Privacy Policy

This policy explains what personal data we collect when you use our website, enter our competitions or get in touch with us. It also covers how we use that data, who we share it with and your rights under UK data protection law.

Who we are

Tramway Path is the trading name of TRWP LTD, a company registered in England and Wales under company number 14803417. Our registered office is 5 Brayford Square, London, E1 0SG.

We are the data controller for the personal data described in this policy, which means we decide how and why it is used.

If you have any questions about this policy or your data, email contact@tramwaypath.co.uk.

The data we collect

When you create an account or enter online: your name, email address, postal address, telephone number and date of birth. We also hold your order history, ticket numbers, subscription details and any site credit on your account.

When you enter by post: the details you write on your postcard. These are your name, address, email address, telephone number and date of birth.

When you pay: payments are handled by our payment providers, including PayPal. We see confirmation that your payment went through and limited details such as the card type. We never see or store your full card number.

When you get free scratch cards: the cards you’ve been sent, their results, and any cash or site credit you’ve won. If you claim a cash prize, you give your bank details or PayPal email address directly to our payout provider, fumopay. We don’t store them.

If you win: proof of identity, such as a copy of your passport or driving licence. We may also ask for evidence that the payment card used for your entry was yours or used with permission. For the Grand Prize, we collect the details our solicitors need to transfer the property or the property fund.

To keep play safe: your spending and how often you enter. We also hold the payment methods on your account, any declined payments, any spending limit or break you’ve asked for, and anything you tell our team about your circumstances. If you share something sensitive, such as information about your health, we will only use it to support you and protect your account.

When you contact us: your messages, any complaints and our replies.

When you browse: information about your device and how you use the site, collected through cookies and similar technologies. See the Cookies section below.

Marketing preferences: whether you’ve signed up to our emails and whether you’ve opted out.

How we use your data, and our lawful basis

UK data protection law says we need a lawful basis for each way we use your data. Here is what we use it for and the basis we rely on.

Running the competitions and your account. We use your data to process your entries and subscriptions and to issue ticket numbers. We also use it to send your tickets and scratch cards, run the draws, and award and deliver prizes. Basis: to perform our contract with you.

Checking age and identity, preventing fraud and meeting our legal duties. This covers age verification at checkout, verifying winners, keeping financial records and responding to lawful requests. Basis: legal obligation, and our legitimate interest in preventing fraud and abuse.

Protecting players. This covers spending limits, monitoring for signs of harm and honouring breaks and account closures, as set out on our Compliance page. Basis: our legitimate interest in running safe competitions in line with the Voluntary Code of Good Practice for Prize Draw Operators.

Announcing winners.

  • For our weekly giveaways, we publish the winner’s first name, the initial of their surname, their town and the winning ticket number.
  • For the Grand Prize, we publish the winner’s name and town on our website and social media.
  • Any further publicity, such as photos or interviews, only happens if the winner agrees.

Basis: to perform our contract with you, as set out in our terms and conditions, and our legitimate interest in showing our draws are genuine.

Answering questions and complaints. Basis: our legitimate interest in helping you, and our contract with you where it relates to an order.

Sending marketing emails about competitions, offers and winners. Basis: your consent. If you’re an existing customer and didn’t opt out when you bought from us, we may also email you about similar competitions. You can unsubscribe at any time using the link in every email.

Understanding and improving our site and advertising. This covers analytics, customer surveys and measuring how our ads perform. Basis: your consent for non-essential cookies, and our legitimate interest in improving our service.

Who we share your data with

We don’t sell your personal data. We only share it with organisations that help us run Tramway Path, and only what they need to do their job:

  • Shopify, which hosts our website and store and processes orders
  • Payment providers, including PayPal, to take payments
  • fumopay, our payout provider, to pay cash prizes won on scratch cards
  • PrizeShark, our prize fulfilment partner, which arranges some Mini Weekly Giveaway prizes and may contact winners from tramwaypath@prizeshark.com
  • Our solicitors, to transfer the Grand Prize property or property fund to the winner
  • Email, survey and customer service providers, to send your tickets, scratch cards and any emails you’ve signed up to, and to ask for your feedback
  • Review platforms such as Trustpilot, to invite you to leave a review
  • Age and identity verification providers, to confirm you are 18 or over
  • Advertising and analytics partners such as Meta and TikTok, where you’ve agreed to cookies
  • Professional advisers, regulators, law enforcement and fraud prevention agencies, where the law requires it or to prevent fraud

Random.org generates our winning numbers, but it never receives your personal data.

International transfers

Some of our providers, including Shopify, process data outside the UK. When that happens, we make sure appropriate safeguards are in place. These include UK adequacy regulations or the ICO’s International Data Transfer Agreement or Addendum.

How long we keep your data

  • Orders, entries and payment records: six years from the end of the financial year they relate to, as required for tax and accounting.
  • Account details: for as long as your account is open. If you close it, we keep only what we need for the reasons in this list.
  • Breaks, closures and spending limits: for as long as we need to honour them, so an account can’t be reopened or a limit lifted in error.
  • Winner verification documents: only as long as we need to verify you and award the prize, plus any period the law requires.
  • Postal entries: until the competition and any related complaints are complete. They are then securely destroyed.
  • Marketing: until you unsubscribe. We then keep your email address on a suppression list so we don’t contact you again.

Your rights

Under UK data protection law you have the right to:

  • ask for a copy of the personal data we hold about you
  • ask us to correct anything that’s wrong or incomplete
  • ask us to delete your data where we no longer have a reason to keep it
  • ask us to restrict how we use your data
  • object to how we use your data where we rely on legitimate interests
  • object to direct marketing at any time, and we will stop
  • ask for a copy of the data you’ve given us in a format you can pass to someone else
  • withdraw your consent at any time, where we rely on consent

To use any of these rights, email contact@tramwaypath.co.uk. We will reply within one month, and there is usually no charge. We may need to check your identity first.

Automated decisions

Winners are chosen at random using Random.org, and scratch card results are randomly pre-assigned when each card is issued. Neither involves any assessment of you. Our player protection checks may flag an account automatically, but any decision to restrict or pause an account is made by our team.

Age

Our competitions and scratch cards are for people aged 18 or over. We don’t knowingly collect data from anyone under 18. If we find we have, we will delete it unless the law requires us to keep it.

Cookies

We use cookies and similar technologies to make the site work, remember your basket and keep you signed in. With your consent, we also use analytics and advertising cookies to understand how people use the site and to measure our ads.

You can change your choices at any time through our cookie banner or your browser settings. Essential cookies can’t be switched off, because the site won’t work without them.

Keeping your data secure

Our website runs on Shopify, and payments are encrypted and handled by our payment providers. We limit access to personal data to the people who need it to do their job.

Complaints

If you’re unhappy with how we’ve handled your data, please email us first at contact@tramwaypath.co.uk so we can try to put it right.

You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113.

Changes to this policy

We will update this page if anything changes and show the date of the latest version at the top.