Sweepstakes Privacy Notice – United States
1. Who we are
This Sweepstakes Privacy Notice explains how SAS Confluent Digital (“Confluent Digital,” “we,” “us,” or “our”) collects, uses, discloses and protects personal information in connection with Sweepstakes operated through the top-sweepstakes website.
SAS Confluent Digital
Espace Wojo – Immeuble Silex
15 rue des Cuirassiers
69003 Lyon
France
Email: dpo@confluent-digital.com
For purposes of applicable European data protection law, including Regulation (EU) 2016/679 (“GDPR”), SAS Confluent Digital acts as the data controller for personal information collected directly through the Sweepstakes website.
2. Information we collect
We may collect:
- first and last name;
- email address;
- street address, city, state and ZIP code;
- telephone number;
- date of birth and eligibility information;
- Sweepstakes entry information;
- date and time of entry;
- IP address, browser, device and technical information;
- information used for security, fraud prevention and duplicate-entry detection;
- marketing consent and unsubscribe information; and
- applicable privacy choices and opt-out preference signals.
3. How we use your information
We use personal information to:
- administer the Sweepstakes;
- register and validate entries;
- verify age, residence and eligibility;
- prevent duplicate, fraudulent or automated entries;
- conduct the random drawing;
- contact and verify the potential winner;
- award the Prize;
- comply with applicable legal obligations;
- protect the security and integrity of the website; and
- where you have separately opted in, send marketing and promotional emails from SAS Confluent Digital.
Under applicable European data protection law, processing may be based, depending on the activity involved, on the administration of your requested participation in the Sweepstakes, compliance with legal obligations, our legitimate interests in maintaining the security and integrity of the Sweepstakes, or your consent.
4. Telephone number
Your telephone number is collected solely for Sweepstakes administration, eligibility verification, fraud prevention where applicable and potential winner contact.
SAS Confluent Digital does not use the telephone number collected through this Sweepstakes entry form for marketing calls or marketing text messages.
Providing your telephone number does not constitute consent to receive marketing calls or text messages.
5. Email marketing
Sweepstakes participation is separate from marketing.
Entering the Sweepstakes does not automatically subscribe you to marketing communications.
If you separately select the optional email marketing checkbox, SAS Confluent Digital may send you promotional emails, including emails containing offers relating to third-party products and services.
This consent authorizes marketing communications from SAS Confluent Digital only.
Your email address will not be provided to a third-party marketing partner for that partner to conduct its own direct marketing merely because you selected the Confluent Digital email marketing option.
You may unsubscribe at any time using the unsubscribe link contained in a marketing email or through our Your Privacy Choices page.
Refusing or withdrawing marketing consent will not affect your Sweepstakes entry or your chances of winning.
6. Optional partner offers
After you submit your entry, we may present optional partner offers. These offers are separate from the Sweepstakes, and declining them does not affect your entry or your chances of winning.
If you select a partner offer, you are taken to that partner’s website and the contact details you provided are shared with that partner so it can respond to your request. That partner then acts as an independent controller of the information it receives, and its own privacy policy applies to any further use, including any marketing it may send you.
Declining an offer shares nothing. We tell you which partner is concerned, and what is shared, on the page where the offer is presented — before you select it.
7. Who we may disclose information to
We may disclose information where reasonably necessary to service providers acting on our behalf, including providers of hosting, infrastructure, databases, security, fraud prevention, email delivery, analytics and Sweepstakes administration services.
We may also disclose information to professional advisers, courts, regulators or competent authorities where required or permitted by law.
Sweepstakes contact information is not disclosed to marketing partners for their own direct marketing merely because you entered the Sweepstakes or subscribed to Confluent Digital marketing emails. Disclosure to a partner occurs where you select that partner’s offer, as described in section 6 above.
8. International data processing
SAS Confluent Digital is established in France. Personal information collected through the Sweepstakes may therefore be processed in France and elsewhere within the European Economic Area.
Some service providers may process information in the United States or other countries.
Where required by applicable European law, appropriate international transfer mechanisms are used, which may include an adequacy decision, the EU-U.S. Data Privacy Framework for eligible organizations, or European Commission Standard Contractual Clauses.
9. Data retention
Sweepstakes entry and administration records may generally be retained for up to three years following the end of the Sweepstakes, unless a longer period is necessary to comply with applicable law, resolve a dispute or establish, exercise or defend legal claims.
Technical security and fraud-prevention records are generally retained for up to twelve months unless a longer period is reasonably necessary.
Marketing consent records may be retained for the duration of the relevant marketing relationship and for an appropriate period thereafter to demonstrate compliance.
Opt-out and suppression records may be retained for as long as reasonably necessary to ensure that your preference continues to be honored.
10. U.S. state privacy rights
Depending on your state of residence and applicable law, you may have rights concerning your personal information, including rights to access, correct or delete information, obtain a portable copy of certain information, and opt out of certain sales, sharing or targeted advertising.
You may exercise applicable rights through our Your Privacy Choices page or by contacting dpo@confluent-digital.com.
We will not unlawfully discriminate against you for exercising an applicable privacy right.
11. California privacy
Where SAS Confluent Digital is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), eligible California residents may exercise the rights provided by that legislation.
Where required by applicable law, SAS Confluent Digital recognizes qualifying opt-out preference signals, including Global Privacy Control (“GPC”).
12. European data protection rights
Because SAS Confluent Digital is established in France, processing carried out in the context of its establishment may also be subject to the GDPR.
Subject to applicable conditions, you may have rights to access, rectify or erase personal information, restrict processing, object to certain processing, obtain certain information in portable form and withdraw consent where processing is based on consent.
Requests may be submitted to dpo@confluent-digital.com.
You may also lodge a complaint with the French data protection authority, the Commission Nationale de l’Informatique et des Libertés (CNIL).
13. Security
We use reasonable administrative, organizational and technical measures designed to protect personal information from unauthorized access, loss, alteration, disclosure or misuse.
No Internet transmission or storage system can, however, be guaranteed to be completely secure.
14. Children
This Sweepstakes is not intended for individuals who do not satisfy the age requirements contained in the Official Rules.
We do not knowingly accept Sweepstakes entries from individuals who are not eligible because of their age.
15. Changes
We may update this Notice to reflect changes in applicable law or our practices.
The Effective Date above identifies the version applicable at the relevant time.
Material changes will be communicated where required by law.
16. Contact
SAS Confluent Digital
Attn: Data Protection Officer
Espace Wojo – Immeuble Silex
15 rue des Cuirassiers
69003 Lyon
France
dpo@confluent-digital.com