Privacy Policy
Effective Date: May 1, 2026
1. ABOUT THIS PRIVACY POLICY
This Privacy Policy explains how XCLUSIV Digital (“XCLUSIV”, “we”, “us”, or “our”) collects, uses, stores, protects, and discloses personal information.
This Policy applies to XCLUSIV Digital and to services and platforms operated by XCLUSIV, including 876Promotions.
876Promotions is a service and brand operated by XCLUSIV Digital. It is not a separate legal entity.
We are committed to protecting your privacy and handling personal information responsibly and in accordance with applicable Jamaican data protection requirements, including the Data Protection Act, 2020.
2. WHAT INFORMATION DO WE COLLECT?
The information we collect depends on how you interact with us.
When you participate in a promotion operated through 876Promotions, we may collect:
- Your title, such as Mr., Miss, or Mrs.;
- First name;
- Last name;
- Email address;
- Telephone number;
- Information submitted as part of your promotion entry; and
- A photograph or image of your purchase receipt where the applicable promotion requires proof of purchase.
A purchase receipt may contain information such as the store where the purchase was made, products purchased, purchase date and time, and receipt or invoice number.
We collect this information because it is needed to administer and validate the relevant promotion.
We do not ask promotion participants to provide unnecessary information such as government identification numbers, home addresses, date of birth, gender, nationality, or other unrelated personal information unless a particular promotion specifically requires information that is lawful and necessary for that promotion.
3. HOW DO WE USE YOUR INFORMATION?
For promotion participants, we use personal information to:
- Receive and record your entry;
- Confirm that your entry meets the applicable promotion requirements;
- Validate proof of purchase where required;
- Administer the promotion;
- Select winners;
- Contact potential winners;
- Confirm prize arrangements;
- Respond to enquiries concerning the promotion;
- Provide relevant information to the sponsoring client where necessary to administer the promotion;
- Comply with applicable legal or regulatory requirements; and
- Provide winner information to the Betting, Gaming and Lotteries Commission where requested or required.
We do not use information collected through a promotion for unrelated XCLUSIV Digital marketing.
We do not sell or rent promotion participant information to third parties.
4. PROMOTION WINNERS
The rules of a particular promotion may provide for the publication of a winner’s name and, where applicable, photographs or other promotional content.
Where this is part of the applicable promotion rules, the requirements will be communicated to participants as part of the promotion’s terms and conditions.
Winner information may also be provided to the promotion’s sponsoring client or the Betting, Gaming and Lotteries Commission where necessary or lawfully requested.
5. HOW DO WE SHARE YOUR INFORMATION?
We may share personal information where reasonably necessary to administer a promotion, provide our services, comply with legal requirements, or protect our rights.
Depending on the circumstances, information may be shared with:
- The business sponsoring the relevant promotion;
- Authorized persons working on the administration of the promotion;
- The Betting, Gaming and Lotteries Commission;
- Technology and service providers that support the operation of our websites and systems; and
- Government, regulatory, legal, or law-enforcement authorities where disclosure is required or permitted by law.
We do not sell or rent personal information collected through our promotions.
6. THIRD-PARTY SERVICES
We use third-party technology providers to help us operate our websites, applications and services.
These may include providers such as:
- FastComet – We use FastComet for hosting and infrastructure supporting the 876Promotions platform and associated database.
- ManyChat – We use ManyChat to support chatbot functionality. Where participants submit information through a ManyChat interaction, the relevant information may be transmitted to our promotion system and may also be stored by ManyChat as a contact.
- Google – We use Google services for business email and, on the XCLUSIV Digital website, analytics and website-related functionality.
- Cloudflare – We use Cloudflare in connection with security and website infrastructure for 876Promotions.
- Meta – Meta technologies, including Meta Pixel, may be used on 876Promotions for advertising measurement and related website functionality.
These providers may process information through infrastructure located outside Jamaica. We take reasonable steps to ensure that third-party processing is appropriately managed and that personal information is handled in accordance with applicable requirements.
7. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
Our websites may use cookies, analytics tools, pixels, tags, or similar technologies to support website functionality, security, analytics, advertising measurement, and related purposes.
For example, XCLUSIV Digital uses Google Analytics on its website, while 876Promotions may use Meta Pixel and Google Tag Manager.
These technologies may allow information about website activity or the way a device interacts with a website to be processed by the relevant service provider.
The exact information collected may depend on the technology, browser, device, and configuration in use.
We do not use these technologies to intentionally identify promotion participants by name for our own marketing purposes.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
We do not keep personal information indefinitely.
For 876Promotions, participant information will normally be retained for one (1) year after the relevant promotion has been completely closed.
A promotion is considered completely closed after winner selection, winner contact, prize fulfillment, and any reasonably necessary administrative or regulatory follow-up have been completed.
After the applicable retention period, information will be securely deleted, destroyed, anonymized, or otherwise disposed of unless there is a legitimate reason to retain it for longer, such as a legal, regulatory, contractual, audit, or dispute-related requirement.
9. HOW DO WE PROTECT YOUR INFORMATION?
We use reasonable technical and organizational measures designed to protect personal information from unauthorized access, misuse, loss, destruction, alteration, or disclosure.
Our controls include measures such as:
- Secure website connections;
- Individual user accounts;
- Multi-factor authentication for administrative access to 876Promotions;
- Restrictions on repeated unsuccessful authentication attempts;
- Automatic session expiry following inactivity;
- Restricted database and server access;
- Access and server logging where available;
- Regular backups; and
- Controlled administrative access.
No internet-based system can be guaranteed to be completely secure. We nevertheless take reasonable steps to protect the information entrusted to us.
10. YOUR PRIVACY RIGHTS
Depending on the circumstances and applicable law, you may have rights concerning your personal information.
These may include the right to:
- Know how your personal information is being used;
- Request access to personal information we hold about you;
- Request correction of inaccurate information;
- Request deletion where applicable;
- Object to or restrict certain processing where applicable;
- Request that your information be transferred to another data controller where applicable; and
- Make a complaint about the way your information is handled.
To submit a privacy request, contact us at info@xclusivdigital.com.
For matters specifically relating to 876Promotions, you may also contact info@876promotions.com.
11. VERIFYING YOUR IDENTITY
When you make a request concerning personal information, we may need to verify that you are the person to whom the information relates.
For example, we may ask you to confirm information already associated with your promotion entry, such as your name, email address, or telephone number.
This is intended to prevent personal information from being disclosed or changed by someone who is not authorized to receive it.
12. INFORMATION PROCESSED FOR OUR CLIENTS
When you participate in a promotion operated through 876Promotions, the promotion may be sponsored by another business.
In these circumstances, XCLUSIV Digital provides the technology and services used to administer the promotion, while the sponsoring client may determine the purpose and substantive rules of the promotion.
XCLUSIV processes participant information for the administration of the promotion and does not use that information for unrelated purposes of its own.
Where appropriate, XCLUSIV may coordinate with the sponsoring client concerning a participant’s request, complaint, or other matter relating to the promotion.
13. INFORMATION ABOUT CHILDREN
Our services are not intentionally designed to collect personal information from children where such collection is not appropriate or permitted.
Where a particular promotion has age restrictions, the applicable promotion rules will state those requirements.
If we become aware that personal information has been collected in circumstances where it should not have been, we will take reasonable steps to address the situation.
14. INTERNATIONAL PROCESSING
Some of the service providers we use may operate or maintain infrastructure outside Jamaica.
As a result, personal information may be processed or stored outside Jamaica when using certain services.
We do not intentionally transfer promotion participant information overseas for sale or unrelated marketing.
Where international or cross-border processing applies, we take reasonable steps to manage that processing in accordance with applicable data protection requirements.
15. DATA BREACHES
We maintain procedures for responding to suspected or confirmed personal data breaches.
If a security incident affects personal information, we will assess the incident, take reasonable steps to contain and address it, and make any notifications required by applicable law.
Where XCLUSIV is processing information on behalf of a promotion client, we may also notify and coordinate with the relevant client as appropriate.
16. YOUR QUESTIONS OR COMPLAINTS
If you have a question, concern, privacy request, or complaint about the way XCLUSIV handles your personal information, contact info@xclusivdigital.com.
For 876Promotions-related matters, you may also contact info@876promotions.com.
We will review privacy complaints and requests and respond in accordance with applicable requirements.
17. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy when our services, technology, processing activities, legal requirements, or privacy practices change.
The latest version will be published on the relevant XCLUSIV Digital website.
Where appropriate, material changes will be highlighted or otherwise communicated.
18. CONTACT INFORMATION
Registered Business Address:
XCLUSIV Digital
60 Sunset Avenue
Kingston 8
Jamaica
Primary Email:
info@xclusivdigital.com
876Promotions privacy enquiries:
info@876promotions.com
Effective Date: May 1, 2026
Policy Owner:
Managing Director
XCLUSIV Digital