Privacy Policy
Paragon (Scotland) Limited
Effective Date: 26th March 2026
Paragon (Scotland) Limited ("we", "us", "our") is the data controller for the purposes of applicable data protection law, including the UK GDPR and the Data Protection Act 2018. We are registered with the Information Commissioner's Office (ICO), reference ZC110710.
This Privacy Notice explains how we collect, use, and protect personal data in connection with our fundraising prize draw competition (the "Competition"), which is run in partnership with Race Against Dementia and promoted by Touchstone Wealth Limited on our behalf.
The Competition is open to both paying and free-entry participants. This Notice applies equally to all entrants regardless of how they enter.
1. Information We Collect
When you enter the Competition, we may collect the following personal data:
• Full name
• Email address
• Telephone number (optional)
• Postal address
• Method of entry (paid or free)
If you make a paid entry, we will also collect your donation amount. We only collect information that is strictly necessary to administer the Competition.
2. Lawful Basis for Processing
We process your personal data on the following legal bases:
• Contractual necessity – to administer your entry into the Competition, verify your eligibility, and contact you if you win.
• Legitimate interests – to ensure the Competition is operated fairly, transparently, and efficiently, and to fulfil our obligations to Race Against Dementia as our charitable partner. We have assessed that these interests are not overridden by your rights and freedoms.
We will not use your data for marketing purposes.
3. How We Use Your Information
We use your personal data strictly for the following purposes:
• To administer your entry into the Competition
• To select and verify the winner
• To contact the winner and arrange delivery of the prize
• To send essential communications relating to your entry
• To pass winner details to Race Against Dementia for the purpose of announcing or publicising the outcome, where applicable
We do not sell or rent your personal data to any third party.
4. Third Parties We Share Data With
We may share your personal data with the following third parties, only to the extent necessary:
• Crowdfunder – the platform used to host the Competition and process paid entries. Crowdfunder acts as a data processor on our behalf and is required to handle your data securely and in accordance with applicable data protection law.
• Race Against Dementia – our charitable partner. Winner details (name only, unless you consent to more) may be shared with Race Against Dementia for the purpose of acknowledging and publicising the Competition outcome.
• Touchstone Education Wealth Limited – the organisation promoting the Competition on our behalf. Touchstone does not independently control or retain your personal data.
• Legal and regulatory authorities – where we are required to do so by law.
All third-party processors are contractually required to process your data securely and only for the purposes we specify.
5. Data Retention
We will retain your personal data only for as long as is necessary:
• Entrant data will generally be deleted within 6 months of the Competition closing date, once the winner has been selected, contacted, and the prize fulfilled.
• Any data retained for legal, financial, or audit purposes will be kept only as long as required by law and stored securely.
6. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration. Where data is shared with third-party processors, we require equivalent standards of security.
7. Your Data Protection Rights
Under the UK GDPR, you have the right to:
• Request access to your personal data (a Subject Access Request)
• Request correction of inaccurate or incomplete data
• Request erasure of your data (the "right to be forgotten"), where applicable
• Object to or restrict processing in certain circumstances
• Data portability – to receive your data in a structured, machine-readable format where processing is based on contract
To exercise any of these rights, please contact us using the details in Section 9. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.
8. Changes to This Notice
We may update this Privacy Notice from time to time to reflect changes in law or our practices. Any updates will be published on the relevant fundraising page. We encourage you to review this Notice periodically.
9. Contact Details
If you have any questions about this Privacy Notice or the way your data is handled, please contact us:
Paragon (Scotland) Limited
Synergy House, Heaven’s Walk, Doncaster DN4 5HZ Email: info@paragonadminservices.co.uk