Privacy Policy

1. Introduction

Welcome to Pick a Winner. This Privacy Policy explains how we collect, use, and protect your information when you use our service. Pick a Winner is operated from the Republic of North Macedonia and is the data controller for the account-holder data described in this Policy; the controller/processor split for contest-participant data is described in Section 15. You can reach us through the Support Channel described in Section 13.

2. Information We Collect

We collect the following types of information:

• Account information: your email address and password when you create an account.
• Facebook data: when you connect your Facebook account, we access your Facebook Pages and contest post data to enable winner selection. We do not store Facebook user passwords.
• Payment information: when you purchase a tier upgrade or pay a contest fee, our payment processor (Lemon Squeezy) collects and processes your payment details on our behalf. We do not store your full payment card numbers; we retain transaction records (such as order identifier, amount, and date) for financial and legal compliance.
• Usage data: standard server logs including IP addresses, browser type, and pages visited.

3. Google AdSense and Cookies

This site uses Google AdSense to display advertisements. Google AdSense uses cookies and similar technologies to serve ads based on your prior visits to this and other websites.

Google's use of advertising cookies enables it and its partners to serve ads to you based on your browsing patterns. You may opt out of personalized advertising by visiting Google Ads Settings. Alternatively, you can opt out of third-party vendor cookies for personalized advertising at www.aboutads.info.

When you first visit the Service, a cookie consent banner lets you accept or reject non-essential cookies. Your choice is stored in a cookie named "cookie_consent" for 365 days and controls four categories: analytics storage, advertising storage, advertising user data, and advertising personalization. If you reject, only non-personalized advertisements are shown and analytics and advertising storage are withheld; if you have not yet made a choice, advertisements run in a limited, non-personalized mode. Essential cookies required for sign-in and your locale preference are always set and are not affected by this choice. You can change your decision at any time by clearing the "cookie_consent" cookie.

4. How We Use Your Information

• To provide and maintain the contest management service.
• To authenticate your identity and manage your account.
• To display relevant advertisements via Google AdSense.
• To improve our service based on usage patterns.

5. Data Sharing

We do not sell your personal information. We share data only with the service providers necessary to operate the Service:

• Facebook/Meta: to access your Pages and contest data via their API.
• Google AdSense: advertising cookies are set by Google to serve and personalize ads.
• Google Analytics: to measure how visitors use the site, subject to your cookie consent choice.
• Lemon Squeezy: to process tier-upgrade and contest-fee payments.
• Hosting and email providers: our hosting provider stores the Service's data, and our email delivery provider sends transactional and winner-notification emails. A fuller list of sub-processors appears in Section 15.

6. Data Retention

We retain your account and contest data for as long as your account is active. When you delete your account, we anonymize rather than erase certain records: your name and email are replaced with placeholder values, contest entries and audit records are stripped of identifying details, and payment records are retained only in anonymized form as required by law. You may request deletion of your account and associated data at any time by contacting us. In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify you without undue delay through your account email and, where required, notify the relevant supervisory authority within the timeframes prescribed by law.

7. Your Rights

You have the right to:

• Access the personal data we hold about you.
• Request correction or deletion of your personal data.
• Opt out of personalized advertising via the links in Section 3.
• Withdraw your Facebook connection at any time through your Profile settings.

8. Google Analytics

This site uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses cookies to analyse how visitors use the site. The data collected (including your IP address) is transmitted to and stored by Google. We use this information to evaluate website usage, compile reports, and improve our service. You may opt out by installing the Google Analytics Opt-out Browser Add-on.

9. Children's Privacy

Pick a Winner requires every account holder to be at least 18 years old (or the age of legal majority in their jurisdiction, whichever is greater), and the Service is not directed at minors. We do not knowingly collect personal information from anyone under 18. Contest participants' data is collected by contest organizers, who are responsible for compliance with children's privacy laws such as the Children's Online Privacy Protection Act (COPPA) where applicable. If you believe we have inadvertently collected a minor's personal data, please contact us and we will delete it promptly.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own. By using the Service, you consent to the transfer of your information to countries that may have different data protection rules than your country of residence.

11. Your Rights Under GDPR (EEA Users)

If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right of access — request a copy of your personal data.
• Right to rectification — request correction of inaccurate data.
• Right to erasure — request deletion of your personal data.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing of your personal data.
• Right to restrict processing — request limitation of how we use your data.
• Right to lodge a complaint — lodge a complaint with your local data protection supervisory authority.

Our lawful basis for processing your data includes: your consent (for cookies and advertising), contractual necessity (to provide the Service), and legitimate interest (to improve and secure the Service).

12. Your Rights Under CCPA (California Residents)

If you are a California resident, you have the right to: know what personal information we collect and how it is used, request deletion of your personal information, opt out of the sale of personal information (we do not sell personal data), and not be discriminated against for exercising your rights. To exercise these rights, contact us at the email address below.

13. Contact Us

If you have any questions about this Privacy Policy, your personal data, or wish to exercise any of your rights, please contact our Support Channel: goran@pickawinner.pro or arsphy@yahoo.com. Per EULA §31.1, the two addresses are treated as a single contractual contact channel — sending your request to either address is sufficient.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.

15. Data Controller and Data Processor Roles (Contest Participant Data)

When you run a giveaway through Pick a Winner, two distinct data-processing roles arise. This section clarifies who is responsible for what, and where contest participants should send data-rights requests.

You are the data controller for the participant data collected through your contest — including commenter names, profile IDs, comment text, timestamps, message tags, and any email addresses voluntarily included in comments. You decide the purpose of processing (running your giveaway) and the means (the eligibility rules you configure).

Pick a Winner is a data processor on your behalf for that participant data. We process participant data only in accordance with your instructions, as expressed through your use of the Service, and we do not process it for our own independent purposes. (For account-holder data — your email, name, payment history, etc. — Pick a Winner is the data controller; that processing is covered by Sections 2–14 above.)

Participant data-rights requests

Where a contest participant or other data subject wishes to exercise rights of access, rectification, erasure, restriction, portability, or objection under the GDPR, the UK GDPR, the CCPA, or other applicable law over data processed through one of our contests, that request must be directed to the contest organizer as the controller. The organizer is the Facebook Page or Instagram account that ran the giveaway. Pick a Winner cannot evaluate or respond to participant data-rights requests directly; where such a request reaches us, we may, at our discretion, forward it to the relevant organizer or decline to engage with it. As processor, we will provide reasonable assistance to organizers in responding to legitimate participant requests, insofar as the relevant data is held within the Service and the assistance is technically feasible.

Data Processing Agreement (Article 28 GDPR)

A separate Data Processing Agreement satisfying Article 28(3) GDPR is available on written request to our Support Channel (goran@pickawinner.pro or arsphy@yahoo.com) by any account holder who is established in, or processes personal data of subjects in, the EU, EEA, or UK, or who is otherwise subject to mandatory processor-agreement requirements under applicable law. Once executed, the DPA supplements this Privacy Policy and the EULA; in the event of conflict regarding the processing of participant Personal Data, the DPA controls.

Sub-processors. To deliver the Service, we use third-party sub-processors including Render (hosting), Lemon Squeezy (payments), Meta Platforms (Facebook & Instagram Graph APIs), Google (AdSense, Analytics, Fonts), and our email delivery provider. We maintain responsibility for their compliance with data-processing obligations consistent with the EULA.