Privacy Policy — The Structural Advantage

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, which holds your card details for us so that instalments can be collected.
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.

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, picks, and support you paid for	Performance of our contract with you
Take your payment, collect instalments, issue receipts, and deal with failed payments and refunds	Performance of our contract with you
Recover unpaid instalments and prevent payment fraud	Legitimate interest in being paid for what we supply and in protecting against fraud
Store and analyse your member tracker entries so you can see your own results	Performance of our contract with you
Aggregate and de-identify tracker data for the Operator Accountability Programme, and report concerns 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
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.

The Operator Accountability Programme

We combine tracker data across all members, strip out anything that identifies an individual, and use the result to build a picture of how each operator conducts itself — whether entry caps are honoured, whether draws happen when they should, and whether prizes are delivered. We do not publish operator scores, ratings, or warnings to members, and we do not name operators publicly. The picture feeds our own internal assessment and, where warranted, a report to a regulator.

Sharing with the Gambling Commission. Where our aggregated findings suggest an operator is persistently breaching the terms of its own competitions, or may be running an unlawful lottery or otherwise breaching gambling law, we may report them to the Gambling Commission and to the Department for Culture, Media and Sport (DCMS). Depending on the issue, we may also report to the Advertising Standards Authority, the Competition and Markets Authority, or Trading Standards. These reports are made on aggregated, de-identified data about operators — not about you. We will not name you or pass on data that identifies you unless you have given us separate written consent, or the law requires it. If a regulator later asks us to substantiate a report and that would mean identifying you, we will come to you first and ask, unless we are legally barred from doing so.

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.
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; 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, stores your card details securely so instalments can be collected, 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.
Softr — provides the members’ area platform, including your account, the materials, 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.

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.
Payment and transaction records — for 6 years from the end of the tax year they relate to, because tax law requires it.
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.
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.

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. 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. 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 where appropriate. Please check back periodically.

Contact & Complaints

Questions about this policy or how we handle your data? Email info@thestructuraladvantage.co.uk.

Not happy with our response? You have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection, at ico.org.uk or on 0303 123 1113. We’d appreciate the chance to put things right first, so please come to us before you approach the ICO.