Privacy Policy

1. Data controller

Emperor Labs Oy. Contact for privacy matters: privacy@raffler.fi.

2. What data we collect and why

• Account information (email, display name) — account creation and sign-in. Basis: performance of a contract.
• Entry data (which raffles you've entered, win/loss, redemption status) — running the raffle and delivering the prize. Basis: performance of a contract.
• Location data (voluntary, at check-in) — confirming your presence at an event venue. Basis: consent (your device's own location permission).
• Referral data (who invited whom) — running the friend-referral feature.
• Push notification identifier — raffle status and win notifications. Basis: consent.
• Partner data sharing (display name, email) — shared with our partners for marketing purposes. You accept the sharing with the raffle rules when you enter a raffle; on the prize wheel it is a separate, optional choice. Basis: consent, which you can withdraw at any time in your profile.
• Usage logs (IP address, error logs) — security and abuse prevention. Basis: legitimate interest.

We do not collect special categories of personal data (health, religion, political opinions, etc.).

3. Automated decision-making

Winner selection happens automatically via a random algorithm, without any case-by-case human review. The outcome is a technically produced random selection, not a decision based on the controller's discretion.

4. Who we disclose data to

Raffle organizer: Raffle organizer — for prize delivery and contact, when you enter that raffle.

Partners: Partners — once you have accepted the sharing when entering a raffle, or separately on the prize wheel. You can withdraw it in your profile at any time.

Processors: Processors (technical infrastructure): Supabase (database, EU/Ireland), Resend (sending email: account confirmation and password reset codes, and win notifications; Resend, Inc., United States), plus the Apple/Google services and browser vendors' Web Push services used to deliver push notifications. Some processors operate outside the EU/EEA; those transfers rely on the EU's standard contractual clauses.

5. Retention period

Account data is kept until account deletion. Entry data is kept for 3 years from your last entry. Usage logs are kept for 12 months.

6. Your rights

• access your data (the "Export my data" feature in your profile produces a machine-readable JSON export),
• correct inaccurate data,
• delete your data (the "Delete my account" feature),
• withdraw partner data sharing at any time from your profile,
• transfer your data from one system to another,
• lodge a complaint with the supervisory authority: Office of the Data Protection Ombudsman (tietosuoja.fi).

We respond to requests within one month at the latest.

Request account deletion

7. Minors

General use of the Service does not require users to be 18 or older. Some raffles are marked 18+, and entering them requires users to confirm that they are at least 18 years old. We do not collect a date of birth for this confirmation.

8. Contact

Privacy matters: privacy@raffler.fi. You may also contact the Office of the Data Protection Ombudsman: tietosuoja.fi. See also the Terms of Service.