This policy explains how Barton Technology Ltd, Company No. 3930086, of Suite 652, 124 City Road, London, EC1V 2NX (“we”, “us”, “our”), trading as Owner Foundry, collects and uses your personal data when you enter a competition at win.ownerfoundry.com. We are the data controller for the purposes of UK GDPR and the Data Protection Act 2018.
What we collect
When you enter a competition on this site, we collect:
your first name and email address;
your country — detected automatically from your connection when you enter, not asked for or taken from GPS/precise location;
marketing attribution: any UTM campaign parameters in the link you arrived on, the page that referred you, and the page you entered from;
your referral code and referral activity — who you referred, and (if someone else referred you) which entrant’s link you followed;
the points you earn and which optional actions (social follows, shares, daily bonus entries) you’ve completed, so we can total your entries into the draw.
We also collect two technical identifiers automatically, and we do not store either in a form that identifies your device or connection directly:
your IP address — kept only as a one-way cryptographic hash (HMAC), not the address itself, used to enforce a daily entry cap per connection and to flag suspicious entry patterns;
a coarse device fingerprint— your browser type and language combined with your IP address, also kept only as a one-way hash. This is not a persistent tracking identifier (we don’t use canvas/WebGL device fingerprinting); it exists only to catch the same person entering repeatedly from the same device.
If you win a prize, we may also ask you for further details needed to deliver it (for example a postal address) — that request is made directly and is not collected through this form.
Why we use it, and our lawful basis
To run the competition — confirming your entry, running the portal where you track your entries and complete bonus actions, totalling your points, running the prize draw, and notifying you if you win. Lawful basis: performance of a contract — entering creates an agreement between you and us on the terms of that competition.
To send you marketing emails about Owner Foundry, once you’ve entered. Lawful basis: consent, given when you submit the entry form (this is stated on the form itself, next to the “Enter now” button). Every marketing email includes an unsubscribe link, and unsubscribing never affects your existing entry into a competition you’ve already entered.
To prevent fraud and abuse— the IP and device-fingerprint hashes, the daily entry cap, and the bot-protection check (Cloudflare Turnstile) shown on the entry form all exist to stop automated or duplicate entries. Before any prize is awarded, we also manually review the winning entrant’s activity for signs of abuse. Lawful basis: our legitimate interest in running a fair competition.
Winner audit — keeping a record of who won, what they were awarded, and the fraud check carried out before award, so we can show the competition was run fairly if ever asked. Lawful basis: legitimate interest, and legal obligation where advertising standards rules require us to keep records of a promotion.
Analytics, only if you accept analytics cookies. Lawful basis: your consent, given via the cookie banner.
Who we share it with
We do not sell your personal data. We share it with the service providers we use to run this site, each acting as our processor and only for the purposes described above:
Our own contact database (BartMail)— the Barttech group’s own email platform, not a third-party marketing tool, and never sold or shared onward. Once you confirm your entry, your email address, first name, country and attribution data are added here so we can send you the emails described above.
Email delivery (Emailit) — the service that actually sends the emails BartMail queues on our behalf (entry confirmation, welcome, portal login links, and referral progress updates).
Email verification (Reoon)— receives your email address only, to check it’s a real, deliverable address before we act on your entry.
Bot protection (Cloudflare Turnstile)— runs a check in your browser when you submit the entry form to confirm you’re not an automated script.
Hosting and data storage (Vercel, Supabase) — host this site and store the competition database. They process technical data such as your IP address as part of delivering the site to you.
Error monitoring (Sentry) — records technical diagnostic information when something goes wrong on the site, which can include your IP address.
Analytics (Google Analytics 4 and Rybbit) — only after you accept analytics cookies. See Cookies below.
Some of these providers are based outside the UK, so your data may be transferred internationally. Where that happens we rely on the provider’s standard contractual clauses or an equivalent safeguard.
Cookies, analytics and advertising
A small number of cookies are strictly necessary to run this site and are set regardless of any cookie choice, because the site cannot work without them:
comp_session— keeps you signed in to your entrant portal. Signed so it can’t be tampered with; contains no readable personal data.
a referral cookie(named per competition) — set for 30 days when you follow someone else’s referral link, so that if you go on to enter, we can credit the right person’s referral. Contains only a referral code, no personal data.
cookie_consent_v2— remembers the cookie choice you make below, so we don’t ask you every visit.
Everything else is optional, and nothing optional runs until you choose. The banner offers three one-click choices — Accept all, Analytics only, or Reject all — and rejecting is exactly as easy as accepting.
Analytics cookies, if you accept them, let us see how the site is used — we currently use Google Analytics 4 and Rybbit for this.
Advertising cookies — the banner also offers an advertising/remarketing choice, but as things stand today no advertising or remarketing tag is active on this site: we haven’t connected an ad platform to it. If that changes, this page will be updated in the same change that adds the tag, and it will only ever run for visitors who have given advertising consent.
Our lawful basis for analytics and advertising cookies is your consent. We also send Google Consent Mode signals, so that if you refuse, no advertising identifiers are used even by a tag added later.
You can change or withdraw your choice at any time — it is as easy to withdraw as it was to give: . You can also clear cookies and browser storage through your browser settings.
International transfers
Where a provider named above processes data outside the UK, we rely on that provider’s standard contractual clauses or an equivalent recognised safeguard to protect your data.
How long we keep your data
We keep your entrant record for the competition you entered, and afterwards for as long as we reasonably need to complete the prize draw, the winner audit, and to deal with any dispute about the result — normally no more than 12 months after a competition closes, unless a longer period is needed to meet a legal or accounting requirement. You can ask us to delete your data sooner at any time using the contact details below; we’ll action that unless we have a legal reason to keep a specific record (for example, evidence we relied on to disqualify a fraudulent entry).
Your rights
Under UK GDPR you have the right to:
access the personal data we hold about you;
have inaccurate data corrected;
ask us to delete your data (“right to be forgotten”);
restrict or object to processing, including objecting to marketing at any time;
receive your data in a portable format, where that applies;
withdraw consent at any time — this doesn’t affect processing carried out before you withdrew it.
This site doesn’t have self-service account deletion or export buttons — entrants aren’t asked to create a password-protected account, so the simplest correct route is a direct request. To exercise any of these rights, contact us at ownerfoundry.com/contact. We aim to respond within one month.
If you are unhappy with how we’ve handled your personal data, you have the right to complain to the Information Commissioner’s Office at ico.org.uk.
US visitors
If you’re in the US, we honour the same rights described above for any request you make — access, correction, deletion and objection to marketing — regardless of which state you’re in. We don’t sell personal data to anyone, so there’s nothing to opt out of on that front. Use the same contact details above for any request.
Children
This competition is open to entrants aged 18 and over only (see our Terms). It is not directed at children, and we ask that nobody under 18 submits their details.
Changes to this policy
We may update this policy from time to time. The “last updated” date at the top reflects when it was most recently revised.
Contact
Barton Technology Ltd, Suite 652, 124 City Road, London, EC1V 2NX. Contact: ownerfoundry.com/contact