Who We Are
This Privacy Policy explains how The Structural Advantage (THE STRUCTURAL ADVANTAGE LTD, a company registered in England and Wales under company number 17081276) handles personal data collected through this website, www.thestructuraladvantage.co.uk, and its associated Scorecard and waitlist.
For the purposes of UK data protection law — the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 — we are the data controller responsible for your personal data.
- Contact: info@thestructuraladvantage.co.uk
- Registered office: 124 City Road, London EC1V 2NX
- ICO registration: Registered with the UK Information Commissioner’s Office. Registration number: ZC178868
Information We Collect
We only collect what we need to run the waitlist and the membership. Depending on how you use the site, this may include:
- Details you give us — your name and email address when you complete the Scorecard or join the waitlist, plus the answers you choose to provide in the Scorecard (such as your current approach, goals, and what you consider a fair price).
- Messages you send us — the contents of any email or enquiry you send, and our reply.
- Technical & usage data — collected automatically as you browse, such as your IP address, browser type, device, referring page, and how you move through the site.
- Marketing preferences — your consent status and whether you have opted in or out of our communications.
- Advertising & measurement data — where you consent, tools such as the Meta Pixel and Conversions API record your interactions with our site and our ads so we can measure and improve our campaigns.
- Membership account data — if you buy a membership: your name, email address, account login details, the plan you chose, and your activity in the members’ area, such as which modules you have viewed.
- Payment data — your billing details, the amount and date of each payment, whether a payment succeeded or failed, and the last four digits and expiry of your card. We never see or store your full card number. Payments are handled by Stripe. If you choose Klarna at checkout, Klarna handles that payment and any agreement you make with it.
- Member tracker data — the entries, costs, outcomes, and notes you choose to record in the member tracker. This is covered in its own section below.
- Complaint and refund records — what you tell us when you cancel, ask for a refund, or make a complaint, and how we dealt with it.
We do not intentionally collect special category data (such as health, race, or religious belief), and we ask that you do not send it to us.
How We Use Your Information
Under UK GDPR we must have a lawful basis for using your data. We rely on the following:
| What we do | Lawful basis |
|---|---|
| Score your Scorecard answers and tell you whether you’re a fit | Your consent, and our legitimate interest in qualifying members |
| Add you to the waitlist and notify you about launch, pricing, and your founding spot | Your consent |
| Send the free Online Competition Guide and the pre-launch webinar invite | Your consent |
| Aggregate Scorecard responses to help set a fair launch price and shape the membership | Legitimate interest (responses are used in aggregate, not to identify you) |
| Respond to your enquiries | Legitimate interest in helping you |
| Keep the site secure, working, and free of abuse | Legitimate interest in protecting our service |
| Measure how our ads perform, attribute sign-ups, and reach relevant audiences (via the Meta Pixel and Conversions API) | Your consent |
| Create and run your membership account, give you access to the members’ area, and provide the materials, the Competition Board, and support you paid for | Performance of our contract with you |
| Take your payment, issue receipts, and deal with refunds and payment disputes | Performance of our contract with you |
| Prevent payment fraud | Legitimate interest in protecting against fraud |
| Handle cancellations, refunds, complaints, and payment disputes | Performance of our contract with you, legal obligation (consumer law), and our legitimate interest in resolving disputes fairly |
| Store and analyse your member tracker entries so you can see your own results | Performance of our contract with you |
| Compile aggregated, de-identified tracker data into factual reports for the Operator Accountability Programme, and forward them, where warranted, to regulators including the Gambling Commission and DCMS | Legitimate interest in the integrity of the competitions market and in protecting members and the wider public from unfair or unlawful operators |
| Keep a locked internal evidence record of the tracker entries behind each report we send to a regulator (see Evidence records behind regulator reports) | Legitimate interest in being able to show that our reports are accurate, and in establishing, exercising, or defending legal claims |
| Keep encrypted backup copies of our membership data so it can be restored if something goes wrong | Legitimate interest in protecting the service and your data against loss |
| Meet our legal and accounting obligations | Legal obligation |
Where we rely on consent, you can withdraw it at any time — see Marketing & opting out.
Member Tracker Data
If you hold a membership, the members’ area includes a tracker — a private record of the competitions you enter and what happens to them. Using it is optional. This section explains what it holds, what we do with it, and where it goes.
What the tracker holds
- Entries — the competitions you enter, the operator that ran each one, the date, the number of entries you took, and what you spent.
- Outcomes — whether you won, what you won, and its stated value.
- Prize fulfilment — whether a prize you won was actually delivered, and how long it took.
- Your notes — anything else you choose to record about an operator, such as where you felt a draw looked irregular. We ask you to name only the operating business, never an individual who runs it.
Only you and we can see your tracker. Other members cannot. We do not ask for, and you should not enter, bank details, card numbers, or anyone else’s personal data.
Our lawful basis
- Providing the tracker to you — performance of our contract with you. The tracker is part of what you paid for, so we need this data to deliver it.
- Aggregated analysis and the Operator Accountability Programme — our legitimate interests, and those of members and the wider public, in understanding how operators behave and in a fairer competitions market. We have assessed this basis and concluded that, because we work from aggregated and de-identified data and do not publish anything that identifies an individual, the impact on your privacy is minimal and does not override those interests. You can ask us for a summary of that assessment, and you can object to this use at any time — see Your rights.
- Reporting concerns to a regulator — our legitimate interests as above, or legal obligation where the law requires the disclosure.
- Keeping the evidence behind a report — our legitimate interests in being able to substantiate what we reported and in establishing, exercising, or defending legal claims. See below.
The Operator Accountability Programme
Where you record your own experience of an operator in the tracker — a flag, a note, the dates and detail — we compile that information across all members, strip out anything that identifies an individual, and combine it with our own observation of the operator's public listings into a factual record. Nothing in this programme is shown to members or made public: we do not publish operator scores, ratings, warnings, trust statuses, or notes, and we do not name operators publicly. The only output is a factual report that, where warranted, we forward to a regulator.
Evidence records behind regulator reports
A report is only as good as the evidence behind it. So whenever we send a report to a regulator, we take a locked copy of the underlying tracker entries the report was built from, together with the report itself and the date we sent it. Because it has to show which entries were counted, that internal copy includes the member each entry belongs to.
- It stays internal. The evidence record is not sent to the regulator or anyone else. Everything in the callout above still applies: we will not identify you unless you have given us separate written consent, or the law requires it.
- It is locked and limited. It contains only the entries behind that report, is stored encrypted and separately from the members' area, and is accessed only to answer a question about that report or to deal with a legal claim, complaint, or regulatory enquiry connected to it.
- It is kept for a fixed period. We keep each evidence record for at least two years from the date of the report, so that we can establish, exercise, or defend legal claims and answer regulators' questions about it. We then review it and delete it, unless a related claim, complaint, or enquiry is still live or reasonably expected, in which case we keep it only until that is resolved.
- It survives account closure. If your account closes, entries of yours that are held in an evidence record are kept for that period even though your live tracker data is deleted or anonymised. Nothing else about you is kept for this reason.
Your control
- Export — you can download your tracker data at any time.
- Correct or delete — you can edit or delete individual entries yourself, or ask us to delete the lot. Deleting an entry from your tracker does not change an evidence record already taken for a report that has been sent.
- Object — you can object to your data being used for the Operator Accountability Programme, and we will exclude you from future aggregation.
Once data has been aggregated and de-identified it can no longer be linked back to you, so it is no longer personal data and we cannot extract it from historic aggregates. Deleting your account removes your identifiable tracker data, except for any entries held in an evidence record as described above; it does not unwind aggregates already produced.
Cookies & Tracking
Cookies are small files stored on your device. We use them to make the site work and, where you agree, to measure and improve our advertising.
- Essential / functional — needed for the site and the embedded Scorecard to work. ScoreApp may set its own cookies when you take the Scorecard.
- Advertising & measurement — set only with your consent. We use the Meta Pixel and Meta’s Conversions API to measure how our Facebook and Instagram ads perform, to attribute sign-ups, and to show relevant ads on Meta platforms.
Non-essential cookies, including advertising cookies, are only set after you agree to them. You can withdraw your consent at any time — for example, through the cookie controls on the site or your browser settings — without affecting the cookies that are essential for the site to work.
Who We Share It With
We never sell your personal data. We share it only with the service providers who help us run the site, and only so far as they need it. These providers act as our processors under contract:
- ScoreApp — hosts and runs the Scorecard, and captures your opt-in and answers.
- IONOS — hosts this website and provides our email, which we use to send waitlist updates and the Competition Guide. We don’t use any separate email or marketing provider.
- Stripe Payments UK, Ltd — processes membership payments, including payments made with Klarna, and handles receipts, refunds, and fraud checks. We never see your full card number. Stripe also acts as a data controller in its own right for fraud prevention and for meeting its own legal obligations, under its own privacy policy.
- Klarna — if you choose Klarna at checkout, we share your name, email address and the order details with Klarna so it can offer you its payment options, carry out its own checks, and take payment. Klarna acts as a data controller in its own right for this, under its own privacy notice, and any payment agreement you make with it is between you and Klarna.
- Softr — provides the members’ area platform, including your account, the materials, the Competition Board, and the member tracker. Softr stores your account details and tracker data on our behalf.
- Meta Platforms Ireland Ltd (Facebook & Instagram) — where you consent, we use the Meta Pixel and Conversions API for advertising. This involves sharing data about your interactions with our site and, through the Conversions API, hashed identifiers such as your email address, so Meta can measure our ads and help us reach relevant audiences. Meta processes this under its own privacy policy.
We never share your data with anyone else for their own marketing. We may also disclose data where the law requires it, or to establish, exercise, or defend legal claims.
International Transfers
Some of our providers may store or process data outside the UK. Where that happens, we make sure the transfer is protected by an approved safeguard — such as UK adequacy regulations or the International Data Transfer Agreement (or its addendum to the EU Standard Contractual Clauses) — so your data keeps an equivalent level of protection. For example, where we use Meta’s advertising tools, your data may be transferred to Meta outside the UK under these safeguards. The same applies to Stripe and Softr, both of which have operations outside the UK; each is engaged under contract terms that include the International Data Transfer Addendum or equivalent safeguards. Klarna is based in Sweden, and transfers to the European Economic Area are covered by UK adequacy regulations.
How Long We Keep It
We keep your personal data only as long as we need it for the purposes above. In practice:
- Waitlist & Scorecard data — until you ask us to remove it, or until you tell us you’re no longer interested and a reasonable period has passed.
- Enquiries — for as long as needed to deal with your query and a short period afterwards.
- Membership account data — for as long as your membership is active, and for 12 months afterwards so we can reinstate your account if you come back or ask about it.
- Member tracker data — for as long as your membership is active. When your account closes, we give you at least 30 days to export it, then delete or anonymise it, except for any entries held in an evidence record (next item).
- Evidence records behind regulator reports — at least 2 years from the date of the report, kept for the establishment, exercise, or defence of legal claims. We then review each record and delete it, unless a related claim, complaint, or regulatory enquiry is still live or reasonably expected, in which case we keep it only until that is resolved. See Evidence records behind regulator reports.
- Complaint, cancellation, and refund records — for 6 years after the matter closes, because that is how long a related legal claim can be brought.
- Payment and transaction records — for 6 years from the end of the tax year they relate to, because tax law requires it.
- Backups — we keep encrypted weekly backup copies of membership data for up to 90 days. Data deleted from our live systems drops out of our backups as older copies are deleted, and we don't restore deleted data from a backup except to recover from a fault.
- Records we must keep by law — for the period the law requires (for example, tax records).
When we no longer need your data, we delete it or anonymise it so it can no longer identify you.
Your Rights
Under UK GDPR you have the right to:
- Be informed about how we use your data — this policy is part of that.
- Access a copy of the personal data we hold about you, including anything of yours held in an evidence record.
- Rectify data that is inaccurate or incomplete.
- Erase your data (the “right to be forgotten”) where there’s no good reason for us to keep it.
- Restrict how we use your data in certain circumstances.
- Object to processing based on legitimate interests, and to direct marketing at any time.
- Data portability — receive the data you gave us in a portable format.
- Withdraw consent at any time, where we rely on it.
These rights have some legal limits. In particular, we may not be able to erase, or stop using, entries held in an evidence record while we need them to establish, exercise, or defend legal claims. If that applies to a request you make, we will tell you, explain why, and tell you when the record is due for deletion.
To exercise any of these, email info@thestructuraladvantage.co.uk. We’ll respond within one month. Exercising your rights is free in most cases.
Marketing & Opting Out
We’ll only send you marketing emails — waitlist updates, launch news, the webinar invite — where you’ve agreed to receive them. Every marketing email includes an unsubscribe link, and you can opt out at any time by clicking it or emailing us. Opting out of marketing won’t affect any service messages we need to send you about your place on the waitlist.
Data Security
We take appropriate technical and organisational measures to protect your data against loss, misuse, and unauthorised access, including two-step verification on the accounts we use to run the service and encryption of our backups and evidence records. No method of transmission over the internet is completely secure, but we work to protect your data and to limit who can access it. If a breach occurs that risks your rights, we’ll notify the Information Commissioner’s Office and, where required, you.
Age & Children
The Structural Advantage is intended only for adults aged 18 or over. We do not knowingly collect data from anyone under 18. If you believe a minor has given us their data, contact us and we’ll delete it.
Third-Party Links
Our site and emails may link to other websites — including competition sites we reference and support organisations such as GamCare and GambleAware. We’re not responsible for the privacy practices of those sites, and this policy doesn’t cover them. Please read their own privacy policies before sharing data with them.
Changes to This Policy
We may update this policy from time to time. When we do, we’ll change the “Last updated” date at the top. Significant changes will be communicated to waitlist members and members where appropriate. Please check back periodically.
Contact & Complaints
Questions about this policy or how we handle your data? Email info@thestructuraladvantage.co.uk. Section 20 of our Membership Terms explains how we handle a complaint and how long each step takes.