Privacy Policy

The Policy was last updated on January 2, 2026.

1. INTRODUCTION
   1. ALMAGROVE LTD, a company incorporated and registered in England and Wales under company number 03000668, having its registered office at 458 Wimborne Road, Bournemouth, Dorset, BH9 2EY, United Kingdom and whose contact email is hello@jambala.uk ("Almagrove Ltd", "Jambala", "Company", "we", "us", or "our"). The Company operates an interactive prize competition platform under the brand name Jambala, providing online competitions, draws, and related promotional services through its website and associated communication channels. Users, participants, and visitors (including those merely browsing the website) shall be referred to as "You", "Your", "Yourself", or "User", as the context may require, for the purpose of using the Website and the Services provided thereunder in accordance with this Privacy Policy and Our Terms of Use (as defined below).
   2. This Privacy Policy ("Policy") outlines Our practices and policies, the kinds of information that We may collect from You when You access or use the Website, the reasons and methods for such collection, how We use and disclose the information that We gather from You in connection with Your use of the Website and Services, as well as the security practices and procedures for safeguarding Your privacy in relation to the information shared with Us. You agree to be bound by the provisions of this Policy by accessing and using the Website and Services, which shall be deemed to create a legal contract between You and Us. It is recommended that You read and keep Yourself updated with any modifications to this Policy to ensure that You understand Our policies and practices.
   3. Unless otherwise defined in this Policy, all capitalised terms shall have the meaning ascribed to them in Our Terms of Use, accessible at https://jambala.co.uk/terms-and-conditions ("Terms of Use"), or in any other agreement that You may have entered into with Us. This Policy must be read together with, and forms an integral part of, Our Terms of Use, which collectively govern Your access to and use of the Website and Services.
   4. For the purposes of UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Almagrove Ltd is the data controller of the personal data described in this Policy. This Policy applies to personal data processed by Almagrove Ltd in connection with the operation of the Jambala prize competition platform and related services (the "Services") provided via the Website at https://jambala.co.uk, mobile applications, emails, social media pages, messaging platforms, and any other online or offline channels that We operate in relation to those Services (collectively, the "Website").
   5. This Policy shall be read in conjunction with, and construed in accordance with, the laws of England and Wales, including, without limitation, the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), and any other applicable data protection or privacy laws and guidance issued by the Information Commissioner's Office (ICO). This Policy forms a legally binding electronic agreement between Us and You, governing the processing and protection of Your personal data when You use Our Website or Services.
2. TYPES OF DATA WE COLLECT
   1. Information Provided To Us: We collect the information you voluntarily provide when you create an account, enter a competition, make a payment, or communicate with us. This may include:
      1. Identity and Contact Details: full name, date of birth (to confirm eligibility), email address, phone number, postal address, county and country of residence.
      2. Account Details: username, password, and other registration information.
      3. Payment and Billing Information: billing address and limited payment details (such as the last four digits of your card number or transaction ID).
      4. Communication Data: any correspondence you send us (by email, WhatsApp, social media, or other means) and your marketing preferences.
   2. Data Collected Automatically: When you visit or use our Website, certain information is collected automatically through cookies, analytics tools and similar technologies ("Trackers"). This may include:
      1. Technical Data: internet protocol (IP) address, browser type, operating system, device type, device identifiers and time zone.
      2. Usage Data: the pages you visit, features you use, time spent on the Website, and interactions with our communications (such as opening emails or clicking links).
      3. Advertising Identifiers: unique device IDs or cookies used for analytics and targeted advertising, managed in accordance with our Cookie Policy.
   3. Optional or Non-Mandatory Data: In some cases, we may ask for additional information (such as survey responses, feedback, or preferences) to help improve our Services. Providing this information is optional, and declining to do so will not affect your access to the core functionality of the Website.
   4. Accuracy of Information: You are responsible for ensuring that the personal information you provide to us is accurate, complete, and up to date. Failure to provide certain information may limit our ability to provide you with certain features of the Services.
3. NOTICE AND YOUR ACKNOWLEDGEMENT
   1. Acceptance of this Policy: By accessing or using Our Website and Services, You acknowledge that You have read and understood this Privacy Policy and agree to the collection, use, disclosure, and other processing of Your personal data as described herein. Your continued use of the Website constitutes Your acceptance of this Policy and any updates made from time to time.
   2. Lawful Bases for Processing: We collect and process Your personal data only for specific, lawful, and legitimate purposes. Each purpose is supported by one or more lawful bases under the UK GDPR and the Data Protection Act 2018.
      1. Account Creation and Management: To create, verify, and manage Your account, allow You to participate in Our prize competitions, and provide You with access to the Website and Services. Lawful basis: Performance of a contract.
      2. Payment Processing and Prize Fulfilment: To process Your payments, verify Your eligibility, communicate competition results, and fulfil prizes in accordance with Our Privacy. Lawful basis: Performance of a contract and compliance with legal obligations.
      3. Service Communications: To send You necessary service-related messages such as confirmations, notifications of competition entries, results, and updates to Our Terms or this Policy. Lawful basis: Performance of a contract or compliance with legal obligations.
      4. Improvement and Personalisation: To operate, maintain, improve, and personalise Our Website, Services, and user experience based on Your interactions and preferences. Lawful basis: Legitimate interests ensuring We deliver an effective, relevant, and user-friendly platform.
      5. Fraud Prevention and Legal Compliance: To protect the integrity of Our Website, detect and prevent fraudulent or illegal activity, verify age and identity, comply with anti–money laundering laws, and respond to lawful information requests. Lawful basis: Legal obligation and legitimate interests ensuring the safety, security, and compliance of Our operations.
      6. Marketing and Promotional Communications: To provide You with marketing information, newsletters, and promotional offers that may be of interest to You, in accordance with Your preferences. Lawful basis: Consent, or legitimate interests where permitted by law. You may opt out of receiving marketing communications at any time by clicking the "unsubscribe" link in Our emails or contacting Us directly.
      7. Customer Support and Enquiries: To respond to Your enquiries, handle complaints, or provide customer support related to the Website and Services. Lawful basis: Performance of a contract and legitimate interests ensuring efficient service and communication.
      8. Compliance and Protection of Our Rights: To comply with applicable legal and regulatory obligations, respond to court orders or lawful government requests, and protect or enforce Our rights, interests, and the safety of Our users. Lawful basis: Legal obligation and legitimate interests.
   3. The Rights of Users: Under the UK GDPR, You have the following rights in relation to Your personal data:
      1. Right of Access: You can ask Us whether We process Your personal data and request a copy of that information.
      2. Right to Rectification: You can request correction of any inaccurate or incomplete personal data We hold about You.
      3. Right to Erasure ("Right to be Forgotten"): You can ask Us to delete Your personal data in certain circumstances, such as when it is no longer needed for the purpose for which it was collected.
      4. Right to Restrict Processing: You can request that We temporarily suspend processing of Your personal data in specific situations.
      5. Right to Data Portability: You can request to receive Your personal data in a structured, commonly used, and machine-readable format and, where feasible, ask Us to transfer it to another controller.
      6. Right to Object: You can object to processing that We carry out based on Our legitimate interests and can object at any time to Your data being used for direct marketing.
      7. Right to Withdraw Consent: You can withdraw any consent You have previously provided. This will not affect the lawfulness of processing carried out before withdrawal.
      8. Right to Lodge a Complaint: You can raise concerns with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection.

      Website: www.ico.org.uk Telephone: 0303 123 1113

4. International Users: Our Website is operated from the United Kingdom and intended primarily for users located within the UK. If You access the Website from outside the UK, You do so at Your own initiative and are responsible for compliance with local laws where applicable.
5. MODE AND PLACE OF PROCESSING THE DATA
   1. Methods of Processing: We process personal data using secure systems and procedures designed to protect it from unauthorised access, alteration, disclosure or destruction. Processing is carried out by Our authorised personnel or by trusted third parties who provide technical, operational or support services to Us, such as IT, hosting, payment, or marketing partners. All such parties are bound by confidentiality and data protection obligations, and where they act as Our data processors, they do so under written agreements in compliance with the UK GDPR.
   2. Place of Processing: Personal data is processed primarily at Our offices in the United Kingdom and through Our secure servers. Some processing activities or support services may be performed by Our affiliates or service providers located in other jurisdictions, where data protection laws may differ from those in the UK. Where We transfer personal data outside the United Kingdom, We ensure that appropriate safeguards are in place such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses to provide an adequate level of protection for Your data.
6. DATA SHARING AND DISCLOSURE
   1. General Disclosure: We value Your privacy and do not sell, rent, or trade Your personal data. We only share personal data when it is necessary for the operation of Our Services, compliance with legal obligations, or the protection of Our legitimate interests, and always in accordance with the UK GDPR.
   2. Disclosure to Service Providers: We may share Your personal data with trusted third-party service providers who assist Us in delivering Our Services, including:
      1. IT infrastructure and hosting providers;
      2. Payment processors and fraud prevention partners;
      3. Customer support and communication tools;
      4. Marketing and analytics service providers (subject to Your consent, where applicable); and
      5. Professional advisers, such as auditors, legal counsel, and consultants.

      All such third parties are bound by contractual obligations to keep personal data secure and to use it only for the purpose of providing services to Us.

   3. Legal and Regulatory Disclosure: We may disclose personal data where required to comply with applicable laws, lawful requests, court orders or regulatory authorities.
   4. Business Transfers: In the event of a merger, acquisition, sale, or transfer of all or part of Our business or assets, Your personal data may be transferred to the acquiring entity. Any such transfer will be conducted in accordance with applicable data protection laws, and You will be notified of any material changes to how Your personal data is processed.
   5. Prize Draw Name Display: To demonstrate the transparency and legitimacy of Our prize competitions, We may publish or announce the winner's name and general location during live draws, on Our Website, or through Our official social media channels. Such disclosure is limited to what is necessary to ensure the fairness and credibility of the competition. If You wish to object to the publication of Your details, You may notify Us at hello@jambala.uk, and We will respect Your preference wherever legally permissible.
7. DATA SECURITY MEASURES
   1. Security Practices: We take the protection of Your personal data seriously and have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risks involved in processing such data. These measures are designed to protect against unauthorised or unlawful access, accidental loss, destruction or damage.
   2. Our Measures Include: We employ a combination of technical, organisational and physical safeguards designed to protect personal data from unauthorised access, alteration, disclosure or destruction. These measures are proportionate to the type of data We process, the nature of Our business operations, and the risks associated with processing. Our internal policies ensure that personal data is accessible only to authorised personnel who require it for legitimate business purposes and who are bound by confidentiality obligations. We regularly review and update Our security controls to maintain the integrity and security of Our systems. In the event that We engage third-party service providers who process personal data on Our behalf, they are contractually required to implement comparable security measures and to process such data only in accordance with Our instructions.
   3. Data Breach Notification: In the unlikely event of a personal data breach that poses a risk to Your rights and freedoms, We will notify the Information Commissioner's Office (ICO) and, where required, inform You without undue delay in accordance with Articles 33 and 34 of the UK GDPR.
   4. User Responsibility: While We take all reasonable precautions to protect Your data, You are responsible for keeping Your account credentials secure and not sharing Your password or other access information with others.
8. DATA RETENTION
   1. Retention Principle: We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to meet any legal, accounting, or reporting requirements, to resolve disputes and enforce Our agreements. When determining the appropriate retention period, We consider the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which We process the data, and any applicable legal or regulatory obligations.
   2. Data Deletion and Anonymisation: Once personal data is no longer required for these purposes, it is securely deleted, anonymised, or otherwise processed in a manner that prevents further identification of the individual. Where deletion is not immediately feasible, due to technical or backup constraints, the data will be securely stored and isolated from any further processing until it can be permanently removed.
   3. User Rights upon Deletion: You may request deletion of Your personal data at any time in accordance with Your rights set out under this Policy. However, We may retain certain limited information where necessary to comply with Our legal obligations or to establish, exercise, or defend legal claims.
9. COOKIES AND TRACKING TECHNOLOGIES

   This Website uses cookies and similar tracking technologies ("Cookies") to improve functionality, analyse traffic, and personalise content. Essential Cookies are necessary for the operation of the Website and cannot be disabled. Non-essential Cookies (such as analytics and advertising cookies) are used only with Your consent, which You can manage through Our cookie banner or browser settings. If You choose to disable Cookies, some parts of the Website may not function properly.

10. CHILDREN'S DATA

    Our Website and Services are not intended for use by individuals under the age of 18, and We do not knowingly collect or process personal data from anyone below this age. If You are a parent or legal guardian and believe that Your child has provided personal data to Us, please contact Us immediately at hello@jambala.co.uk, and We will take appropriate steps to delete such information from Our systems. Where age verification is necessary to confirm eligibility for participation in Our prize competitions or to award prizes, We may request acceptable proof of age or identity before granting access to certain Services.

11. CHANGES TO THIS POLICY

    We may amend or update this Privacy Policy from time to time to reflect changes in Our business practices, legal or regulatory developments or for any other operational reasons. Any material modifications will be communicated through appropriate means, which may include posting a notice on Our Website, updating the "last revised" date at the top of this Policy or notifying You directly where practicable. You are encouraged to review this Policy periodically to remain informed about how We collect, use, and protect Your personal data. Your continued use of the Website and Services following any such updates shall constitute Your acknowledgment and acceptance of the revised Policy.

12. DISCLAIMER AND LIMITATION OF LIABILITY
    1. While We implement reasonable and appropriate technical, organisational and physical security measures to protect Your personal data, no method of transmission over the internet or method of electronic storage is completely secure. Accordingly, We cannot guarantee absolute security of Your data.
    2. To the fullest extent permitted by applicable law, We shall not be liable for any indirect, incidental, special, consequential or punitive damages arising out of or in connection with any unauthorised access, disclosure, loss or alteration of personal data, except where such loss results from Our negligence, wilful misconduct or breach of Our legal obligations under applicable data protection laws.
13. CONTACT AND DATA PROTECTION ENQUIRIES

    If You have any questions about this Privacy Policy, wish to exercise any of Your rights, or have concerns regarding the processing of Your personal data, You may contact Us at:

    Data Protection Contact:

    Almagrove Ltd. (Jambala)

    458 Wimborne Road, Bournemouth, Dorset, BH9 2EY, United Kingdom

    Email: hello@jambala.co.uk

    We will respond to all legitimate requests within a reasonable period and in accordance with applicable data protection laws.