Fly with TingPrivacy Notice

1. Who We Are

BELIV LLC (“Beliv”, “we”, “us” or “our”), with correspondence address at 1511 Ave. Ponce de León, Ciudadela Suite 24, San Juan, 00923, Puerto Rico, is the organiser of the Fly With Ting Promotion (the “Promotion”).

For the purposes of applicable UK data protection legislation, including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, BELIV LLC acts as the data controller of the personal information collected and processed in connection with the Promotion.

It is important that you read this Privacy Notice so that you understand how and why we collect, use, disclose and protect your personal information.

2. Information We Collect

When you enter, participate in, win, or otherwise engage with the Promotion, we may collect and process the following categories of personal information:

• Full name;
• Email address;
• Telephone number (where provided);
• Postal address (where required for prize fulfilment);
• Age, date of birth, or age verification information;
• Promotional codes submitted as part of the Grand Prize Draw;
• Responses to promotional or sampling-related questions;
• Proof of eligibility, age, identity, residency or other verification information;
• Social media usernames or handles where relevant;
• Records relating to participation in the Promotion;
• Communications between you and the Promoter;
• Photographs, video recordings, testimonials, statements, biographical information and other publicity materials where collected in connection with the Promotion.

We may also collect information necessary to investigate suspected fraud, duplicate registrations, abuse of the Promotion, or violations of the applicable Terms and Conditions.

3. How We Use Your Information

We may process your personal information for the following purposes:

Promotion Administration

To organise, administer and operate the Promotion, verify eligibility, validate entries, prevent fraud, identify duplicate registrations, conduct prize draws and communicate with entrants.

Lawful Basis: Legitimate Interests (Article 6(1)(f) UK GDPR).

Prize Fulfilment

To verify winners, administer prizes and arrange prize fulfilment.

Lawful Basis: Performance of a Contract (Article 6(1)(b) UK GDPR).

Promotion Security and Fraud Prevention

To detect, investigate and prevent fraudulent activity, duplicate entries, abuse of the Promotion or violations of the Terms and Conditions.

Lawful Basis: Legitimate Interests (Article 6(1)(f) UK GDPR).

Publicity and Promotional Activities

Where winners participate in publicity, interviews, promotional content, marketing campaigns, photographs, videos, testimonials or similar activities relating to the Promotion, Ting products, Beliv brands or related promotional activities.

Lawful Basis: Consent and/or other lawful basis available under applicable law.

Such use may continue after the Promotion has ended, subject to the terms agreed with the participant and applicable data protection laws.

Compliance with Legal Obligations

To comply with applicable laws, regulations, court orders, regulatory requirements and legal processes.

Lawful Basis: Compliance with Legal Obligations (Article 6(1)(c) UK GDPR).

4. Sharing of Information

We may share your personal information with:

• Marketing and promotional agencies assisting with the Promotion;
• Promotion administration providers;
• Information technology, software and hosting providers;
• Cloud service providers;
• Prize suppliers;
• Travel providers involved in administering the £1,000 flight voucher prize;
• Gift card suppliers and fulfilment providers;
• Professional advisers, auditors and legal advisers;
• Regulatory authorities, courts or governmental bodies where required by law.

We will only share personal information to the extent necessary for the purposes described in this Privacy Notice.

5. International Transfers

Your personal information may be transferred to, accessed from, processed or stored outside the United Kingdom, including in the United States of America, where the Promoter, its affiliates, cloud service providers, hosting providers, contractors or service providers maintain operations, infrastructure or systems.

Whenever we transfer personal information internationally, we implement appropriate safeguards designed to protect your information in accordance with applicable data protection laws. Such safeguards may include:

• the UK Extension to the EU-US Data Privacy Framework (where applicable);
• International Data Transfer Agreements (IDTAs);
• Standard Contractual Clauses; or
• other legally recognised transfer mechanisms.

6. Storage and Security

We implement reasonable technical, organisational and administrative safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, misuse or access.

However, no transmission of information over the internet or electronic storage system can be guaranteed to be completely secure.

7. Retention of Information

We will retain personal information only for as long as necessary to:

• administer the Promotion;
• verify eligibility;
• award and fulfil prizes;
• administer publicity activities;
• resolve complaints or disputes;
• comply with legal, regulatory, tax and accounting obligations; and
• protect or enforce our legal rights.

Once personal information is no longer required, it will be securely deleted, anonymised or otherwise disposed of in accordance with our retention practices.

8. Keeping Your Information Accurate

You are responsible for ensuring that the personal information you provide is accurate, complete and up to date. Please inform us if your information changes during the Promotion.

9. Your Rights

Subject to applicable law, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Request deletion of your personal information;
• Request restriction of processing;
• Object to certain processing activities;
• Request portability of your personal information;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with the Information Commissioner’s Office (ICO).

Information about your rights is available from the Information Commissioner’s Office at ico.org.uk. You may lodge a complaint with the ICO through ICO Complaints.

10. Access Requests and Verification

We may request additional information to verify your identity before responding to any request concerning your personal information. This helps us ensure that personal information is disclosed only to authorised persons.

We will normally respond to valid requests within one month, although this period may be extended where permitted by law.

11. Information Relating to Third Parties

You should not provide us with personal information relating to another person unless:

• you have informed them of this Privacy Notice; and
• you have obtained any permissions required under applicable law.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Any material changes will be published through the relevant Promotion channels or otherwise notified where appropriate.

13. Contact Us

If you wish to exercise your privacy rights, update your information, withdraw consent, or contact us regarding this Privacy Notice, please contact:

Privacy Contact Email: info@lovemyting.com
General Promotion Contact Email: info@lovemyting.com

BELIV LLC
1511 Ave. Ponce de León
Ciudadela Suite 24
San Juan, 00923
Puerto Rico