John Varvatos Game of Thrones Contest - United Kingdom Data Terms 
 
These United Kingdom Data Terms (“UK Terms”) apply to personal data (as more particularly described under applicable privacy laws of the United Kingdom and the European Union, “Personal Data”) collected, processed or stored by John Varvatos Enterprises, Inc. (together with its subsidiaries referred to as “John Varvatos”, “we”, “our”, or “us”) in connection with the John Varvatos Game of Thrones Contest (together with all related services thereto, the “Contest”) with respect to any United Kingdom-based entrants in the Contest (“Entrants”, “you”, or “your”). In accordance with Section 15 of the Official Rules of the Contest, these UK Terms further describe how your Personal Data is collected and how we use this information in connection with the Contest. 
 
Please be advised that these UK Terms do not necessarily reflect our practices with respect to information gathered in connection with any other services that we provide; these UK Terms relate solely to Personal Data of Entrants. These UK Terms are incorporated into, and are made a part of, the Privacy Policy available at https://www.johnvarvatos.com/Legal_PrivacyPolicy.html (“Privacy Policy”). To the extent that there is a conflict or inconsistency between these UK Terms and the Privacy Policy, the Privacy Policy will govern except solely to the extent required by applicable law, in which case these UK Terms will govern. Any capitalized terms that are not defined in these UK Terms will have the meanings ascribed to them in the Privacy Policy. 
 
1. GENERAL 
 
Entrants may have certain additional privacy rights, such as the right to file a complaint with data protection regulators, and the Information Commissioners’ Office (“ICO”). You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. With respect to your Personal Data, you have the following rights: 
 
a. Access, correction or deletion: you can request a copy of your Personal Data; if the Personal Data held is inaccurate, you have the right to have it corrected; and you have the right to have your Personal Data deleted in certain circumstances. b. Restrict processing or transfer Personal Data: in limited circumstances, you have the right to request that processing is stopped but your Personal Data is retained. You can request a copy of your Personal Data in a machine-readable form that can be transferred to another provider. c. Objection: in certain circumstances (including where Personal Data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing. d. Automated decision making: in some instances, our use of your Personal Data may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you. When we make an automated decision about you, you have the right to contest the decision, to express your point of view, and to require that a human review the decision. 
 
2. LEGAL BASIS FOR PROCESSING PERSONAL DATA 
 
The following chart describes our legal basis, in each instance, for processing Entrants’ Personal Data: 
 
- Purpose for which data is used                           

To administer, fulfill, coordinate and support the Contest 

Data 

Name, photo, physical address, email address, age, phone number, Instagram handle

Legal basis 

Contractual necessity 

- Purpose for which data is used   

To verify compliance with Contest rules, your identity and to prevent fraud 

Data 

Any data contained in Contest documentation that you submit 

Legal basis 

Legitimate interests – it is in our legitimate interests to ensure that entries and submissions to the Contest are not made in violation of the Contest rules 

- Purpose for which data is used 

To send you marketing information about our offers and services 

Data 

Email address, phone number, Instagram handle 

Legal basis 


Legitimate interests – it is in our legitimate interests to promote our products and services 

- Purpose for which data is used 


To promote, market and publicize the Contest and your submissions

Data  

Photo, email address, Instagram handle 

Legal basis 

Legitimate interests – it is in our legitimate interests to promote our Contest and Entrants’ submissions in order to promote our products and services 
 
3. TRANSFER OF PERSONAL DATA TO THE UNITED STATES 
 
You acknowledge that we are a United States-based business with international locations. By providing Personal Data in connection with the Contest, you understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories. 
 
 
Effective March 13, 2019.