Personal Information Notice: Find The Golden Cocoa Bean promotional campaign - Palmer’s (ET Browne UK LTD)

1. Introduction

This notice sets out how E.T. Browne UK (“ETB”) uses, and protects, personal information, including information from participating in promotions organised by ETB and our partners.

The purpose of this notice

ETB uses and stores personal information for the following purposes to:

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you in advance and we will explain the legal basis allowing us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, only when required or permitted by applicable Law.

Our lawful basis for using and storing personal information are explained in more details below.


ETB is the Data Controller for personal information relating to people who have:


ETB will only disclose any personal information to organisations outside of ETB:

We may share your personal information with the parties set out below, to process as independent controllers or as processers on our behalf, for the purposes set out in this Personal Information Notice.

Specific third parties listed in the table below including, and for the purposes as listed in the table below:

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

2. Website visitors and people engaging with products, prizes, services or promotions

It is necessary for the products, services and promotions we provide to use and store personal information. We are also committed to transparency about how we use personal information and informing people of their rights in relation to the use and storage of personal information. More information about your rights is available at the end of this notice.

3. Your Privacy at A Glance

Purpose of the processing Relevant Personal Data Legitimate Basis Retention Period Recipient
To administer the prize draw to which you will participate, provide a product, prize or service you have requested
  • Identity Data
  • Contact Data
  • Technical Data
We have a contractual obligation 1 month from the Prize Draw end date MW-W Group Ltd
Switchstance Ltd
Cloud Nine Incentives Ltd
Richdomar Ltd
Maintain our own accounts and records;
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
  • Marketing and Communications Data
  • Usage Data
We have a legal obligation 1 month from the Prize Draw end date N/A
Fulfil our legal obligations
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
  • Marketing and Communications Data
  • Usage Data
We have a legal obligation 1 month from the Prize Draw end date N/A
Exercise our legal rights (including legal proceedings)
  • Identity Data
  • Contact Data
  • Technical Data
  • Profile Data
  • Marketing and Communications Data
  • Usage Data
We have a legitimate interest to exercise our rights 1 month from the Prize Draw end date N/A

4. Types of personal information and how it is collected:

We may collect and process the following personal information from you, which we have grouped as follows:

  1. Identity Data, which includes your first name, last name, date of birth, gender and photographs of identifiable individuals
  2. Contact Data, which includes your address, email address and telephone numbers
  3. Technical Data, which includes your IP address and your browser type
  4. Profile Data, which includes details of your interests, preferences and feedback
  5. Marketing and Communications Data, which includes your preferences in receiving marketing messages from us and our third parties and your communication preferences
  6. Usage Data, which includes information about how you use our website, products and services

The types of personal information we collect is provided to us directly by you for one of the following reasons:

5. Personal information - why we are collecting it and how it is used

Under the UK General Data Protection Regulation (“UK GDPR”), the lawful bases we rely on for collecting and processing your personal information are:

The personal information we hold on you will be used in different ways, including:

Specifically, we use your personal information we collect to carry out our business and to provide a service, product or promotion or carry out a contract with you:

6. Personal information - sharing and international transfers

We share information with partner organisations, which are involved in the products, prizes, services or promotions. In addition, we may have to share information with regulators such as the ASA or HMRC.

We do not transfer your personal data outside the UK and Ireland.

7. Personal information - storing

Your personal information is securely stored. To help ETB operate our service and meet our legal obligations, we will store personal information for 1 month after the date of the product, service or promotion for which the information was used and/or stored. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

8. Your rights

Under data protection law, you have the following rights:

Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them or they are not relevant.

No fee usually required

We do not charge a fee to give you access to your personal information or to exercise any of the other rights described above. We may, however, charge a reasonable fee if your request for access is clearly unfounded or excessive or we may refuse to comply with the request.

What we need from you

Where we hold reasonable doubt about your identity, we may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

11. Complaints

If you have any cause for concern about ETB’s or its partners handling of personal information, you have the right to make a complaint at any time with the national data protection authority, the ICO at We would, however, appreciate the chance to address your concerns before you approach such regulatory authority. Please contact us using the details below.

12. Contact details

E.T. Browne UK Ltd.
Unit 5, Loughton Business Centre
5 Langston Rd
[email protected]

ETB may modify this Personal Information Notice and you should therefore periodically visit this page to be sure that you have read and agree with our most current Personal Information Notice. If there are any substantial changes to Personal Information Notice, we will inform you of such changes. For further information, please see ETB’s Privacy Notice at We are not responsible for the content of external sites.

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