BE HEMPY – MASTER GIVEAWAY RULES AND GDPR

Version 1.0
Organiser: Grail Herbs d.o.o.

This document represents the overarching framework for conducting Be Hempy giveaways.

It consists of:

1. General Rules for Be Hempy Giveaways
2. Personal Data Processing Notice
3. Template for the Special Terms of an Individual Giveaway
4. Standard Text for the Entry Form

1. GENERAL RULES FOR BE HEMPY GIVEAWAYS
2. Organiser

The organiser of Be Hempy giveaways is:

Grail Herbs d.o.o.
Obrtna cesta 22
1291 Škofljica
Slovenia

Email: info@be-hempy.si

Website: www.be-hempy.com

V nadaljevanju: organizator.

2. Purpose of the Rules

These general rules set out the basic conditions for participation in giveaways organised by Be Hempy or Grail Herbs d.o.o.

Special terms published for each individual giveaway also apply.

The special terms specify in particular:

• the name of the giveaway,
• the duration,
• the method of participation,
• any restrictions on participation,
• the prize or prizes,
• the method of selecting the winner,
• the selection date,
• the method of notification, and
• the deadline and method for claiming the prize.

If the special terms of an individual giveaway differ from these general rules, the special terms apply to that giveaway, provided they comply with applicable legislation.

3. Who May Participate?

Unless otherwise specified for an individual giveaway, natural persons with permanent or temporary residence in the Republic of Slovenia who meet the conditions of the specific giveaway may participate.

For giveaways intended only for adults due to the nature of the prize, products or other reasons, only persons aged at least 18 may participate.

The organiser may set additional restrictions in the special terms of an individual giveaway.

As a rule, persons directly involved in organising or carrying out a specific giveaway may not participate if this could affect the fairness of the selection.

4. Method of Participation

The method of participation is specified for each individual giveaway.

Participation may take place, among other ways:

• via a form on the website,
• by email,
• via Facebook,
• via Instagram,
• via other social networks,
• via a dedicated landing page,
• by answering a question,
• by carrying out another clearly defined action.

The participant must meet the conditions stated for the specific giveaway.

Unless stated otherwise, participation is free of charge and is not conditional on a purchase.

5. Duration of the Giveaway

The start and end of each individual giveaway are specified in the special terms.

Entries or participation received after the deadline will not be considered unless the organiser expressly specifies otherwise.

6. Prizes

The type, quantity and, where necessary, value of the prizes are specified in the special terms of each individual giveaway.

As a rule, prizes:

• cannot be exchanged for cash,
• cannot be requested in another form,
• cannot be exchanged for another prize,

unless the organiser specifies otherwise for an individual giveaway.

Due to objective circumstances, the organiser may replace a prize with another prize of comparable or greater value if the original prize cannot be provided for reasons beyond the organiser’s reasonable control.

7. Selection of Winners

The method of selecting winners is specified in the special terms of each individual giveaway.

Selection may be carried out:

• by random draw,
• on the basis of a correct answer,
• by selection by a committee,
• on the basis of predetermined criteria,
• by another transparently defined method.

The organiser may prepare an internal record or other appropriate evidence of the selection process.

8. Notification of the Winner

The organiser may notify the winner via:

• email,
• telephone,
• a private message on a social network, or
• another channel specified in the special terms.

Within the deadline specified in the special terms, the winner must provide the data required to verify eligibility and to claim or receive delivery of the prize.

If the winner does not respond within the specified deadline, the organiser may consider that the winner does not wish to claim the prize and may select an alternate winner if this is provided for in the special terms.

9. Publication of Winners

If the organiser publicly publishes a winner’s data, participants will be clearly informed in advance in the rules or the personal data processing notice, and an appropriate legal basis will be ensured.

Only the minimum amount of data necessary for the purpose of publication will be published.

Without an appropriate legal basis, the organiser does not publish data such as:

• residential address,
• telephone number,
• email address,
• tax number, or
• other data that is not necessary for publishing the winner.

10. Claiming and Delivery of the Prize

The method of claiming the prize is specified for each individual giveaway.

The prize may be:

• sent by post,
• collected in person,
• delivered electronically, or
• handed over in another agreed manner.

The winner must provide the organiser with the data objectively necessary to deliver the prize.

11. Tax Obligations

If tax or other legal obligations arise due to the type or value of the prize, the organiser and the winner shall act in accordance with applicable regulations.

The organiser may request from the winner the data required to fulfil legal or tax obligations.

Such data is not requested from all participants unless necessary, but generally only from the winner when required.

12. Irregularities and Abuse

The organiser reserves the right to exclude participation if it determines:

• the use of false data,
• automated or mass manipulation of entries,
• fraud,
• a breach of the giveaway rules,
• another attempt to influence the fairness of the selection.

The decision must be based on reasonable and verifiable grounds.

13. Amendment or Termination of the Giveaway

In the event of circumstances that could not reasonably have been foreseen or prevented, the organiser may amend, temporarily suspend or cancel the giveaway.

The organiser will inform participants of material changes in an appropriate manner.

Changes must not unjustifiably interfere with rights already acquired by participants.

1. PERSONAL DATA PROTECTION – GDPR
2. Data Controller

The data controller is:

Grail Herbs d.o.o.
Obrtna cesta 22
1291 Škofljica
Slovenia

Email: info@be-hempy.si

15. What Personal Data Do We Collect?

The scope of the data depends on the individual giveaway.

We may process:

• first and last name,
• email address,
• telephone number,
• username or social-network profile,
• an answer or other content required for participation,
• participation data,
• data required to demonstrate the proper conduct of the giveaway.

From the selected winner we may additionally obtain:

• delivery address,
• data for identity verification,
• tax or other data where required by law.

Be Hempy’s principle is that data needed only for delivery of the prize is generally not requested from all participants at the time of entry.

16. Purpose of Processing

We may process personal data for:

1. Conducting the Giveaway

This includes:

• receiving and recording entries,
• verifying participation conditions,
• conducting the selection or draw,
• preventing abuse,
• notifying winners,
• handing over or delivering the prize,
• demonstrating the correctness of the procedure,
• handling any questions or claims.

1. Compliance with Legal Obligations

Where necessary, we use data to comply with tax, accounting or other legal obligations.

1. Direct Marketing and E-Newsletters

Where consent is the appropriate legal basis and the individual gives it, Be Hempy may use their data to send:

• e-newsletters,
• useful and educational content,
• product information,
• special offers,
• promotions,
• new giveaways,
• webinars,
• guides,
• tests and other Be Hempy content.

At Be Hempy, the default model is that such marketing consent is separate from participation in a giveaway, unless the special terms of a specific giveaway clearly and lawfully provide otherwise.

17. Legal Bases

The legal basis depends on the specific purpose of processing.

The organiser ensures an appropriate legal basis in accordance with Article 6 of the GDPR and other applicable legislation.

For individual processing activities, the following in particular may apply:

• the individual’s consent,
• processing necessary for carrying out the relationship or giveaway,
• compliance with a legal obligation,
• the organiser’s legitimate interests, where the relevant conditions are met.

The specific legal basis and purpose must be presented to the individual clearly and transparently.

18. Marketing Consent

If direct marketing is carried out on the basis of consent, that consent must be:

• clear,
• specific,
• informed,
• unambiguous,
• demonstrable.

Where marketing consent is not a condition of an individual giveaway, refusal to consent to e-newsletters does not affect the possibility of participating.

Consent may be withdrawn at any time.

Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

19. How Long Do We Retain Data?

We retain participants’ data only for as long as necessary to conduct and conclude the giveaway and for a period reasonably necessary to demonstrate proper conduct or address potential claims.

Winners’ data may be retained for longer where required by tax, accounting or other regulations.

Data used for direct marketing, where processing is based on consent, is used until the consent is withdrawn or for as long as an appropriate legal basis exists.

For each specific giveaway, the organiser sets more precise retention periods where necessary.

20. Who Has Access to the Data?

Personal data is not sold.

Contracted processors or service providers may access the data to the extent necessary to provide services, including:

• web-hosting providers,
• information-system providers,
• email communication system providers,
• giveaway service providers,
• delivery services,
• accounting and tax service providers.

Data may also be disclosed to competent authorities where required by law.

21. Transfers of Data to Third Countries

If providers used in conducting a giveaway or marketing activities may result in the transfer of personal data outside the European Economic Area, the organiser must ensure an appropriate legal basis and the required safeguards.

More detailed information may be requested at info@be-hempy.si.

22. Rights of the Individual

In accordance with the GDPR and depending on the specific legal basis, an individual has the right to request:

• access to personal data,
• rectification,
• erasure,
• restriction of processing,
• data portability,
• objection to processing.

Where processing is based on consent, the individual may withdraw it at any time.

A request may be sent to:

info@be-hempy.si

Before fulfilling a request, the organiser may verify the applicant’s identity in justified cases.

23. Unsubscribing from E-Newsletters

The recipient may unsubscribe from marketing emails at any time via the unsubscribe link in the received message or in the manner specified in the message.

Unsubscribing from marketing does not in itself affect data processing required due to a giveaway already conducted, legal obligations or other valid legal bases.

24. Complaint

If an individual believes that their personal data is being processed contrary to regulations, they may contact the organiser at:

info@be-hempy.si

They also have the right to lodge a complaint with the

Information Commissioner of the Republic of Slovenia.

25. Social Networks

If a giveaway takes place via Facebook, Instagram or another social network, certain data may also be processed in accordance with the rules and privacy policy of the operator of the relevant platform.

Where appropriate, the special terms of an individual giveaway also include a statement that the giveaway is not sponsored, endorsed, administered by or associated with the relevant platform, where this reflects the actual circumstances and the platform’s rules.