grenada’s Tax Code, where data may be retained for up to seven years or as required by law. We may also retain data to resolve disputes, enforce our agreements, or defend against legal claims in accordance with Grenada’s Civil Liability Act, which permits data retention for the protection of legal and statutory rights. Once the applicable retention period expires, or when the data is no longer necessary for these purposes, we will securely delete or anonymize it to prevent any possibility of re-identification, in full compliance with the GDPA‘s provisions to safeguard your privacy..

 

7. Data Security

We implement robust technical and organizational measures in compliance with the GDPA, ensuring that your personal data is protected from unauthorized access, alteration, disclosure, or destruction. These measures include encryption protocols (e.g., SSL/TLS) for secure data transmission, strict access controls, and advanced firewall and intrusion detection systems. Regular security audits, vulnerability scans, and penetration testing are conducted to proactively identify and mitigate potential risks, with regular backups and disaster recovery plans in place. Although we adhere to industry best practices, no platform can guarantee absolute security. In the event of a data breach, we will follow the notification requirements as outlined in the relevant sections of the GDPA, ensuring prompt communication to affected individuals and authorities.

 

8. Your Rights

Under the GDPA (Data Protection Act, No. 1 of 2023) and the Civil Liability Act of Grenada, you are afforded several rights concerning the personal data we collect and process. These rights are designed to empower you and ensure transparency, fairness, and accountability in our data processing activities. Below is a detailed explanation of each right:

 

• Right to Access (GDPA, Section 15): You have the right to request and obtain confirmation as to whether we are processing your personal data. Upon request, we will provide you with a copy of the personal data we hold about you, as well as details on how your data is being used, the purpose of processing, the categories of data processed, and any third parties with whom your data may be shared. We aim to fulfill such requests within the legally mandated time frame, usually within 30 days, unless an extension is necessary due to the complexity or volume of the requests.
• Right to Rectification (GDPA, Section 16): You have the right to request correction of any inaccurate or incomplete personal data we hold about you. We are legally obligated to take reasonable steps to verify the accuracy of your data and promptly make any necessary updates or amendments. If you believe any information we hold is incorrect or incomplete, please contact us to rectify the issue.
• Right to Erasure (Right to be Forgotten) (GDPA, Section 17): You have the right to request the deletion or removal of your personal data when there is no compelling reason for its continued processing. This right applies, for example, if the data is no longer necessary for the purpose for which it was collected, if you withdraw consent (where consent is the legal basis for processing), or if the data is processed unlawfully. We will comply with such requests, except where the data must be retained to comply with legal obligations, exercise or defend legal claims, or fulfill regulatory requirements.
• Right to Object (GDPA, Section 18): You have the right to object to the processing of your personal data when processing is based on our legitimate interests or those of a third party. This right also extends to objecting to processing for direct marketing purposes. If you raise an objection, we will cease processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your rights and interests or for the establishment, exercise, or defense of legal claims.
• Right to Data Portability (GDPA, Section 19): You have the right to request that your personal data be transferred directly to you or another data controller in a structured, commonly used, and machine-readable format. This right applies where the processing is based on your consent or a contractual obligation and the processing is carried out by automated means. We will ensure that such transfers are conducted in a secure manner and comply with legal and regulatory requirements.

 

Exercising Your Rights

To exercise any of the above rights, please contact us at [Insert Contact Email] with your request. We may ask for further information to verify your identity before fulfilling your request to ensure that your data is protected.

We will respond to all requests within one month of receipt, as stipulated by the GDPA. In certain circumstances, where requests are complex or numerous, we may extend this period by an additional two months; however, you will be informed of any such extension and the reasons for it.

If you feel that your rights under the GDPA have not been adequately addressed, you also have the right to lodge a complaint with the Data Protection Authority in Grenada or seek judicial remedy in accordance with the GDPA and the Civil Liability Act of Grenada.

 

Contact Information for Data Protection Requests:

• Email: [email protected]
• Mailing Address: Tanteen, PO Box 3454, St George, Grenada

By understanding and exercising your rights, you help ensure that your personal data is handled securely, transparently, and fairly in accordance with the highest standards of data protection.

 

9. Third-Party Links

Our Website may contain links to third-party websites, including social media platforms such as Facebook, X (formerly Twitter), Instagram, YouTube, and TikTok. These external websites operate independently of us, and we are not responsible for their privacy practices, content, or how they manage and protect your personal data. We strongly encourage you to review the privacy policies and terms of service of any third-party websites you access through our links to understand how they collect, use, and protect your information. Interacting with these platforms or any other third-party site is at your own discretion, and you should ensure you are comfortable with their policies before engaging with their content or services.

 

10. Live Draw Events

We may conduct live draw events on platforms like YouTube and Facebook. By participating in these events, you acknowledge that your information (such as your username or comments) may be visible to other participants and viewers, in accordance with the terms and privacy policies of those platforms. Please consult their policies for additional information on how they handle your data.

 

11. Changes to This Privacy Policy

We may revise this Privacy Policy periodically to reflect changes in our practices, technological advancements, or legal requirements, in compliance with Grenadian law. The updated version will be posted on our Website, with the “Effective Date” indicating the latest revision. Continued use of our Website after updates constitutes acceptance of the revised Privacy Policy.

 

12. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Grenada, West Indies, and complies with relevant provisions of the GDPA, the Civil Liability Act of Grenada (pertaining to legal liability matters), and other applicable statutes. Any disputes or claims arising out of or relating to this Privacy Policy shall be resolved exclusively by the courts of Grenada, and participants agree to submit to this jurisdiction

 

13. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

• Top Dog Raffle
• Mailing Address: Tanteen, PO Box 3454, St George, Grenada
• Email: [email protected]

• Effective Date: November 1, 2024

By using our Website, you confirm that you have read, understood, and agreed to this Privacy Policy and the data practices described herein.